September 17, 2015

Exemption No. 12898

Regulatory Docket No. FAA−2015−2661

Mr. Christopher Ison

The Ison Law Group

Counsel for Image in Flight

2073 US Highway 92 West, Suite 104

Winter Haven, FL 33881

Dear Mr. Ison:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated June 3, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Image in Flight (hereinafter petitioner or operator) for an exemption. The petitioner

requested to operate an unmanned aircraft system (UAS) to conduct aerial photography, 

videography, and mapping.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.
2

Airworthiness Certification

The UAS proposed by the petitioner are the DJI Phantom 2 Vision+ and DJI Inspire 1.

In accordance with the statutory criteria provided in Section 333 of Public Law 112−95 in 

reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, and limited 

operating area associated with the aircraft and its operation, the Secretary of Transportation 

has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA 

finds that relief from 14 CFR part 21, Certification procedures for products and parts, 

Subpart H—Airworthiness Certificates, and any associated noise certification and testing 

requirements of part 36, is not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Image in Flight is granted an exemption from 14 CFR 

§§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
3

91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the 

extent necessary to allow the petitioner to operate a UAS to perform aerial data collection.

This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Image in Flight is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2 

Vision+ and DJI Inspire 1 when weighing less than 55 pounds including payload. 

Proposed operations of any other aircraft will require a new petition or a petition to 

amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA 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 or

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO 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 VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 
4

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein 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 or any law enforcement official upon request. The 

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

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an 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.

8. 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 prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. 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.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 
5

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

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

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

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

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

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

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

to the Administrator or any law enforcement official upon request.

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

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

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

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

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

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 
6

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

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

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

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 in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects 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.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

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

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. 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 
7

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
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This exemption terminates on September 30, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
1

June 3, 2015 

U.S. Department of Transportation 

Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Ave., SE 

Washington, DC 20590 

RE: Petition for Section 333 Exemption Under FAA Modernization and Reform Act of 2012 

Petitioner : Image In Flight 

Petitioner’s UAS(s) Models : DJI Phantom 2 Vision+; DJI Inspire 1 

Petitioner’s UAS(s) Operations : Aerial Photography; Aerial Videography; 

Aerial Mapping Services 

Regulations Requiring Exemption : 14 CFR §§ 61.23(a) and (c); 

14 C.F.R. §§ 61.101(e)(4) and (5)

14 C.F.R. § 61.113(a); 

14 C.F.R. §61.315(a)

14 C.F.R. § 91.7(a); 

14 C.F.R. § 91.119(c)

14 C.F.R. §91.121; 

14 C.F.R. §91.151(a)(1)

14 C.F.R. §91.405(a); 

14 C.F.R. §91.407(a)(1)

14 C.F.R. §§ 91.409(a)(1) and (2); and 

14 C.F.R. 91.417(a) and (b)

To whom it may concern, 

On behalf of Image In Flight (IIF), a Rancho Cordova, California, company specializing 

in aerial photography, aerial videography, and aerial mapping services through the use of Small 

Unmanned Aircraft Systems (sUAS), the undersigned counsel for IIF hereby applies for Section 

333 exemption pursuant to the FAA Modernization and Reform Act of 2012, Public Law 112-95 

(P.L. 112-95), and 14 C.F.R. Part 11. 
2

 The owner and operator of IIF, Thomas Michael Bartlett, holds a commercial pilot, 

rotorcraft-helicopter rating, with over 185 flight hours in rotorcraft-helicopters. Consequently, Mr. 

Bartlett understands the importance of safe flight operations and is acutely aware of the importance 

of complying with all Federal Aviation Regulations (F.A.R.s). As such, IIF, through the careful 

oversight and tutelage of Mr. Bartlett, will conduct all sUAS flight operations in the safest possible 

manner. To that end, IIF will comply with any flight operation or atmospheric condition limitations 

imposed upon the commercial operation of IIF’s sUAS models. 

The following petition outlines IIF’s sUAS models – DJI Phantom 2 Vision+ and DJI 

Inspire 1 – for which IIF seeks exemption, IIF’s sUAS flight operations and conditions, privacy 

concerns, public interest and safety concerns, and the above specified F.A.R.s requiring 

exemption. Under Section 333(b)(1), IIF’s petition will give the FAA good cause to issue a 

Certificate Of Waiver or Authorization (COA) by showing that the size, weight, speed, operational 

capacity, proximity to airports and populated areas, and operations within the Visual Line of Sight 

of the Pilot in Command and Visual Observer of IIF’s sUAS models do not create a hazard to users 

of the National Airspace System (NAS) or public or pose a threat to national security. 

