UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

Regulatory Docket No. 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

IMPACT PRODUCTIONS LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

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

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

OPERATION OF DJI PHANTOM 3 PROFESSIONAL UNMANNED AIRCRAFT 

SYSTEMS 

PURSUANT TO SECTION 333 OF 

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Submitted on November 5, 2015

Michael J. LoBrutto

1059 Fosters Mill Road

Boynton Beach Fl. 33436

(561) 789-4346
2

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level 

AOI Area of Interest 

ATC Air Traffic Control 

ATO Air Traffic Organization 

AV Aerial Vehicle 

CFR Code of Federal Regulations 

COA Certificate of Authorization 

FAA Federal Aviation Administration 

FAR Federal Aviation Regulation 

GCS Ground Control Station 

GPS Global Positioning System 

LOL Loss of Link 

NAS National Airspace System 

NOTAM Notice to Airman 

PIC Pilot In Command 

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

SO Safety Observer 

SOP Standard Operating Procedures 

UA Unmanned Aircraft 

UAS Unmanned Aircraft System 

VFR Visual Flight Rules 

VLOS Visual Line of Site 

VMC Visual Meteorological Conditions 

VTOL Vertical Takeoff and Landing 
3

SUMMARY 

Impact Productions LLC seeks exemption from the requirements of 14 C.F.R §§ 

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

and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of 

the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit 

Impact Productions LLC to operate an Unmanned Aircraft System (UAS) for the 

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

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

INTRODUCTION AND INTERESTS OF THE PETITIONER

Impact Productions LLC continually provides its clients with expertise in the field of 

photography and videography. Impact Productions LLC has worked with many clients on 

real estate listings, special events and weddings. Impact Productions LLC is experienced in 

all aspects of videography and photography. The objective of Impact Productions LLC 

aerial video and photography department is to provide high quality imaging for a variety of 

commercial and residential customers. Owner Michael LoBrutto has extensive knowledge 

with Model Aircrafts and is currently a member of the AMA as well as the Palm Beach 

Radio Control Association. 

HOW THE OPERATOR WILL MAINTAIN AN EQUIVALENT LEVEL OF 

SAFETY OR NO ADVERSE IMPACT TO SAFETY

These limitations and conditions to which Impact Productions LLC agrees to 

be bound when conducting commercial operations under an FAA issued exemption 

including: 
4

1. The UAS will weigh less than 55 lbs. 

2. Flights will be operated within line of sight of operator. 

3. A spotter will be utilized in assisting in the visual positioning of the UAS

while in flight.

4. The UAS will not fly near or over sensitive infrastructure or property such as 

power stations, water treatment facilities, correctional facilities, heavily 

traveled roadways, government facilities, etc.

5. The UAS will not fly in adverse weather conditions such as in high winds or 

reduced visibility.

6. Maximum total flight time for each operational flight will be approximately 20 

minutes. 

7. Flights will be terminated at 15% battery power reserve. 

8. Flights will be operated at an altitude of no more than 400 feet AGL 

9. UAS operator will be trained and certified in the proper safety and operations 

of the UAS. 

10. The UAS will only operate within a controlled area as defined in the 

Procedures. 

11. The operator will have been trained in operation of UAS generally and 

received up-to-date information on the particular UAS to be operated as 

required. 

12. If the UAS loses communications or loses its GPS signal, the UAS will have 

capability to return to a pre-determined location within the Security Perimeter 

and land. 

13. The UAS will have the capability to abort a flight in case of unpredicted 

obstacles or emergencies. 

UNMANNED AIRCRAFT SYSTEMS: DJI PHANTOM 3 PROFESSIONAL UAS 

Impact Productions LLC seeks an exemption to operate the DJI Phantom 3 

Professional within the NAS. The DJI Phantom 3 Professional Quadcopter features are 

vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control 

Station (GCS) systems. The DJI Phantom 3 Professional has a maximum gross weight 

(including battery and propellers) of approximately 2 pounds 8 ounces, while the Diagonal 

Size (including propellers) is approximately 23.22 inches, height of 7.25 inches, and a 

maximum speed of approximately 16 m/s (ATTI mode, no wind). The UAs is equipped with 

four main rotors; driven by Lithium Polymer battery powered electric motors. 
5

The DJI Phantom 3 Professional UAs that will be operated by Impact Productions 

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

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

45, Identification and Registration Marking.

