June, 11 2015 

Attn: 

U. S. Department of Transportation Docket Operations 

West Building Ground Floor, Room wl2-140 1200 New 

Jersey Ave, SE Washington, DC 20590 

RE: VISUAL SYSTEMS LLC REQUESTS AN EXEMPTION FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.l 13(a) & (b), 91.7(a), 

91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), AND 91.417(a) & (b) 

CONCERNING COMMERCIAL OPERATION OF OJI Phantom 3 UNMANNED AIRCRAFT 

SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM 

ACT OF 2012 (PUBLIC LAW 112-95} 

Submitted By: 

Charles Rohr, President 

Visual Systems, LLC 

13002 East 39th Lane 

Spokane Valley, WA 99206 
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 ......................................................................... 6 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH THE VISUAL SYSTEMS, LLC 

SEEKS EXEMPTION ............................................................................................................ 7 THE 

EXTENT OF RELIEF THE VISUAL SYSTEMS LLC SEEKS AND THE REASON THE VISUAL 

SYSTEMS LLC SEEKS THE RELIEF .............................................................. 10 

THE REASONS WHY GRANTING VISUAL SYSTEMS LLC REQUEST WOULD BE 

IN THE PUBLIC INTEREST ............................................................................................ 12 THE 

REASONS WHY GRANTING THE EXEMPTION TO VISUAL SYSTEMS LLC WOULD 

NOT ADVERSELY AFFECT SAFETY .............................................................. 14 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER ................... 25 

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT VISUAL SYSTEMS LLC .................................................. 25 

CONCLUSION ..................................................................................................................... 25 

APPENDICES ......................................................................................... 26 
GLOSSARY OF ABBREVIATIONS 

AGL 

AOI 

ATC 

ATO 

AV 

CFR 

COA 

FAA 

FAR 

GCS 

GPS 

LOL 

NAS 

NOT AM 

PIC 

Section 333 

so 

SOP 

UA 

UAS 

VFR 

VLOS 

VMC 

VTOL 

Above Ground Level 

Area of Interest 

Air Traffic Control 

Air Traffic Organization 

Aerial Vehicle 

Code of Federal Regulations 

Certificate of Authorization 

Federal Aviation Administration 

Federal Aviation Regulation 

Ground Control Station 

Global Positioning System 

Loss of Link 

National Airspace System 

Notice to Airman 

Pilot In Command 

FAA Modernization and Reform Act of2012 (FMRA) 

Safety Observer 

Standard Operating Procedures 

Unmanned Aircraft 

Unmanned Aircraft System 

Visual Flight Rules 

Visual Line of Site 

Visual Meteorological Conditions 

Vertical Takeoff and Landing 

VISUAL SYSTEMS LLC seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, 
SUMMARY 

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

91.7(a), 91.121, 91.15 l(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.4 l 7(a) & (b), to 

operate an Unmanned Aircraft System (OJI Phantom 3) pursuant to Section 333 of the FAA 

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

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

aerial video and photography of construction sites, residential and commercial real estate, civil 

landscapes and events over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

VISUAL SYSTEMS LLC is a startup company located in Spokane Valley WA. It's President 

Charles Rohr is a certificated private pilot and former Air Force navigator with over 3000 hours 

of military flying time, including 35 combat missions in Desert Storm. VISUAL SYSTEMS 

LLC intends to conduct commercial drone operations focusing primarily on first responder 

training videos, fire marshal arson investigations, building/structure inspections, property 

appraisals, real estate marketing and economic development. 

My staff has safely flown small RC electric quadcopters recreationally for approximately 2 years 

without incident. 