IIF’s petition will prove that IIF’s flight operations and conditions for commercial usage 

of the DJI Phantom 2 Vision+ and DJI Inspire 1 for aerial photography, videography and mapping 

services provides an equivalent level of safety when compared to the F.A.R.s requiring exemption. 

To that end, the FAA has already granted Section 333 exemption to other commercial UAS 

operators with similar UAS make and models for similar commercial flight operations in 

Exemption Numbers 11699, 11693, 11062, 11109, 11112, 11213, and 11656. 

Please refer to the Table of Contents beginning on page three (3) to assist your review of 

IIF’s petition for Section 333 exemption. If we may provide additional insight or information 

regarding IIF’s petition, please do not hesitate to contact The Ison Law Group at 863-712-9475 or 

Christopher@thepilotlawyer.com. 

 Sincerely, 

THE ISON LAW GROUP 

 Christopher Ison, Esq. 

Enclosures 
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TABLE OF CONTENTS

I. Glossary of Terms ................................................................................4 

II. Publishable Summary ................................................................................5 

III. Petitioner’s Contact Information ..............................................................5 

IV. Image In Flight Operations .......................................................................6 

a. The sUAS(s) ................................................................................6 

i. DJI Phantom 2 Vision+ .....................................................7 

ii. DJI Inspire 1 .....................................................................10 

b. Flight Conditions and Operating Procedures ..........................................11 

V. Privacy .......................................................................................12 

VI. Public Interest and Safety .....................................................................12 

VII. Regulations from Which Exemption is Requested ..........................................13 

a. 14 CFR §§ 61.23(a) and (c): Medical Certificates Requirement and Duration ...............13 

b. 14 C.F.R. §§ 61.101(e)(4) and (5): Recreational Pilot Privileges and Limitations ...............13

c. 14 C.F.R. § 61.113(a): Private Pilot Privileges and Limitations: Pilot in Command ......13

d. 14 C.F.R. §61.315(a): What Are The Privileges and 

Limits of My Sport Pilot Certificate? ...................................................13

e. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness ...................................................14 

f. 14 C.F.R. § 91.119(c): Minimum Safe Altitude: General ..........................................14

g. 14 C.F.R. §91.121: Altimeter Settings ............................................................15

h. 14 C.F.R. §91.151(a)(1): Fuel Requirements For Flight In VFR Conditions ...............15

i. 14 C.F.R. §91.405(a): Maintenance Required ...................................................15

j. 14 C.F.R. §91.407(a)(1): Operation After Maintenance, 

k. Preventative Maintenance, Rebuilding, Or Alteration...............................................15

l. 14 C.F.R. §§ 91.409(a)(1) and (2): Inspections ...................................................15

m. 14 C.F.R. 91.417(a) and (b): Maintenance Records ..........................................15 

EXHIBIT LIST

Exhibit 1: DJI Phantom 2 Vision+ User Manual (52 pages) ..........................................16 

Exhibit 2: DJI Phantom 2 Vision+ Release Notes (7 pages) ..........................................69 

Exhibit 3: DJI Phantom 2 Vision+ Pilot Training Guide (12 pages) ..................................76 

Exhibit 4: DJI Inspire 1 User Manual (64 pages) ...................................................88 

Exhibit 5: DJI Inspire 1 Release Notes (6 pages) ..................................................152 

Exhibit 6: DJI Inspire 1 Maintenance Manual (2 pages) .........................................157 

Exhibit 7: DJI Inspire 1 Safety Guidelines (5 pages) ..................................................160 
4

GLOSSARY OF TERMS 

Aircraft: any contrivance invented, used, or designed to navigate, or fly in, the air (Title 49, United 

States Code (49 USC) § 40102). 

National Airspace System (NAS): the common network of U.S. airspace; air navigation facilities, 

equipment and services, airports or landing areas; aeronautical charts, information and services; 

rules, regulations and procedures, technical information, and manpower and material. 

Operational Control: with respect to a flight, means the exercise of authority over initiating, 

conducting or terminating a flight (14 CFR § 1.1). 

Pilot in Command (PIC): the person who has final authority and responsibility for the operation 

and safety of the flight; has been designated as PIC before or during the flight; and holds the 

appropriate category class and type-rating, if appropriate, for the conduct of the flight (14 CFR § 

1.1). 

Small Unmanned Aircraft System (sUAS): an unmanned aircraft and associated elements, 

including communication links and the components that control the unmanned aircraft, that are 

required for the pilot in command to operate safely and efficiently in the national airspace system 

(P.L. 112-95, Section 331), weighing less than 55 pounds, including payload. 