BASIS FOR PETITION 

Petitioner, Impact Productions LLC, pursuant to the provisions of the Federal 

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

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

petitions the Administrator to commercially operate the DJI Phantom 3 Professional UASs 

in the National Airspace System (NAS), and for an exemption from the requirements of 14 

C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

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

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

with the unmanned aircraft and its operation, Impact Productions LLC operation of the DJI 

Phantom 3 Professional UASs 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. 

Impact Productions LLC requests relief from Sections 91.405(a), 91.407(a) (1), 

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

maintenance that only apply to aircraft with an airworthiness certificate. Impact Productions 

LLC submits that the requested relief is proper since an equivalent level of safety will be 

ensured. Impact Productions LLC will only use experienced personnel or technicians to 
6

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

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

Manual). Furthermore, Impact Productions LLC will document and maintain all 

maintenance records for the DJI Phantom 3 Professional UASs. 

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

privileges and limitations: Pilot in command, is requested by Impact Productions LLC to 

the extent necessary to allow a Pilot in Command (PIC) and who has demonstrated, by 

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

operate the DJI Phantom 3 Professional UASs in a manner consistent with this exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from 

people, vessels, vehicles and structures. 

Impact Productions LLC seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the DJI Phantom 3 Professional UASs do not require an 

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

Productions LLC submits that it will ensure that the DJI Phantom 3 Professional UASs are 

in an airworthy condition, prior to every flight, by determining that the UASs are in 

compliance with the operating documents (i.e., Instruction Manual), and that the aircraft are 

in a condition for safe flight. 

Impact Productions LLC also seeks an exemption from the requirements of Section 

91.121, entitled Altimeter Settings, as the DJI Phantom 3 Professional UAs will not have a 

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

Professional UAs will be provided to the PIC via Global Positioning System (GPS) 
7

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 

Impact Productions LLC operation of the DJI Phantom 3 Professional UASs within visual 

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

91.121. 

Additionally, Impact Productions LLC seeks an exemption from the requirements of 

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

Productions LLC submits that safety will not be affected by operation of the DJI Phantom 3 

Professional UAs during daylight hours in visual meteorological conditions (VMC) under 

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

approximately 13.5 minutes to the first point of intended landing and, assuming normal 

cruising speed, to fly after that for at least 4.5 minutes. In accordance with 14 C.F.R. § 

11.81, Impact Productions 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: 

Michael J. LoBrutto

Impact Productions LLC 

1059 Fosters Mill Road

Boynton Beach, Florida 33436

Tel: (561) 789-4346

Email: mjlobrutto@bellsouth.net

B. The Specific Sections Of 14 C.F.R. From Which Impact Productions LLC Seeks 

Exemption. 
8

1. Impact Productions 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. Impact Productions 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. Impact Productions LLC Seeks Exemption From The Requirements Of 

Section 91.121.

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

part: 
9

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

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

when operating--

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

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

within 100 nautical miles of the aircraft; 

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

this section, the current reported altimeter setting of an appropriate 

available station; or 

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

departure airport or an appropriate altimeter setting available before 

departure. 

4. Impact Productions LLC Seeks Exemption From The Requirements Of 

Section 91.151(b).

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

(b), states the following: 

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

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

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

fly after that for at least 20 minutes.

5. Impact Productions LLC Seeks Exemption From The Requirement Of 

Section 91.405(a).
10

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. Impact Productions LLC 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[.] 

7. Impact Productions LLC Seeks Exemption From The Requirements Of 

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

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

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

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

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

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

this chapter; or 
11

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

accordance with part 21 of this chapter. 

