UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, D.C.

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

JONATHAN ANDREW PITTS

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

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

AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF

DJI PHANTOM 3 UNMANNED AIRCRAFT SYSTEM

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Submitted on September 4, 2015

Jonathan Andrew Pitts (owner/operator/pilot)

340 S Lemon Ave #4731

Walnut, CA 91789 USA

Home Tel: (469) 919-5229

Cell: (352) 221-4320
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TABLE OF CONTENTS

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

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

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

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

BASIS FOR PETITION..............................................................................................4

A. Name and Address Of The Petitioner: ..............................................................6

B. The Specific Sections of 14 C.F.R. from which Jonathan Andrew Pitts Seeks 

Exemption..............................................................................................................6

C. The Extent Of Relief Jonathan Andrew Pitts Seeks And The Reason Jonathan 

Andrew Pitts Seeks The Relief. .............................................................................9

D. The Reasons Why Granting Jonathan Andrew Pitts’ Request Would Be In The 

Public Interest; That Is, How It Would Benefit The Public As A Whole. ..............10

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 I Seek Exemption...........................13

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

Rules From Which I Seek Exemption:.................................................................22

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

Jonathan Andrew Pitts’ Request. ........................................................................22

CONCLUSION ........................................................................................................23

APPENDICES ................................................................................................................24

APPENDIX A...........................................................................................................25

APPENDIX B...........................................................................................................27

APPENDIX C........................................................................................................... 28
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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

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
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SUMMARY

Jonathan Andrew Pitts seeks exemption from the requirements of 14 C.F.R §§ 

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 me to operate 

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

video and photography for real estate photography and special events over certain areas 

of the United States of America.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Jonathan Andrew Pitts is a licensed real estate agent in multiples states and 

provides his clients with expertise in real estate transactions and high quality photographs 

to aide in those transactions. Petitioners objective in aerial video and photography is to 

provide high quality imaging to aide in commercial, residential, or government real estate 

transactions.

Petitioner possesses a second class medical certificate and is a commercial pilot 

with airplane single and multiengine land, instrument airplane ratings with approximately 

1,700 hours of flight time and over 15 years of experience in aviation. Petitioner also 

holds a Bachelor of Science Degree from Embry-Riddle Aeronautical University in 

Aeronautics with minors in Flight, Air Traffic Control, and Business.

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 3

Jonathan Andrew Pitts seeks an exemption to operate DJI systems for 

compensation or hire within the NAS. The DJI Phantom 3 are vertical takeoff and landing 

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

tablet or smart phone systems. The DJI Phantom 3 has a maximum gross weight of 

approximately 1280 gram, while having a length of 16 inches width of 16 inches, height 

of 8 inches, and a maximum speed of approximately 29 knots. The DJI Phantom 3 UA is

equipped with four main rotors; driven by Lithium Polymer battery powered electric 

motors.

The DJI Phantom 3 UA that will be operated by Jonathan Andrew Pitts 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, Jonathan Andrew Pitts, pursuant to the provisions of the Federal 

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

2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, 

hereby petitions the Administrator to commercially operate the DJI Phantom 3 UAS in the 

National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R 
5

§§ 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, Jonathan Andrew Pitts, will meet 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, Jonathan Andrew Pitts, 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. 

Jonathan Andrew Pitts submits that the requested relief is proper since an 

equivalent level of safety will be ensured. Petitioner will use his experience to perform 

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

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

Maintenance Log, and DJI Phantom 3 Instruction Manual). Furthermore, Petitioner will 

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

Jonathan Andrew Pitts seeks relief from Section 91.7(a), entitled Civil Aircraft 

Airworthiness, because the DJI Phantom 3 UAS does not require an airworthiness 

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

Pitts will ensure that the UAS is in an airworthy condition, prior to every flight, by 

determining that the UAS is in compliance with the operating documents (i.e., Monthly 

Maintenance Log, and DJI Phantom 3 Instruction Manual), and that the aircraft is in a 

condition for safe flight. 

Jonathan Andrew Pitts also seeks an exemption from the requirements of Section 

91.121, entitled Altimeter Settings, as the DJI Phantom 3 UA will not have a typical 

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

DJI 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, Jonathan Andrew Pitts, seeks an exemption from the requirements of 

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

Andrew Pitts submits that safety will not be affected by operation of the DJI Phantom 3

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 15 

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

after that for at least 5 minutes. 

In accordance with 14 C.F.R. § 11.81, Jonathan Andrew Pitts provides the 

following information in support of its petition for exemption:
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A. Name and Address Of The Petitioner:

Jonathan Andrew Pitts (owner/operator)

340 S Lemon Ave #4731

Walnut, CA 91789 USA

Tel: (469) 919-5229 Fax: (866) 237-6383

Email: jon@ticonoc.us

B. The Specific Sections of 14 C.F.R. from which Jonathan Andrew Pitts Seeks 

Exemption. 