UAS Certificate of Waiver or Authorization (COA): an authorization issued by the Air Traffic 

Organization to an operator for a specific unmanned aircraft activity. 

Visual Line of Sight (VLOS): unaided (corrective lenses and/or sunglasses excepted) visual

contact between a pilot in command and an unmanned aircraft sufficient to maintain safe 

operational control of the aircraft, know its location, and be able to scan the airspace in which it is 

operating to see and avoid other air traffic or objects aloft or on the ground. 
5

PUBLISHABLE SUMMARY

Pursuant to 14 C.F.R §11.81(f), should the FAA require a publishable summary for the Federal 

Register, Image In Flight (IIF) submits the following information regarding the rules from which 

IIF seeks exemption and a brief description of the nature of the exemptions sought. 

IIF seeks exemption from the following Federal Aviation Regulations (F.A.R.s): 

14 CFR §§ 61.23(a) and (c); 14 C.F.R. §§ 61.101(e)(4) and (5); 14 C.F.R. § 

61.113(a); 14 C.F.R. §61.315(a); 14 C.F.R. § 91.7(a); 14 C.F.R. § 91.119(c); 14 

C.F.R. §91.121; 14 C.F.R. §91.151(a)(1); 14 C.F.R. §91.405(a); 14 C.F.R. 

§91.407(a)(1); 14 C.F.R. §§ 91.409(a)(1) and (2); and 14 C.F.R. 91.417(a) and (b). 

IIF seeks exemption from the above listed F.A.R.s for the purpose of commercially operating 

Small Unmanned Aircraft Systems (sUAS), to wit: DJI Phantom 2 Vision+ and DJI Inspire 1. IIF 

will commercially operate these sUAS models to conduct aerial photography, aerial videography, 

and aerial mapping services for website and social media outlets within the United States of 

America. IIF seeks exemptions equivalent to exemptions that the FAA has already granted to other 

commercial UAS operators with similar UAS make and models for similar commercial flight 

operations in Exemption Numbers 11699, 11693, 11062, 11109, 11112, 11213, and 11656. Under 

Section 333(b)(1) of the FAA Modernization and Reform Act of 2012, IIF’s petition will give the 

FAA good cause to issue a Certificate Of Authorization by showing that the size, weight, speed, 

operational capacity, proximity to airports and populated areas, and operations within the Visual 

Line of Sight of the Pilot in Command and Visual Observer of IIF’s sUAS models do not create a 

hazard to users of the National Airspace System (NAS) or public or pose a threat to national 

security. To that end, IIF seeks exemption from the specified F.A.R.s as IIF’s flight operations 

and conditions provide an equivalent level of safety when compared to the F.A.R.s to be exempted. 

IIF will adhere to any flight operation or atmospheric condition limitation imposed by the FAA. 

PETITIONER’S CONTACT INFORMATION 

Image In Flight 

3997 Machias Place 

Rancho Cordova, CA 95742 

Telephone: 916-599-8648 

Owner: Thomas Bartlett 

The Ison Law Group 

2073 US Hwy 92 West, Suite 104 

Winter Haven, FL 33881 

Telephone: 863-712-9475 

Email: Christopher@thepilotlawyer.com

Counsel for Petitioner 
6

IMAGE IN FLIGHT OPERATIONS 

sUAS Models and Specifications 

IIF’s requested exemption from the above specified F.A.R.s will allow for IIF’s use of the DJI 

Phantom 2 Vision+ and DJI Inspire 1 for commercial operations pertaining to aerial photography, 

aerial videography, and aerial mapping services within the United States of America. These sUAS 

models are either similar to, or the same as, sUAS models that the FAA has already granted 

exemption for similar commercial flight operations in Exemption Numbers 11699, 11693, 11062, 

11109, 11112, 11213, and 11656. 

The DJI Phantom 2 Vision+ and DJI Inspire 1 are quad-copter sUAS models, capable of providing 

hover flight in both the vertical and horizontal planes. As such, both sUAS models provide 

excellent maneuverability and ease of control for the PIC. The ease with which a PIC can control 

these sUAS models is evidenced by the fact that both sUAS models are commercially available 

for RC hobbyists, requiring no training or experience prior to flight. 

Both the DJI Phantom 2 Vision+ and DJI Inspire 1 additionally provide excellent situational 

awareness for the PIC. Both sUAS models allow the PIC to determine the exact altitude of the 

sUAS via GPS technology and monitoring. In addition, both sUAS models provide the PIC with 

the ability to monitor the available remaining battery life, allowing the PIC to make informed, safe 

decisions regarding the duration and continuation of a particular flight. 