BACKGROUND 

VISUAL SYSTEMS, LLC seeks an exemption to operate OJI Phantom 3 system for compensation or 

hire within the NAS. The OJI Phantom 3 is vertical takeoff and landing (VTOL) Unmanned Aircraft 

(UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The 

OJI Phantom 3 has a maximum gross weight of approximately 2.8 lb. while having a diagonal 

dimension of 23.2", a maximum speed of approximately 16.4'fps and a maximum flying height of 

400'. The OJI Phantom 3 is equipped with four main rotors; driven by Lithium Polymer battery 

powered electric motors. 
BASIS FOR PETITION 

Petitioner, VISUAL SYSTEMS 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 OJI Phantom 3, 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)(l), 91.409(a)(l) & (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, VISUAL SYSTEMS LLC operation of DJI Phantom 3 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, VISUAL SYSTEMS LLC requests relief from Sections 91.405(a), 91.407(a)(I), 

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

that only apply to aircraft with an airworthiness certificate. 

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

safety will be ensured. VISUAL SYSTEMS LLC will use experienced personnel or technicians to 

perform maintenance, alterations, or preventive maintenance on the U AS using the methods, 

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

OJI Phantom 3 Instruction Manual). Furthermore, VISUAL SYSTEMS LLC will document and 

maintain all maintenance records for the OJI Phantom 3 UAS. 

Relief from certain requirements of Section 61.l 13(a) and (b), entitled Private Pilot 

Privileges/Pilot in Command, is requested to the extent necessary to allow a Pilot In Command 

(PIC) holding a private pilot or higher level certificate and who meets minimum flight hour and 

currency requirements, that the PIC is able to safely operate a UAS in a manner consistent with 

this exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels vehicles and structures. 

The OJI Phantom 3 that will be operated by VISUAL SYSTEMS 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. 
VISUAL SYSTEMS LLC also seeks an exemption from the requirements of Section 91.121, entitled 

Altimeter Settings, as the OJI Phantom 3 UAS will not have a typical barometric altimeter onboard. 

However, altitude information of the OJI Phantom 3 UAS will be provided to the PIC via Global 

Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks 

from the UA to the GCS for active monitoring of the flight path. This altitude information, combined 

with VISUAL SYSTEMS LLC operation of the OJI Phantom 3 UAS within visual line of sight, at or 

below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121. 

Additionally, The VISUAL SYSTEMS LLC seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements/or flight in VFR conditions. The VISUAL SYSTEMS LLC 

submits that safety will not be affected by operation of the OJI Phantom 3 UAS during daylight hours 

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

power to fly for a total duration of approximately 23 minutes. Battery power indicators are also able 

to show exactly how much battery power is left, as well as how much time is needed to return safely 

back to point of take off. 

In accordance with 14 C.F.R. § 11.81, VISUAL SYSTEMS LLC provides the following information 

in support of its petition for exemption: 

A. Name And Address Of The Petitioner. 

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

VISUAL SYSTEMS LLC 

13002 East 39th Lane 

Spokane Valley, WA 99206 

POC: Charles Rohr 

509 991-3667 

crohr530@gmail.com 
B. The Specific Sections Of 14 C.F.R. From Which VISUAL SYSTEMS LLC Seeks Exemption. 

1. The VISUAL SYSTEMS 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. The VISUAL SYSTEMS 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. VISUAL SYSTEMS LLC Seeks Exemption From The Requirements Of Section 

91.121. 

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

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

that aircraft, as the case may be, by reference to an altimeter that is set, when operating-

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

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

100 nautical miles of the aircraft; 

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

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. VISUAL SYSTEMS LLC Seeks Exemption From The Requirements Of Section 91.lSl(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. 

S. The VISUAL SYSTEMS LLC Seeks Exemption From The Requirement Of Section 

91.40S(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. VISUAL SYSTEMS LLC Seeks Exemption From The Requirements Of Section 91.407(a)(l) 

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-

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

this chapter(.] 

7. VISUAL SYSTEMS LLC Seeks Exemption From The Requirements Of Sections 91.409(a)(l) 

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 -

(I) 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. VISUAL SYSTEMS LLC Seeks Exemption From The Requirements Of Sections 91.417(a) 

And 91.417(b). 

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

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

owner or operator shall keep the following records for the periods specified in paragraph 

(b) of this section: 

(I) 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. 

(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)(l) 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 VISUAL SYSTEMS LLC Seeks And The Reason The VISUAL 

SYSTEMS Seeks The Relief. 