8. Impact Productions 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: 

(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: 
12

(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: 
13

(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 Impact Productions LLC Seeks And The Reason Impact 

Productions LLC Seeks The Relief.

1. Extent Of Relief Impact Productions LLC Seeks And The Reason Impact 

Productions 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 Impact Productions LLC to determine that the UASs are in 

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

operating documents (i.e. Monthly Maintenance Log, Instruction Manual). 

Impact Productions LLC seeks the requested relief because the DJI Phantom 3 Professional

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

Subpart H. Therefore, Impact Productions LLC will ensure that the DJI Phantom 3 

Professional UASs are in airworthy condition based upon its compliance with the operating 

documents (i.e., Monthly Maintenance Log, Instruction Manual) prior to every flight, and 
14

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

and limitations below.

2. Extent Of Relief Impact Productions LLC Seeks And The Reason Impact 

Productions 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 Professional 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),

Impact Production LLC seeks the requested relief because the DJI Phantom 3 

Professional UAS’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 limitations stated below. As more 

fully set forth herein, an equivalent level of safety will be maintained since the DJI Phantom 

3 Professional UAS is 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 UAS on the heads-up

display of the GCS.

3. Extent Of Relief Impact Productions LLC Seeks And The Reason Impact 

Productions LLC Seeks Relief From Section 91.151(b).
15

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

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

Phantom 3 Professional UAS during daylight hours in visual meteorological conditions 

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

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

minutes. Impact Productions LLC seeks the requested relief because without an exemption 

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

Professional UAS will severely constrain the practicality of any aerial video or still photo 

flight operations that Impact Productions LLC proposes to conduct pursuant to this Petition. 

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

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

Productions LLC proposed operating limitations, ensure that Impact Productions LLC will 

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

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

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

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

4. Extent Of Relief Impact Productions LLC Seeks And The Reason Impact 

Productions LLC Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) 

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

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

only apply to aircraft with an airworthiness certificate, Impact Productions LLC requests 

relief from these Sections because the UASs do not require airworthiness certificates. As set 

forth more fully below, the UASs meet the conditions of FMRA Section 333 for operation 

without an airworthiness certificate. Accordingly, Impact Productions LLC will use trained 

technicians to perform repairs, alterations, or preventive maintenance on the UASs using the 
16

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

Instruction Manual). Impact Productions LLC will document and maintain all maintenance 

records for the DJI Phantom 3 Professional UASs. 

D. The Reasons Why Granting Impact Production 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 Impact Productions 

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

construction sites, real estate, and landscape over certain areas of the United States. 

Additionally, use of the DJI Phantom 3 Professional the NAS, reduce pollution, and provide 

significant benefits to the economy. Notably, the benefits of Impact Productions proposed 

operation of the DJI Phantom 3 Professional UASs will be realized without implicating any 

privacy issues. 

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

The DJI Phantom 3 Professional UAs are battery powered and serve as a safe, efficient, and 

economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. 

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

exemption allowing the use of a 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 UAs do not 

require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting 
17

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 Professional UASs.

Conducting aerial acquisitions with the DJI Phantom 3 Professional 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 Professional 

UASs produce no air pollution, and is the most viable environmentally conscious alternative 

to the cabin class, six cylinder internal combustion engine aircraft that are typically utilized 

for aerial video and photography, while burning approximately 20-30 gallons per hour of 

leaded aviation fuel. The DJI Phantom 3 Professional, 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 UASs to perform aerial acquisitions, the substantial risk to life and 

property in the air and on the ground, which is usually associated with traditional manned 

aircraft flight operations, will be substantially reduced or completely eliminated. Aside from 

the lack of flight crew members located onboard the aircraft, the DJI Phantom 3 

Professional at only 2.8 pounds 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). 
18

3. Performing Aerial Video and Photography Operations With The DJI 

Phantom 3 Professional UASs Will Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 3 Professional UASs are also an 

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

such, operation will allow United States based companies, like Impact Productions 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.