IIF’s primary objective with each commercial flight is the safe return of the sUAS without injury 

to property or person. Both the DJI Phantom 2 Vision+ and DJI Inspire 1 incorporate unique 

operating modes that provide for the safe return of the sUAS should the PIC experience a loss of 

signal connectivity between the sUAS model’s transmitter and receiver. The DJI Inspire 1 

incorporates three safe modes in such a situation: Failsafe, Return to Home, and Dynamic Home 

Point. Likewise, the DJI Phantom 2 Vision+ incorporates a failsafe function should the sUAS 

experience loss of signal connectivity. Both models will guide the sUAS back to a predetermined, 

safe landing zone should the model experience issues. Please see the User Manuals for both the 

DJI Phantom 2 Vision+ and DJI Inspire 1 for more information regarding these safe modes. 

Given the nature of these particular sUAS models, IIF’s requested exemption from various F.A.R.s 

will neither adversely affect the public’s safety nor create a hazard to users of the National Airspace 

System (NAS) or pose a threat to national security. Moreover, IIF’s use of these sUAS models for 

aerial photography, aerial videography, and aerial mapping services, will replace the need for fixed 

winged or rotorcraft aircraft with regards to these services. 

By replacing fixed winged or rotorcraft aircraft with sUAS models, the public will benefit in 

several ways. For example, the use of these sUAS models provides significant reductions in the 

risk of injury to property or person should the sUAS require an emergency landing. Both the DJI 

Phantom 2 Vision+ and DJI Inspire 1 are lightweight, powered by batteries, and carry no 

passengers. By comparison, fixed winged or rotorcraft aircraft, which weigh thousands of pounds, 

carry flammable fuels, and passengers, have been known to cause serious injury or death to 

passengers and bystanders during emergency landings. The use of these particular sUAS models 
7

for aerial photography, aerial videography, and aerial mapping services will substantially benefit 

the public from a safety standpoint. 

Below are the specifications of each sUAS model. 

 

DJI Phantom 2 Vision+ 

Aircraft Specifications: 

Supported Battery: DJI 5200mAh Li-Po Battery 

Weight (Battery & Propellers included): 1242 grams 

Recommended Payload: ≤1300 grams 

Maximum Payload: 1350 grams 

Hovering Accuracy (Ready to Fly): Vertical: 0.8m; Horizontal: 2.5m 

Max Yaw Angular Velocity: 200֯/second 

Max Tiltable Angle: 35 ֯

Max Ascent/Descent Speed: Ascent: 6 m/s; Descent: 2 m/s 

Max Flight Speed: 15 m/s 

Motor Diagonal Length 350 mm 

3-axial Stabilized Gimbal Specifications: 

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

Control Accuracy: ±0.03֯

Controllable Range: Pitch: -90֯ - 0֯

Maximum Angular Speed: Pitch: 90֯/second 

Camera

Operating Environment Temperature: 0֯C - 40֯C 

Sensor Size: 1/2.3” 

Effective Pixels: 14 Megapixels 

Resolution: 4384x3288 

HD Recording: 1080p30/1080i60 

Recording FOV: 110֯/85֯ 

Remote Controller

Operating Frequency: 5.728 GHz – 5.85 GHz 

Communication Distance (open area): CE Compliance: 400m; FCC Compliance: 800m 

Receiver Sensitivity (1%PER): -93dBm 

Transmitting Power (EIRP): CE Compliance: 25mW; FCC Compliance: 100mW 

Working Current/Voltage: 120mA@3.7V 

Battery: 2000mAh rechargeable LiPo battery 

Range Extender

Operating Frequency: 2412MHz-2462MHz 

Communication Distance (open area): 500m-700m 

Transmitting Power: 20dBm 

Power Consumption: 2W 
8

For further information regarding the DJI Phantom 2 Vision+, please refer to the attached 

exhibits. 

DJI Inspire 1 

Aircraft

Weight (Battery Included): 2935 grams 

Hovering Accuracy (P Mode): Vertical: 0.5m; Horizontal: 2.5m 

Max Angular Velocity: Pitch: 300֯/s; Yaw: 150֯/s 

Max Tilt Angle: 35֯

Max Ascent Speed: 5 m/s 

Max Descent Speed: 4 m/s 

Max Speed: 22 m/s (ATTI mode, no wind) 