1. Jonathan Andrew Pitts 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. 

2. Jonathan Andrew Pitts Seeks Exemption From The Requirements Of 

Section 91.121. 

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

part:

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

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

set, when operating--

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

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

within 100 nautical miles of the aircraft; 

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

this section, the current reported altimeter setting of an appropriate 

available station; or 

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

departure airport or an appropriate altimeter setting available before 

departure. 

3. Jonathan Andrew Pitts Seeks Exemption From The Requirements Of 

Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection
7

(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. 

4. Jonathan Andrew Pitts Seeks Exemption From The Requirement Of 

Section 91.405(a).

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

Each owner or operator of an aircraft—

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

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

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

5. Jonathan Andrew Pitts Seeks Exemption From The Requirements Of 

Section 91.407(a)(1) 

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

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

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

preventive maintenance, rebuilding, or alteration unless--

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

43.7 of this chapter. 

6. Jonathan Andrew Pitts 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. 

7. Jonathan Andrew Pitts Seeks Exemption From The Requirements Of 

Sections 91.417(a) And 91.417(b). 
8

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. 

(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: 
9

(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 Jonathan Andrew Pitts Seeks And The Reason Jonathan 

Andrew Pitts Seeks The Relief. 

1. Extent Of Relief Jonathan Andrew Pitts Seeks And The Reason Jonathan 

Andrew Pitts 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 Jonathan Andrew Pitts to determine that the DJI Phantom 3 UAS

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

with the operating documents (i.e., Operations Manual, Monthly Maintenance Log, and 

DJI Phantom 3 Instruction Manual). 

Jonathan Andrew Pitts seeks the requested relief because the DJI Phantom 3 UAS

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

Subpart H. Therefore, Jonathan Andrew Pitts will ensure that the and DJI Phantom 3 UAS

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

Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual) prior to every flight, 

and further, determine that the aircraft are in condition for safe flight, as stated in the 

conditions and limitations below.

2. Extent Of Relief Jonathan Andrew Pitts, Seeks And The Reason Jonathan 

Andrew Pitts 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), Jonathan Andrew Pitts 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 CFR 

91.121 is sought to the extent necessary to comply with the applicable conditions and 
10

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. 

3. Extent Of Relief Jonathan Andrew Pitts Seeks And The Reason Jonathan 

Andrew Pitts Seeks Relief From Section 91.151(b). 

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

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

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

visual flight rules (VFR), for a total duration of 15 minutes to the first point of intended 

landing and, assuming normal cruising speed, to fly after that for at least 5 minutes. 

Jonathan Andrew Pitts seeks the requested relief because without an exemption from 

Section 91.151(b), the flight time duration of the battery powered DJI Phantom 3 UA will 

severely constrain the practicality of any aerial video or still photo flight operations that

Jonathan Andrew Pitts proposes to conduct pursuant to this Petition. 

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

UAS, and DJI Phantom 3 operating documents, and petitioner’s proposed operating 

limitations, ensure that Jonathan Andrew Pitts will safely operate the battery powered DJI 

Phantom 3 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 15 minutes 

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

for at least 5 minutes.

4. Extent Of Relief Jonathan Andrew Pitts Seeks And The Reason Jonathan 

Andrew Pitts 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, Jonathan Andrew Pitts requests

relief from these Sections because the DJI Phantom 3 UAS does not require 

airworthiness certificates. As set forth more fully below, the DJI Phantom 3 UAS meets

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

Accordingly, petitioner will perform maintenance, alterations, or preventive maintenance 

on the UAS using the methods, techniques, and practices prescribed in the UAS 

operating documents (i.e., the Operations Manual, Monthly Maintenance Log, and DJI 

Phantom 3 Instruction Manual). Furthermore, petitioner will document and maintain all 

maintenance records for the DJI Phantom 3 UAS. 

D. The Reasons Why Granting Jonathan Andrew Pitts’ Request Would Be In The 

Public Interest; That Is, How It Would Benefit The Public As A Whole. 
11

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

Andrew Pitts to safely, efficiently, and economically perform aerial video and photography 

for real estate photography, and special events over certain areas of the United States. 

Specifically:

• Petitioner possesses a real estate license in multiple states and being able 

to provide aerial photography services to his clients is an economic benefit 

to the local community.

• Petitioner is an active member of the aviation community and will be able to 

provide a positive impact on the advancement of UAS activity in the local 

community through increased awareness and education.