4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted 

for decades, Impact Productions LLC proposed operation of the DJI Phantom 3 Professional 

UASs will not implicate any privacy issues. Specifically, UASs will be operated only in 

compliance with operating documents (i.e., 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. 

CONCLUSION

As set forth herein, Impact Productions LLC seeks an exemption pursuant to 14 § 11.61 and 

Section 333 of the FAA Modernization and Reform Act of 2012C.F.R. (FMRA), which 

will permit safe operation of the DJI Phantom 3 Professional UASs 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 
19

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 Impact Productions LLC to safely, efficiently, and economically operate the DJI 

Phantom 3 Professional UASs commercially within the NAS. 

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

Modernization and Reform Act of 2012, Section 333, Impact Productions LLC respectfully 

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

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

91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Impact Productions LLC to operate 

the DJI Phantom 3 Professional UASs commercially for the purpose of conducting aerial 

video and photography over certain areas of the United States. 

Dated: November 5, 2015 

Respectfully submitted, 

Impact Productions LLC 

Michael J. LoBrutto

1059 Foster’s Mill Road

Boynton Beach Florida 33436

(561)789-4346

Appendices: 

A. DJI Phantom 3 Professional Specifications Data 

B. DJI Phantom 3 Professional User Manual

C. Monthly Maintenance Log
APPENDIX – A 

DJI PHANTOM 3 TECHNICAL SPECIFICATIONS

Impact Production LLC only utilizes safe and reliable UASs. DJI is an industry 

leader in small UAS production. DJI UASs are loaded with groundbreaking 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) 

FAILSAFES

The Phantom 3 Professional’s flight controller features several important 

upgrades, including a new flight mode. Safety modes include Failsafe and Return-toHome. These features ensure the safe return of the aircraft if the control signal is lost. 

The flight controller can also save critical flight data from each flight to the on-board 

storage device. The new flight controller also provides increased stability and a new air 

braking feature.

The Return-to-Home (RTH) function brings the aircraft back to the last 

recorded Home Point. There are three types of RTH procedures: Smart RTH, Low 

Battery RTH, and Failsafe RTH. This section describes these three scenarios in detail.

Low Battery RTH - The low battery level failsafe is triggered when the DJI 

Intelligent Flight Battery is depleted to a point that may affect the safe return of the 
21

aircraft. Users are advised to return home or land the aircraft immediately when 

prompted. The DJI Pilot app will display a notice when a low battery warning is 

triggered. The aircraft will automatically return to the Home Point if no action is taken 

after a ten-second countdown. The user can cancel the RTH procedure by pressing the 

RTH button on the remote controller. The thresholds for these warnings are 

automatically determined based on the aircraft’s current altitude and distance from the 

Home Point.

The aircraft will land automatically if the current battery level can only support 

the aircraft long enough to descend from its current altitude. The user can still use the 

remote controller to alter the aircraft’s orientation during the landing process.

Failsafe RTH - will be automatically activated if the remote controller signal is 

lost for more than three seconds. The Return to- Home process may be interrupted and 

the operator may regain control of the aircraft if the remote controller signal connection 

is re-established.

AIRCRAFT

Weight (Including Battery And 

Propellers)

1280 g

Diagonal Size (Including 

Propellers)

590 mm

Max Ascent Speed 5 m/s

Max Descent Speed 3 m/s

Hover Accuracy Vertical: +/- 0.1 m (when Vision Positioning is active) 

or +/- 0.5 m

Horizontal: +/- 1.5 m

Max Speed 16 m/s (ATTI mode, no wind)

Max Service Ceiling Above Sea 

Level

6000 m (Software altitude limit: 120 m above takeoff 

point)

Operating Temperature 0°C to 40°C

GPS Mode GPS/GLONASS
22

CAMERA

Sensor Sony EXMOR 1/2.3” Effective pixels: 12.4 M (total 

pixels: 12.76 M)