Max Flight Altitude: 4500 m 

Max Wind Speed Resistance: 10 m/s 

Max Flight Time: Approximately 18 minutes 

Motor Model: DJI 3510 

Propeller Model: DJI 1345 

Indoor Hovering: Enabled by default 

Operating Temperature Range: -10֯ C to 40֯C 

Diagonal Distance: 559 to 581 mm 

Dimensions: 438x451x301mm 

Gimbal

Model: ZENMUSE X3 

Output Power (with Camera): Static: 9W; In Motion: 11W 

Operating Current: Station: 750mA; Motion: 900mA 

Angular Vibration Range: ±0.03֯

Mounting: Detachable 

Controllable Range: Pitch: -90֯ to +30֯; Pan: ±320֯

Mechanical Range: Pitch: -125֯ to +45֯; Pan: ±330֯

Max Controllable Speed: Pitch: 120֯/s; Pan: 180֯/s 

Camera

Name: X3 

Model: FC350 

Total Pixels: 12.76M 

Effective Pixels: 12.4M 

Image Max Size: 4000x3000 

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

Remote Controller 

Name: C1 

Operating Frequency: 5.725~5.825GHz; 2.400~2.483GHZ 

Transmitting Distance: 2km (Outdoor and Unobstructed) 

EIRP: 10dBM@900, 12dBm@5.8G, 20dBm@2.4G 

Video Output Port: USB, Mini-HDMI 
9

Power Supply: Built-in battery 

Charging: DJI Charger 

Dual User Capability: Host-and Slave connection 

Mobile Devise Holder: Tablet or Smart Phone 

Output Power: 9W 

Operating Temperature Range: -10֯C to 45֯C 

Charging Temperature Range: 0-40֯C 

Battery: 6000 mAh LiPo 2S 

Charger

Model: A11-100P1A 

Voltage: 26.3V 

Rated Power: 100W 

Battery (Standard)

Name: Intelligent Flight Battery 

Model: TB47 

Capacity: 4500mAh 

Voltage: 22.2V 

Battery Type: LiPo 6S High voltage battery 

Energy: 99.9Wh 

Net Weight: 570g 

Operating Temperature Range: -10֯C to 40֯C 

Charging Temperature Range: 0-40֯C 

Max Charging Power: 180W 

For further information regarding the DJI Inspire 1, please refer to the attached exhibits. 

Flight Conditions and Operating Procedures 

IIF’s primary objective with every flight is the safe return of the sUAS model without injury to 

property or person. In order to obtain this desired objective, IIF will abide by the following 

operating and atmospheric conditions limitations when performing flight operations with the DJI 

Phantom 2 Vision+ and DJI Inspire 1 sUAS models: 

1. IIF will not operate the above described sUAS models when weighing more than 

55 pounds, including payload. 

2. IIF will not operate the above described sUAS models at a speed exceeding 87 

knots (100 miles per hour). IIF will use either groundspeed or calibrated airspeed 

to determine compliance with the 87 knot speed restriction. IIF prohibits operation 

of the sUAS models at airspeeds greater than the maximum sUAS operating 

airspeed recommended by the aircraft manufacturer. 

3. IIF will not operate the above described sUAS models at an altitude of more than 

400 feet above ground level (AGL). IIF will monitor altitude in feet AGL via GPS 

technology and monitoring. 
10

4. IIF will only operate the above described sUAS models within VLOS of the PIC at 

all times. IIF will require 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 or U.S. driver’s license. 

5. IIF requires the utilization of a visual observer (VO) on all commercial sUAS 

flights. The sUAS will be operated within VLOS of the PIC and VO at all times. 

The VO may be used to satisfy the VLOS requirement as long as the PIC always 

maintains VLOS capability. IIF requires that the VO and PIC be able to 

communicate verbally at all times. IIF does not permit electronic messaging or 

texting during flight operations. IIF requires the sUAS PIC to be designated before 

the flight and does not allow transfer his or her designation during the flight. The 

PIC must ensure that the VO can perform the duties required of the VO. 

6. IIF requires that all operating documents (defined as the granted exemption and all 

documents needed to operate the UAS model and conduct its operations in 

accordance with all grants conditions and limitations) must be accessible during 

sUAS operations and made available to the Administrator upon request. 

7. IIF will require a functional test should any sUAS model undergo maintenance or 

alterations that affect that sUAS’s operation or flight characteristics, e.g., 

replacement of a flight critical component, must undergo a functional test flight 

prior to conducting further operations under this exemption. IIF requires that all 

function flights be conducted by a PIC with a VO and remain at least 500 feet from 

other people. IIF further requires that the functional test flight be conducted in such 

a manner so as to not pose an undue hazard to persons and property. 

8. IIF will be responsible for maintaining and inspecting the above referenced sUAS 

models to ensure that the sUAS models are in a condition for safe operation. 

9. IIF requires that, prior to each flight, the PIC conduct a pre-flight inspection and 

determine whether the above referenced sUAS models are in a condition for safe 

flight. IIF requires that the pre-flight inspection must account for all potential 

discrepancies, e.g., inoperable components, items, or equipment. Should the 

inspection reveal a condition that affects the safe operation of the sUAS, IIF 

prohibits the aircraft from operating until the necessary maintenance has been 

performed and the sUAS is found to be in a condition for safe flight. 

10. IIF requires compliance with the above referenced sUAS models manufacturer’s 

maintenance, overhaul, replacement, inspection, and life limit requirements for the 

aircraft and aircraft components. 

11. IIF requires compliance with all manufacture safety bulletins for each above 

referenced sUAS model. 
11

12. IIF requires all sUAS PICs to hold either an airline transport, commercial, private, 

recreational, or sport pilot certificate. Further, IIF requires the PIC to also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

Government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 

13. IIF prohibits any PIC to operate a sUAS unless the PIC demonstrates the ability to 

safely operate the above referenced sUAS models in a manner consistent with how 

the sUAS model will be operated under this petition for exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from 

persons, vessels, vehicles and structures. To that end, IIF requires PIC qualification 

flight hours and currency to be logged in a manner consistent with 14 CFR § 

61.51(b). 

14. IIF prohibits flight operations of the above referenced sUAS models during night, 

as defined in 14 CFR § 1.1. All flight operations will be conducted under visual 

meteorological conditions (VMC). IIF will not allow the above referenced sUAS 

models to be flown during special visual flight rules (SVFR). 

15. IIF will not operate the above referenced sUAS models within 5 nautical miles of 

an airport reference point (ARP) as denoted in the current FAA Airport/Facility 

Directory (AFD) or for airports not denoted with an ARP, the center of the airport 

symbol as denoted on the current FAA-published aeronautical chart, unless a letter 

of agreement with that airport’s management is obtained or otherwise permitted by 

a COA issued to the exemption holder. IIF will make the letter of agreement with 

the airport management available to the Administrator or any law enforcement 

official upon request. 

16. IIF will operate the above referenced sUAS models at least 500 feet below and/or 

no more than 2,000 feet horizontally from a cloud. IIF will not operate the above 

referenced sUAS models when visibility is less than 3 statute miles. 

17. Should the sUAS lose communications or lose its GPS signal, IIF requires the 

sUAS to return to a pre-determined location within the private or controlled-access 

property. 

18. IIF requires the sUAS PIC to abort the flight in the event of unpredicted obstacles 

or emergencies. 

19. IIF prohibits the sUAS PIC from beginning a flight unless (considering wind and 

forecast weather conditions) there is enough available power for the above 

referenced sUAS models to conduct the intended operation and to operate after that 

for at least 5 minutes or with the reserve power recommended by the manufacturer 

if greater. 
12

20. IIF requires that all documents used to ensure safe operation and flight of the above 

referenced sUAS models and any documents required under 14 CFR §§ 91.9 and 

91.203 to be available to the PIC at the Ground Control Station of the sUAS any 

time the aircraft is operating. IIF will make these documents available to the 

Administrator or any law enforcement official upon request. 

21. IIF requires that during sUAS flights, the sUAS PIC remain clear and give way to 

all manned aviation operations and activities at all times. 

22. IIF prohibits sUAS operation by the PIC from any moving device or vehicle. 

23. IIF requires all sUAS flight operations to be conducted at least 500 feet from all 

nonparticipating persons, vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the sUAS and/or debris in the event of an accident. IIF will 

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 sUAS, IIF requires flight operations to cease 

immediately in a manner ensuring the safety of nonparticipating persons; 

and 

b. The owner/controller of any vessels, vehicles or structures has granted 

permission for operating closer to those objects 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. 

24. IIF will operate all sUAS flights over private or controlled-access property with 

permission from the property owner/controller or authorized representative. IIF will 

obtain permission from the property owner/controller or authorized representative 

prior to each flight to be conducted. 

PRIVACY

IIF’s use of the above referenced sUAS models for aerial photography, aerial videography, and 

aerial mapping services will not implicate any privacy concerns. Since IIF will only operate the 

sUAS models at the request of the property and/or business owner(s), IIF will have the express 

consent and permission of the property and/or business owner(s) prior to flying over private 

property. The use of these sUAS models for aerial photography, aerial videography, and aerial 

mapping services poses no greater privacy concerns than the use of traditional fixed winged or 

rotorcraft aircraft for similar activities. Images taken will be of individuals who have consented to 

being filmed or otherwise have agreed to be in the area where aerial imagery will take place 

PUBLIC INTEREST AND SAFETY

Unlike traditional fixed winged or rotorcraft aircraft, the use of the above referenced sUAS models 

for aerial photography, aerial videography and aerial mapping services promotes public interest 
13

and safety. Whereas traditional fixed winged or rotorcraft aircraft are large, heavy, noisy, require 

manned operators (placing the pilot’s life in jeopardy should there be an emergency) and are 

flammable, these sUAS models are small, light, quite, unmanned (i.e. not risking human life for 

the purpose of operation), and do not require flammable fuel as a means of propulsion. 

The use of IIF’s sUAS models also benefits the public from a safety perspective since these sUAS 

models do not run on fossil fuels. Since both of IIF’s sUAS models are battery powered, the use 

of these sUAS models over the traditional fixed wing or rotorcraft aircraft will be more 

environmentally and ecologically friendly. In addition, given the extremely light weight of these 

sUAS models, should an emergency result in a forced landing, injury to property or persons would 

be negligible compared to the catastrophic injury to property or persons that would result in an 

emergency landing of a traditional fixed winged or rotorcraft aircraft. 

Apart from the added safety benefits of sUAS flight operations, the use of sUAS for aerial 

photography, aerial videography, and aerial mapping services creates new economic opportunities 

that could fuel the continued growth of aviation and aviation related interests. Consequently, the 

public will benefit from the use of sUAS models for commercial purposes as companies like IIF 

will provide new jobs and economic opportunities, fueling innovation and creativity. 

REGULATIONS FROM WHICH EXEMPTION IS REQUESTED 

14 CFR §§ 61.23(a) and (c): Medical Certificates Requirement and Duration 

IIF requests exemption from 14 CFR §§ 61.23(a) and (c) which provides for certain flight 

operations requiring medical certificates. IIF’s petition for exemption provides an equivalent level 

of safety in that IIF would require a sUAS PIC to hold either a current medical certificate, of any 

class, or a valid U.S. Driver’s License. IIF’s petition for exemption provides an equivalent level 

of safety as provided in 14 C.F.R. §§61.23(a) and (c). 

14 C.F.R. §§ 61.101(e)(4) and (5): Recreational Pilot Privileges and Limitations; 14 C.F.R. § 

61.113(a): Private Pilot Privileges and Limitations: Pilot in Command; and 14 C.F.R. 

§61.315(a): What Are The Privileges and Limits of My Sport Pilot Certificate? 

IIF requests exemption from 14 C.F.R. §§ 61.101(e)(4) and (5) which prohibits recreational pilots 

from receiving compensation for hire or providing flight services in furtherance of a business, 

respectively. In addition, IIF requests exemption from 14 C.F.R. §61.113(a), which prohibits a 

certificated private pilot from receiving compensation or flying for hire when acting as PIC, and 

from 14 C.F.R. §61.315(a), which provides the holder of a sport pilot certificate may only act as 

pilot in command of a light-sport aircraft. 

IIF’s petition for exemption provides an equivalent level of safety in that IIF requires the PIC of a 

sUAS model, at the bare minimum, to hold the privileges of a sport pilot certificate under 14 C.F.R. 

§61 Subpart J, hold either a medical certificate or valid U.S. Driver’s License, and to demonstrate 

proficiency in the PIC’s ability to safely operate the sUAS models in a manner consistent with 

how the sUAS model will be operated under this petition for exemption.
14

Distinct comparisons between the commercial activities of IIF and other business operating 

traditional fixed wing or rotorcraft aircraft expose the unnecessary limitations placed upon sport, 

recreational and private certificated pilots when considering PIC privileges of commercial sUAS 

flight operations. Whereas requiring pilots of traditional fixed wing and rotorcraft aircraft to hold 

commercial and Airline Transport Pilot (ATP) ratings ensures that the pilots possess the necessary 

skills, training and experience to safely transport persons and/or cargo from the point of departure 

to the intended point of destination, the same correlation for sUAS pilots does not apply to the 

flight operations of IIF. 

In the case of IIF’s sUAS flight operations, no persons or cargo will be carried by the sUAS during 

IIF’s aerial photography, aerial videography, or aerial mapping. Unlike traditional fixed wing or 

rotorcraft aircraft, which must traverse over a greater distance, greater amount of property, and a 

greater amount of people in order to get from the point of departure to the intended point of 

destination, IIF’s sUAS will only fly over property authorized by IIF’s clients. In other words, the 

sUAS’s flight will not have to originate from a different location and traverse over the properties 

of disinterested parties in order to fulfill the purpose IIF’s flight operations. As such, the risk of 

injury to disinterested parties is substantially decreased by the use of a sUAS for aerial 

photography, aerial videography, and aerial mapping. 

Consequently, IIF’s requirement that the sUAS PIC hold, at least, a sport pilot certificate provides 

an equivalent level of safety to the requirement that a commercial or ATP rated pilot transport 

persons and/or cargo for hire in manned aircraft. 

14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness 

IIF requests an exemption from 14 C.F.R. §91.7(a) which prohibits the operation of civil aircraft 

unless it is in airworthy condition. As there will be no airworthiness certificate issued for IIF’s 

sUAS models, no standard will exist for determining airworthiness. In any event, IIF’s proposed 

Flight Conditions and Operating Procedure will ensure and equivalent level of safety with 14 

C.F.R. §91.7(a). 

14 C.F.R. § 91.119(c): Minimum Safe Altitude: General 

IIF requests an exemption from 14 C.F.R §91.119(c) which provides that except when necessary 

for takeoff or landing, no person may operate an aircraft below an altitude of 500 feet above the 

surface. Furthermore, this section provides that an aircraft may not be operated closer than 500 

feet to any person, vessel, vehicle, or structure. IIF’s petition requests that the sUAS models be 

flown at an altitude no higher than 400 feet AGL and, when complying with the conditions set 

forth in section 23(b) of IIF’s Flight Conditions and Operating Procedures, at distances closer than 

500 feet from any person, vessel, vehicle, or structure. 

IIF’s Flight Conditions and Operating Procedures provide for an equivalent level of safety. In any 

event, IIF’s sUAS are extremely lightweight, small, and would cause negligible injury to property 

or damage, when compared to the catastrophic damage that a traditional fixed wing or rotorcraft 

aircraft would inflict due to a forced landing. Moreover, the size, speed, and weight of IIF’s sUAS 

models dictate that the PIC and VO maintain VLOS, which will also promote signal connectivity 

between the sUAS’s transmitter and receivers. 
15

14 C.F.R. §91.121: Altimeter Settings 

IIF requests exemption from 14 C.F.R. §91.121 which provides guidelines for the use of altimeter 

settings while operating an aircraft. IIF’s petition for exemption provides an equivalent level of 

safety such that the sUAS model’s PIC will be able to determine the AGL height of the sUAS due 

to GPS technology. The AGL height of the sUAS will be displayed for the PIC during all flight 

operations. As such, the PIC will be able to maintain the requirement that the sUAS be no more 

than 400 feet AGL during all flight operations. 

14 C.F.R. §91.151(a)(1): Fuel Requirements For Flight In VFR Conditions 

IIF requests exemption from 14 C.F.R. §91.151(a)(1) which provides that no person may begin a 

flight in an airplane under VFR conditions with less than 30 minutes of reserve fuel. IIF’s petition 

for exemption provides an equivalent level of safety due to IIF’s prohibition against the PIC from 

beginning a flight unless (considering wind and forecast weather conditions) there is enough 

available power for the sUAS to conduct the intended operation and to operate after that for at 

least 5 minutes or with the reserve power recommended by the manufacturer if greater. 

Given the design and technology of the sUAS models that IIF intends to operate, IIF’s PIC will 

have access to all relevant information concerning the sUAS’s battery life. The PIC will be able to 

make an accurate determination as to whether the PIC can comply with IIF’s “fuel” requirements 

for each flight. 

14 C.F.R. §91.405(a): Maintenance Required; 14 C.F.R. §91.407(a)(1): Operation After 

Maintenance, Preventative Maintenance, Rebuilding, Or Alteration; 14 C.F.R. §§ 

91.409(a)(1) and (2): Inspections; 14 C.F.R. 91.417(a) and (b): Maintenance Records

IIF requests exemption from the following F.A.Rs: 14 C.F.R. §91.405(a) which provides the owner 

or operator of aircraft shall have the aircraft inspected pursuant to Subpart E of 14 C.F.R; 14 C.F.R. 

§91.407(a)(1) which provides that no person may operate any aircraft having undergone preventive 

maintenance unless approved for return to service by a person authorized under §43.7; 14 C.F.R. 

§§91.409(a)(1) and (2) which provides that no person may operate an aircraft within the preceding 

12 calendar months unless an annual inspection has been performed; and 14 C.F.R. §§91.417(a) 

and (b) which provides for the recording of an aircraft’s maintenance if the aircraft holds an 

airworthiness certificate. 

IIF’s petition for exemption provides an equivalent level of safety since IIF requires compliance 

with the sUAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit 

requirements for the aircraft and aircraft components. Due to the nature of a sUAS, compliance 

with certain maintenance requirements under Subpart E of 14 C.F.R. are either impossible or cost 

prohibitive to implement when applied to a sUAS. As such, IIF should be exempt from these 

regulations.