1. Extent Of Relief VISUAL SYSTEMS LLC Seeks And The Reason The VISUAL SYSTEMS 

LLCSeeks 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 flighthour 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.l B(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, VISUAL SYSTEMS LLC submits that an equivalent level of safety 

will be maintained because no PIC will be allowed to operate the Dil Phantom 3 UAS unless that PIC 

has met certain flight-hour and currency requirements, demonstrating that the PIC is able to safely 

operate either the DJI Phantom 3 UAS in a manner consistent with the operations specifications as 

described in this exemption, including evasive and emergency maneuvers, as well as maintaining 

appropriate distances from people, vessels, vehicles and structures. 

Further, VISUAL SYSTEMS LLC submits that all flights of the DJI Phantom 3 UAS, conducted by 

the PIC pursuant to the grant of this Petition: (1) will be incidental to VISUAL SYSTEMS LLC's 

business; and (2) will not carry passengers or property for compensation or hire. 
2. Extent Of Relief VISUAL SYSTEMS LLC Seeks And The Reason VISUAL SYSTEMS LLC 

Seeks Relief From Section 91.7(a). 

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

allow VISUAL SYSTEMS LLC to determine that the OJI Phantom 3 UAS are in airworthy condition 

prior to every flight by ensuring that the U AS is in compliance with the operating documents (i.e., 

VISUAL SYSTEMS LLC Aerial Operations Manual, Monthly Maintenance Log, and OJI Phantom 3 

Instruction Manual). 

VISUAL SYSTEMS LLC seeks the requested relief because the OJI Phantom 3 UAS do not require 

an airworthiness certificate in accordance with 14 C.F .R. Part 21, Subpart H. Therefore, VISUAL 

SYSTEMS LLC will ensure that the OJI Phantom 3 UAS are in airworthy condition based upon its 

compliance with the operating documents (i.e., Monthly Maintenance Log, and OJI Phantom 3) 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 VISUAL SYSTEMS LLC Seeks And The Reason VISUAL SYSTEMS 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 3 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), VISUAL 

SYSTEMS LLC seeks the requested relief because the DJI Phantom 3 UA's altimeter may be set on 

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

flight. 

Considering the limited altitude of the proposed operations, relief from 14 CPR 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 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 VISUAL SYSTEMS LLC Seeks And The Reason VISUAL SYSTEMS LLC 

Seeks Relief From Section 91.15l(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 OJI Phantom 3 UAS during daylight hours 

in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 23 

minutes. VISUAL SYSTEMS LLC seeks the requested relief because without an exemption from 

Section 91.151 (b ), the flight time duration of the 
battery powered OJI Phantom 3 UAS will severely constrain the practicality of any aerial video or 

still photo flight operations that VISUAL SYSTEMS LLC proposes to conduct pursuant to this 

Petition. 

Significantly, as set forth below, the technical specifications of the OJI Phantom 3 UAS, the DJI 

Phantom 3 operating documents, and VISUAL SYSTEMS LLC's proposed operating limitations, 

ensure that VISUAL SYSTEMS LLC will safely operate the battery powered OJI Phantom 3 UAS 

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

with enough battery power to fly for a total duration of23 minutes. 

S. Extent Of Relief VISUAL SYSTEMS LLC Seeks And The Reason VISUAL SYSTEMS LLC 

Seeks Relief From Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), And 91.417(a) & (b). 

Since Sections 91.405(a), 91.407{a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & {b) only apply to 

aircraft with an airworthiness certificate, VISUAL SYSTEMS LLC requests relief from these 

Sections because the OJI Phantom 3 UAS do not require airworthiness certificates. As set forth more 

fully below, the OJI Phantom 3 UAS meet the conditions ofFMRA Section 333 for operation without 

an airworthiness certificate. Accordingly, VISUAL SYSTEMS LLC 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 VISUAL SYSTEMS 

LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual). 

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

OJI Phantom 3 UAS. 