Lens FOV 94° 20 mm (35 mm format equivalent) f/2.8, 

focus at ∞

ISO Range 100-3200 (video) 100-1600 (photo)

Shutter Speed 8s -1/8000s

Image Max Size 4000 x 3000

Still Photography Modes Single Shot

Burst Shooting: 3/5/7 shots

Auto Exposure Bracketing (AEB): 3/5

Bracketed Frames at 0.7EV Bias

Time-lapse

Video Recording Modes UHD: 4096x2160p 24/25, 3840x2160p 24/25/30

FHD: 1920x1080p 24/25/30/48/50/60

HD: 1280x720p 24/25/30/48/50/60

Supported SD Card Types Micro SD 

Max capacity: 64 GB. Class 10 or UHS-1 rating 

required

Max Bitrate Of Video Storage 60 Mbps

Supported File Formats FAT32/exFAT

Photo: JPEG, DNG

Video: MP4, MOV (MPEG-4 AVC/H.264)

Operating Temperature 0°C to 40°C

GIMBAL

Controllable Range Pitch -90° to +30°

Stabilization 3-axis (pitch, roll, yaw)

VISION POSITIONING

Max Velocity Less than 8 m/s (when 2 m above ground)

Altitude Range 50 cm-300 cm

Operating Range 50 cm-300 cm

Operating Environment Surface with clear pattern and adequate lighting (Lux 

> 15)

REMOTE CONTROLLER

Operating Frequency 2.400 GHz-2.483 GHz

Max Distance Up to 5 km or 3.1 miles (unobstructed, free of 

interference) when FCC compliant

Up to 3.5 km or 2.1 miles (unobstructed, free of 

interference) when CE compliant

Video Output Port USB

Operating Temperature 0°C- 40°C

Battery 6000 mAh LiPo 2S
23

Mobile Device Holder For tablet or phone

Receiver Sensitivity (1%PER) -101 dBm ±2 dBm

Transmitter Power (EIRP) FCC: 20 dBm

CE: 16 dBm

Working Voltage 1.2 A @7.4 V

BATTERY CHARGER

Voltage 17.4 V

Rated Power 100 W

INTELLIGENT FLIGHT 

BATTERY

Capacity 4480 mAh

Voltage 15.2 V

Battery Type LiPo 4S

Energy 68 Wh

Net Weight 365 g

Max Flight Time Approximately 23 minutes

Operating Temperature -10°C to 40°C

Max Charging Power 100 W

App / Live View

Mobile App DJI GO

EIRP 100mW

Power Spectral Density 6.9mW/MHz

Live View Working Frequency 2.4GHz ISM

Live View Quality 720P @ 30fps (depending on conditions and mobile 

device)

Latency 220ms (depending on conditions and mobile device)

Required Operating Systems iOS 8.0 or later 

Android 4.1.2 or later

Recommended Devices iOS: iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, 

iPad Air Wi-Fi + Cellular, iPad mini 2, iPad mini 2 

Wi-Fi + Cellular, iPad Air 2, iPad Air 2 Wi-Fi + 

Cellular, iPad mini 3, and iPad mini 3 Wi-Fi + 

Cellular. This app is optimized for iPhone 5s, iPhone 

6, and iPhone 6 Plus

Android: Samsung tabs 705c, Samsung S6, Samsung 

S5, Samsung NOTE4, Samsung NOTE3, Google 

Nexus 9, Google Nexus 7 II, Ascend Mate7, Nubia Z7 

mini, SONY Z3 EXPERIA, MI 3, MI PAD

*Support for additional Android devices available as 

testing and development continues.
24

APPENDIX – B

DJI Phantom 3 Professional User Manual -

https://dl.djicdn.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual

__V1.6.pdf

APPENDIX –C

Monthly Maintenance Log 

UAS #_____ Date Issue Maintenance

Performed 

Initials 

Firmware 

Check 

Frame 

Engines 

Propellers 

Camera 

Gimbal 

Landing 

Gear 

Vibration 

Other: