U.S. Dept. of Transportation, Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Avenue

Washington, DC 20590

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the

Federal Aviation Regulations. Document ID:

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the

“Reform Act”) and 14 C.F.R. Part 11, The Miami-Dade Police Department seeks an exemption 

from Federal Aviation Regulations (“FARs”) detailed below for the following described 

Unmanned Aerial System called in this application DJI Inspire 1, Phantom 2, and Phantom 3, 

which includes an Unmanned Ariel System (UAS) and ground station-based equipment and 

crew:

THE UNMANNED SYSTEM (UAS):

DJI Inspire 1, Phantom 2, and Phantom 3: See enclosed Manuals. The inherent safety 

features, sophistication, programmability, GPS navigation, return home capability, airport

vicinity no-fly feature and restricted altitude feature, as well as differentiating radio

frequency (rf) for aircraft controller/receiver and for the camera make this a much

safer UAS for the purposes of this petition. This is a radio controlled

UAS that has the capacity for software upgrades. It is light, less than 7 pounds

including battery and camera. Incorporated into the programming of these DJI UAS’s

is an automatic return home feature that automatically directs the craft back to point

of take off should communication with the transmitter be lost. The Inspire1 has a

maximum speed of 49 miles/hour. Maximum flight time is 18 minutes. Gross weight

is 6.5 pounds. The Phantom 2 has a maximum speed of 15 miles/hour. Maximum flight 

time of 25 minutes. Gross weight is 2.2 Pounds. The Phantom 3 has a maximum speed of 16 
miles/hour. Maximum flight time of 30 minutes. Gross weight is 2.8 Pounds.

The DJI UAV’s have an additional communication link between the camera and craft on

a different remote frequency for a smart phone connection. Allowing the operator or Pilot In

Command (PIC) to monitor battery level, altitude (AGL), distance from PIC, camera

imagery, and control camera angle.

The software for the DJI UAS’s allows the operator or PIC to set maximum altitude AGL

for each flight, allowing customization of flights to no higher than 150 feet can be

programmed into the UAS's software pre-flight to insure compliance with FAA

standards. Adding to the safety capabilities of this UAS. This UAS is programmed to

remain in position when controls are released. Maintaining altitude and GPS location.

All three DJI UAS’s has an altitude and radar monitoring function that allows the operator

more precise determination of height, direction of flight and distance from the

operator (PIC). The operator or PIC can monitor GPS lock status while UAS is in flight,

with the ability to anticipate loss of GPS locking so the operator or PIC can land the

UAV as a precaution. The DJI UAS’s are also equipped with a new safe dynamic return to

home function and automatic safe landing and taking off modes. The intelligent

battery also calculates how much power is needed to safely return home.

The requested exemption would support an application for a commercial Certificate

of Authorization to use the above described CAV System to support aerial

photography and videography.

The UAS, powered by batteries, is smaller, lighter and more maneuverable than larger

aircraft running on combustible fuel, it operates at lower altitudes with no people on

board and will thereby reduce current risk levels and thereby enhance safety and

diminish the likelihood of death or serious bodily injury. With a small payload and

maximum flight time of only 30 minutes, this is offers little or no risk to national

security.
Low level oblique photos and video from several angles are far more effective than

ground-based imagery for displaying the characteristics of large, structures and properties.

Additionally, we request that we be allowed to use our system to benefit municipal Law 

enforcement Departments who might require assistance, including fire fighters, and other 

Federal Agencies.

The three DJI UAS’s will be operated in the field with both a PIC and a Visual Observer in

accordance with FAA Policy N 8900.227 Section 14 "Operational Requirements for

UAS" and with the following Restrictions:

(a ) All operations must be within the restrict ions of The Florida State Statutes governing UAS

Operations;

(b) No flight will be made with a UAS Gross weight exceeding 55 pounds;

(c) All operations must occur in FAA Class G airspace at no more than 400 ft

AGL, at an airspeed of no more than 25 knots and no further than 3/4 NM

from the PIC;

(d) (All operations must utilize a visual observer (VO). The VO and PIC must be

able to communicate by voice at all times during a flight operation;

(e) The PIC must have accumulated and logged, in a manner consistent with 14

CFR § 61.51 (b), a minimum of 100 flight cycles and 25 hours of total time as

a UA rotorcraft pilot and at least ten hours logged as a UA pilot with a similar

UA type;

(f) The DJI UAS’s will not be operated within 5 NM of an airport or heliport;

(m) Operations will be conducted during VFR conditions with at least Class E weather 

minimums;

(n) The PIC will brief the VO and command staff about the operation and risk

before the first flight at each new location;
(o) No flight may be made without a Pre-Flight Inspection by the PIC before each

operation to ascertain that the UAS is in a condition safe for flight.

The PIC and VO will perform maintenance on the system and will complete a course of 

maintenance instruction as part of their initial training.

We submit that the combination of the UA's light weight, flight performance and

ability, fully qualified flight crew and strict operation under the guidelines established

in 8900.227, and under all of the Restrictions (a) through (o) listed above, the FAA

can have full confidence that the operation will have an equivalent or greater level of

safety than manned aircraft performing the same mission.

The name and contact information of the applicant are:

Miami-Dade Police Department

Sergeant Jose Gonzalez

1563 NW 79 Avenue

Miami, Fl 33018

Tel: 786 390-2730

Email: J.Gonzalez@MDPD.com

I am prepared to modify or amend any part of this request to satisfy the need for an

equivalent level of safety. Please contact us at any time if you require additional

information or clarification. Many thanks for your time.

Sincerely,

Jose Gonzalez