D. The Reasons Why Granting VISUAL SYSTEMS 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 VISUAL SYSTEMS LLC to 

safely, efficiently, and economically perform aerial video and photography of construction sites, real 

estate, events and civic landscape over certain areas of the United States. 

Additionally, use of the OJI Phantom 3 UAS will decrease congestion of the NAS, reduce pollution, 

and provide significant benefits to the economy. Notably, the benefits of VISUAL SYSTEMS LLC's 

proposed operation of the OJI Phantom 3 UAS will be realized without implicating any privacy 

issues. 

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

The DJI Phantom 3 UAS are battery powered and serve as a safe, efficient, and economical 

alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the 
amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a 

OJI Phantom 3 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air 

pollution, as well as increase the safety of life and property in the air and on the ground. 

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

airports caused by arriving and departing aircraft will be reduced. The OJI Phantom 3 U AS 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 3 UAS. 

Conducting aerial acquisitions with the OJI Phantom 3 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 OJI Phantom 3 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 OJI Phantom 3 UAS, while reducing the carbon footprint of aerial 

acquisitions, also eliminates noise pollution, as the UAS are propelled by battery powered electric 

motors, rather than an internal combustion engine. 

By using the OJI Phantom 3 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 UAS (weighing approximately 2.8 

pounds at their maximum gross weight with diagonal dimension of 23.2 inches, 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 3 UAS 

Will Benefit The Economy. 

In addition to being safe and efficient, the DJI Phantom 3 UAS are also an economical alternative to 

using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom 3 

UAS will allow United States based companies, like VISUAL SYSTEMS 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 OJI Phantom 3 U AS 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 OJI Phantom 3 UAS, companies such as VISUAL SYSTEMS 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 OJI Phantom 3 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, 

VISUAL SYSTEMS LLC's proposed operation of the OJI Phantom 3 UAS will not implicate any 

privacy issues. Specifically, the OJI Phantom 3 UAS will be operated only in compliance with 

operating documents (i.e., VISUAL SYSTEMS LLC Aerial Operations Manual, Monthly 

Maintenance Log, and OJI Phantom 3 Instruction Manual) which requires property owner 

involvement as well as local law enforcement notification, and in accordance with the Federal 

Aviation Regulations, including the minimum altitude requirements of 14 

• §91.119. 

• 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 VISUAL SYSTEMS LLC Seeks Exemption. 

1. Reasons Why The DJI Phantom 3 OAS Meet The Conditions Of The FAA Modernization 

and Reform Act of2012 (FMRA) Section 333. 

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

aircraft and its operation, VISUAL SYSTEMS LLC's operation of the DJI Phantom 3 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(]). 

(c) Requirements for Safe Operation.--Jfthe 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, VISUAL SYSTEMS LLC submits that the DJI Phantom 3 UAS can 

operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics 

of the DJI Phantom 3 UAS; (b) the pilot certification requirement; and (c) the specific operating 

limitations. 
a. The Specifications Of The nn Phantom 3 OAS Demonstrate Its Safe Characteristics. 

The DJI Phantom 3 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 3 OAS. 

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

Manual, attached hereto as Appendix A. 

ii. The DJI Phantom 3 UAS Global Positioning Modes Enable The UAS To Remain 

Within A Defined Operational Area. 

The DJI Phantom 3 UAS may be operated in both manual and global positioning flight modes. A 

complete description of the flight and navigational modes of the OJI Phantom 3 UAS is provided at 

pages 11 of the DJI Phantom 3 User Manual attached hereto as Appendix A. 

iii. The DJI Phantom 3 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 3 UAS will remain stationary, in flight, for 3 seconds 

or more. If, after 3 seconds, the DJI Phantom 3 UAS does not reacquire control link data from the 

GCS, the UAS will assume that the Control Link is lost and the 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 UAS are set forth at pages 12 

through 14 of the DJI Phantom 3 User Manual, attached hereto as Appendix A. 

iv. The Dn Phantom 3 GCS And Its Operation. 

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

control software is provided at pages 23 through 29 of the DJI Phantom 3 User Manual. DJI Phantom 

3 User Manual is attached hereto as Appendix A. 

b. Flight Operations Of Dn Phantom 3 UAS Is Limited To The Line Of Sight Of A 

Certificated Pilot in Command With A Safety Observer. 

VISUAL SYSTEMS LLC video production staff will be the only persons to act as a pilot in 

command (PIC) of the DJI Phantom 3 UAS. Additionally, a safety observer will assist him at all 

times during flight time. 

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

Limitations. 

In seeking this exemption, VISUAL SYSTEMS LLC proposes to commercially operate DJI 

Phantom 3 U AS 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 UAS weighing less than 55 pounds 

maximum gross weight: OJI Phantom 3 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 UAS may not be flown at an indicated airspeed exceeding 20 knots. 

4. The UA must be operated at an altitude of no more than 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 A TC. All altitudes reported to A TC 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 U AS 

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 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 componen~ 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 equipmen~ not already covered in the relevant sections of the 

operating documents. 

13. The operator must follow the UAS manufacturer's aircraft/componen~ 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 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 sport pilot certificate and at least a current driver's 

license. 

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. § I.I. 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 U A with 25% battery power remaining. 

25. The operator must obtain an Air Traffic Organization (A TO) 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 

(NOT AM) 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 A TO 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 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. 

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: 

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; 

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; 
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. 

VISUAL SYSTEMS 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 Oil Phantom 3 UAS unless 

that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC 

is able to safely operate the OJI Phantom 3 UAS in a manner consistent with the exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures. 

Considering VISUAL SYSTEMS LLC's proposed area of operations, and the operating limitations 

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

commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to 

safely operate the OJI Phantom 3 UAS, VISUAL SYSTEMS LLC submits that the additional manned 

airmanship experience of a commercially certificated pilot would not correlate to the airmanship 

skills necessary for VISUAL SYSTEMS LLC's specific proposed flight operations. 

The FAA has previously granted relief from Section 61.l 13(a) and (b) specific to UAS, in 

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

11063, II 064, 11065, 11066, II 067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, ll 153, 

11156, 11158, 11159, 11160, 11161). 

VISUAL SYSTEMS LLC will not allow any PIC to operate the OJI Phantom 3 UAS unless that PIC 

has demonstrated, by meeting minimum flight-hour requirements or the OJI Phantom 3 UAS training 

and currency requirements, that the PIC is able to safely operate the OJI Phantom 3 UAS in a manner 

consistent with this exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles and structures. 

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 

61.5l(b), 25 hours oftotal time as a UAS rotorcraft pilot (with a minimum of5 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 

VISUAL SYSTEMS LLC's proposed operations. The Administrator has held that prior documented 

flight experience that was obtained in compliance with applicable regulations would ensure safe 

operations, stating as follows: 

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

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

logged, in a manner consistent with 14 CFR 61.51 (b ), 25 hours of total time as a U AS 

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 IO 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, VISUAL SYSTEMS LLC will ensure safe operations by not allowing any PIC to 

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

and currency requirements, that the PIC is able to safely operate the OJI Phantom 3 UAS in a manner 

consistent with the exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles and structures. 

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not 

Adversely Affect Safety. 
The equivalent level of safety established by Section 91.7(a) will be maintained because prior to 

every flight, VISUAL SYSTEMS LLC will ensure that the DJI Phantom 3 UAS is in an airworthy 

condition based upon the UAS's compliance with its operating documents and as stated in the 

conditions and limitations herein. 

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

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

11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 

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

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not 

Adversely Affect Safety. 

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

information of the DJI Phantom 3 UAS will be provided to the PIC via GPS equipment and a radio 

communications telemetry data link, which downlinks from the UA to the GCS for active monitoring 

of the flight path and altitude. This altitude information, combined with VISUAL SYSTEMS LLC's 

operation of the DJI Phantom 3 UAS within visual line of sight, at or below 500 feet AGL, will 

ensure a level of safety equivalent to Section 91.121. The altitude information will be generated by 

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

automatically established by the UAS 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 91.15l(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 

91.15l(b) as a result of (1) the technical specifications of the DJI Phantom 3 UAS; (2) the limitations 

on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, 

VISUAL SYSTEMS LLC will ensure that it will safely operate the battery powered OJI Phantom 3 

UAS during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 

23 minutes. 

Here, as in Exemption No. 11109, the technical specifications of the OJI Phantom 3 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 3 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 I 0% remaining battery 
power. At the critically low battery level, the OJI Phantom 3 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, l 0808, 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)(l), 

91.409(a)(l) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety. 

In seeking this exemption, VISUAL SYSTEMS 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)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) will be met because VISUAL SYSTEMS 

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., 

VISUAL SYSTEMS LLC Aerial Operations Manual, Monthly Maintenance Log, and OJI Phantom 3 

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

maintenance records for the OJI Phantom 3 UAS. 

Since the OJI Phantom 3 UAS will be inspected as prescribed by the operating documents, VISUAL 

SYSTEMS LLC will maintain the equivalent level of safety established by Sections 91.405(a}, 

91.409(a)(l), and 91.409(a)(2). A copy of the OJI Phantom 3 User Manuals are attached hereto as 

Appendix A and B; a copy of the OJI Phantom 3 UAS Maintenance LOG is attached hereto as 

Appendix C. 

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

will use trained technicians to perform maintenance, alterations or preventive maintenance on the 

UAS using the methods, techniques, and practices prescribed by the operating documents. 

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

Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the OJI Phantom 3 VAS 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)(l}, 

91.409(a)(l) & (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 VISUAL SYSTEMS LLC's proposed operating limitations, the operating 

documents, and the technical aspects of the OJI Phantom 3 UAS, VISUAL SYSTEMS LLC submits 

that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 

91.407(a)(l) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted relief 

specific to U AS in circumstances similar, in all material respects, to those presented herein ( e.g. 

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, I 1109, 111 IO, 1 I 112, I 1136, 

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. § 2 I. I 6 entitled Special Conditions, VISUAL SYSTEMS LLC requests that the FAA prescribe 

special conditions for the intended operation of the OJI Phantom 3 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 §§ 61.113(a) & (b), 91.7 (a), 91.121, 

91.15 l(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (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 U AS 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 OJI Phantom 3 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 2 I .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 OJI Phantom 3 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, 91.15l(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 

91.417(a) & (b). 

• A Summary That Can Be Published In The Federal Register, stating: The Rules From Which 

VISUAL SYSTEMS LLC Seeks Exemption: 

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

61.113(a)&{b), 91.7(a), 91.121, 91.15l(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), 

and 91.417(a) & (b). 

A Brief Description Of The Nature Of The Exemption VISUAL SYSTEMS LLC Seeks: 

This exemption will permit VISUAL SYSTEMS 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. 

• Any Additional Information, Views, Or Arguments Available To Support VISUAL SYSTEMS 

LLC's Request. 

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

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

operate safely in the NAS. As such, VISUAL SYSTEMS LLC's request for exemption may be 

granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above. 

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

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

the authority for such UAS to operate without airworthiness certification. 

As discussed in detail above, VISUAL SYSTEMS LLC will operate the OJI Phantom 3 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. 

CONCLUSION 

As set forth herein, VISUAL SYSTEMS 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 OJI Phantom 3 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 VISUAL SYSTEMS LLC to safely, efficiently, and economically operate the OJI 

Phantom 3 UAS commercially within the NAS. 
WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization 

and Reform Act of 2012, Section 333, VISUAL SYSTEMS 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)(I), 9l.409(a)(I) & 

(a)(2), and 9 l.417(a) & (b ), and permit Leading Edge to operate the on Phantom 3 U AS 

commercially for the purpose of conducting aerial video and photography over certain areas of the 

United States. 

Dated: 

Respectfully submitted, 

Charles Rohr 

13002 East 39111 Lane 

Spokane Valley, WA 99206 

Crohr530@gmail.com 

509 991-3667 

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