 

Additionally, use of the DJI Phantom 3 UAS will decrease congestion of the NAS, 

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

Jonathan Andrew Pitts’ proposed operation of the DJI 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 UA is battery powered and serves 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 3 UAS would reduce the amount of manned 

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

and property in the air and on the ground. 

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

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

DJI Phantom 3 UA does 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 DJI Phantom 3 UASs, instead of manned 

aircraft, will greatly benefit the public by drastically reducing the levels of air and noise 

pollution generated during traditional aerial video and still photography flight operations. 

By using battery power and electric motors, the DJI Phantom 3 UAS produces 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 3 UA, while reducing the carbon footprint of aerial acquisitions, 

also eliminates noise pollution, as the UA is propelled by battery powered electric motors, 

rather than an internal combustion engine. 
12

By using the DJI 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 UA (weighing only 1280 grams, at maximum gross weights with lengths of 16 inches, 

widths of 16 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 is 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 entities, like 

Jonathan Andrew Pitts to remain competitive and contribute to growth of the U.S. 

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

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

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

remain competitive. Operating the battery powered DJI Phantom 3 UAS is one such 

technology that not only allows companies greater operational flexibility compared to 

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

traditional manned aircraft. 

By operating the DJI Phantom 3 UAS, entities such as Jonathan Andrew Pitts can 

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

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

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

of the DJI Phantom 3 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, Jonathan Andrew Pitts’ proposed operation of the DJI Phantom 3 UAS will 

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

only in compliance with operating documents (i.e., the Operations Manual, Monthly 

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

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

Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. 

§ 91.119. 
13

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 I Seek Exemption. 

1. Reasons Why The DJI Phantom 3 UA Meets The Conditions Of The FAA 

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

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

with the unmanned aircraft and its operation, my operation of the DJI Phantom 3 UAS

meets 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, Jonathan Andrew Pitts submits that the DJI Phantom 3

UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: 
14

(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 DJI Phantom 3 UASs 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 UAS. 

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

Phantom 3 Specifications and Data Sheet. Technical specifications can be found in 

Appendix A.

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

Enable The UASs To Remain Within A Defined Operational Area. 

The DJI Phantom 3 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 3 UAS is available on-line DJI Phantom 3 User Manual.

iii. The DJI Phantom 3 UAs Is 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 UA will remain stationary, in flight, 

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

A complete description of the Failsafe Functions of the DJI Phantom 3 UAS is 

available on-line at DJI Phantom 3 User Manual.

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

Operating Limitations. 

In seeking this exemption, Jonathan Andrew Pitts proposes to commercially 

operate the DJI Phantom 3 UA for the 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 
15

than 55 pounds maximum gross weight: DJI 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 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 
16

FAA granted the exemption, then the operator must petition for amendment to 

its grant of exemption. The FAA’s UAS Integration Office (AFS-80) may be 

contacted if questions arise regarding updates or revisions to the operating 

documents. 

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

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

operation of the UAS, the aircraft is prohibited from operating until the 

necessary maintenance has been performed and the UAS is found to be in a 

condition for safe flight. The Ground Control Station must be included in the 

preflight inspection. All maintenance and alterations must be properly 

documented in the aircraft records.

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

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

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

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

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

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

relevant sections of the operating documents. 

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

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

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

requirements, in accordance with the operating documents. Maintenance, 

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

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

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

UAS to service. 

15. Each UAS 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 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 
17

conducted during dedicated training sessions. During training, proficiency, and 

experience-building flights, all persons not essential for flight operations are 

considered nonparticipants, and the PIC must operate the UA with appropriate 

distance from nonparticipants in accordance with 14 C.F.R. § 91.119.

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

1.1. All operations must be conducted under visual meteorological conditions 

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

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

rules (SVFR) are not authorized. 

19. 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. 

20. The UA may not be operated less than 400 feet below or less than 2,000 feet 

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

PIC. 

21. 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. 

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

emergencies in accordance with the operating documents. 

23. 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. 

24. 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. 

25. 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. 
18

26. 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.

27. 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.

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

operations and activities at all times.

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

30. 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). 

31. 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.

32. 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. 
19

2. 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, Jonathan Andrew Pitts 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). 

3. 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 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 my operation of the DJI Phantom 3 UA within visual line of

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

The altitude information will be generated by GPS equipment installed 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). 

4. 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 3 UAS; (2) the limitations on the proposed flight operations; and (3) the location 

of the proposed flight operations. Accordingly, petitioner will ensure that it will safely 

operate the battery powered DJI Phantom 3 UA during daylight hours in VFR conditions, 

with enough battery power to fly for a total duration of 15 minutes to the first point of 

intended landing and, assuming normal cruising speed, to fly after that for at least 5 

minutes. 

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

3 UAS; the limitations on the proposed flight operations; and the location of the proposed 
20

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 provides

audible and visual warnings to the PIC at the GCS when the UA experiences low battery 

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

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

the DJI Phantom 3 UAS will descend and land automatically. 

Significantly, previous exemptions granted by the FAA concerning Section 91.151 

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

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

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

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

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

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

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

11157, 11158, 11159, 11160, 11161).

5. 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, petitioner 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 

petitioner 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 Operations Manual, Monthly Maintenance Log, and DJI 

Phantom 3 Instruction Manual). Furthermore, I will document and maintain all 

maintenance records for the DJI Phantom 3 UAS. 

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

Andrew Pitts will use my experience to perform maintenance, alterations or preventive 

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

operating documents. 

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

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

DJI Phantom 3 UAS will be performed by me. 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. 
21

In consideration of my proposed operating limitations, the operating documents, 

and the technical aspects of the DJI Phantom 3 UAS, I submit 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). 

6. 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, Jonathan Andrew Pitts

requests that the FAA prescribe special conditions for the intended operation of the DJI 

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 §§ 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 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 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 petitioner’s intended operation of the DJI 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, 
22

and 14 C.F.R Sections 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 I Seek Exemption:

Jonathan Andrew Pitts seeks exemption from the requirements of 14 C.F.R 

Sections 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 I Seek: 

This exemption will permit Jonathan Andrew Pitts 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 

Jonathan Andrew Pitts’ 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, petitioner’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, petitioner will operate the DJI 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. 
23

CONCLUSION

As set forth herein, petitioner seeks an exemption pursuant to 14 C.F.R. § 11.61 

and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will 

permit safe operation of the DJI Phantom 3 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 Jonathan Andrew Pitts to safely, 

efficiently, and economically operate the DJI 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, Jonathan Andrew Pitts respectfully 

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

of 14 C.F.R Sections 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 petitioner to operate the DJI Phantom 3 UAS

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

areas of the United States.

Respectfully submitted,

_________________________

Dated: September 3, 2015 Jonathan Andrew Pitts (owner/operator)

340 S Lemon Ave #4731

Walnut, CA 91789 USA

Home Tel: (469) 919-5229

Cell: (352) 221-4320
24

APPENDICES

Appendix A – DJI Phantom 3 Technical Specifications

Appendix B – DJI Phantom 3 Preflight, Flight, and Emergency Check Lists

Appendix C – Monthly Maintenance Log
25

APPENDIX A

DJI PHANTOM 3 TECHNICAL SPECIFICATIONS

Petitioner utilizes a safe and reliable UAS. DJI is an industry leader in small UAS 

production. DJI UASs are programmed 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).
26

DJI PHANTOM 3 TECHNICAL SPECIFICATIONS (CONT’D)
27

APPENDIX B

DJI Phantom 3 Pre-Flight Inspection Check List

PREFLIGHT CHECK LIST

1. Visually inspect aircraft for defects

2. Batteries fully charged and checked – Remote Controller, Intelligent Flight Battery, and 

mobile devices 

3. Propellers mounted correctly and firmly

4. SD card inserted in camera

5. Lens cap removed

6. Antenna extended

7. Transmitter turned on (press once, release, then press and hold for 3 seconds)

8. Ensure Transmitter is in P Mode

9. UAS turned on (press once, release, then press and hold for 3 seconds)

10. Activate the transformation switch on transmitter up and down 4 times quickly to 

convert from travel mode to flight mode or use the appropriate application

11. DJI Pilot application activated

12. Tap bar at top of control application (Safe to Fly GPS) for full status

13. Maps are cached (move the map around, zoom in an out)

14. Minimum return height adjusted (check for tallest object and set accordingly)

15. UAS placed in safe launch and recover position

16. Home point programmed via app

17. Area clear of people / obstructions

18. Obtain weather briefing to ensure conditions are optimal for safe operation

TAKE OFF AND CRUISE CHECK LIST

1. Hover close for 20 seconds. Observe for proper operation.

2. Confirm expected stick operation

3. Monitor battery power

4. Monitor signal strength

5. Maintain line-of-sight with UAS 

6. Ensure area of intended flight path is clear of other aerial traffic.

7. Ensure area of intended flight path is clear of any electrical/power lines

EMERGENCY LANDING

Select a safe zone to for emergency landing of the UAV/UAS in the event an 

emergency landing is required.
28

APPENDIX C

MONTHLY MAINTENANCE LOG

MONTH/YEAR:

A/C N#: Date Description of 

Maintenance

Signature 

and Name 

of 

Mechanic

Firmware Updates

Airframe

Engines

Propellers

Camera/Gimbal

Landing Gear

Vibration/Dampening

Other -

Other -

Other -

Other -