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December 17, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, D.C. 20590 

Re: Petition of Dragonfly Guys for Exemption from Certain Federal Aviation Regulations to 

Operate Unmanned Aircraft Systems Pursuant to Section 333 of the FAA Modernization and 

Reform Act 

Dear Sir or Madam: 

Pursuant to Section333 of the FAA Modernization and Reform Act ("FMRA") and 14 

C.F.R. part 11, Dragonfly Guys (Dragonfly) hereby petitions the Federal Aviation Administration 

("FAA") for exemption from 14 C.F.R. §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 

61.315(a), 91.7(a), 91.15l(a)(l), 91.119(c), 91.121, 91.405(a), 91.407(a)(l), 91.409(a)(l) and 

(2), and 91.417(a) and (b), and any other rules the FAA deems necessary, to enable Dragonfly to 

operate unmanned aircraft systems ("UAS") for aerial data collection and services. Specifically, Dragonfly 

seeks to operate UAS for aerial photography, facilities inspection, and production assistance using 

the DJI Phantom 3 Professional UAS.

I. PROPOSED OPERATIONS AND PUBLIC INTEREST BENEFITS 

Dragonfly, an employee-owned company, is a startup partnership with two principals.

Dragonfly will provide aerial photography services, both photo and video for clients requiring real estate

sales documentation, insurance inspections, news gathering and code enforcement inspections. 

UAS can provide a safe and cost-effective way to achieve these objectives. Grant of this petition 

will enable Dragonfly to better serve its customers in its operating area.
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Permitting Dragonfly to use UAS will result in:

Dragonfly's operations will carry minimal risk. Using UAS for aerial photography, visual facility inspection

will both eliminate the dangers associated with conducting these activities manually from the ground or 

in manned aircraft and enable Dragonfly to efficiently and quickly provide needed services. Dragonfly is 

committed to the safe operation as specified by current FAA regulations, the UAS manufacturer, and 

UAS industry recommendations.

This commitment ensures that Dragonfly will operate safely in the national airspace, mitigate the risks of 

harming other aircraft or people or property on the ground, and present no threat to national security. 

II. THE UAS 

Dragonfly requests an exemption to operate the DJI Phantom 3 Professional which is well below 55 

pounds including payload. Through the Section 333 exemption process, the FAA has authorized use of all 

UAS for which exemption is requested.

III. APPLICANT INFORMATION 

The name and contact information of the applicant is: 

James R. Adair, Partner

Dragonfly Guys

509 Bryan St.

Weatherford, Texas 76086

(817946-4818 radair1914@yahoo.com

IV. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED

14 C.F.R. §§ 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; 
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14 C.F.R. § 91.151(a)(l); 

14 C.F.R. § 91.405(a); 

14 C.F.R. § 91.407(a)(1); 

14 C.F.R. §§ 91.409(a)(l) and (2); 

14 C.F.R. §§ 91.417(a) and (b). 

V. OPERATING PARAMETERS 

Dragonfly will adhere to the following operating parameters when operating a UAS pursuant 

to a grant of the requested exemption: 

1. Operations will be conducted using the DJI Phantom 3 Professional. 

2. The UAS will not be operated at a speed exceeding 87 knots (1 00 miles per hour), at an altitude 

greater than 400 feet above ground level, or, when visibility is less than 3 statute miles, less than 500 

feet below or 2,000 feet horizontally from clouds. All operations will be conducted during the day under 

visual flight conditions. 

3. All operations will be conducted in accordance with a Certificate of Waiver or Authorization ("COA''). 

4. All operations will use a pilot-in-command ("PIC") and a visual observer ("VO"), and the UAS will 

remain within the visual line of sight of the PIC or the VO at all times. The PIC will maintain VLOS 

capability and the ability to communicate verbally with the VO during the duration of the flight.

5. The PIC will hold an airline transport, commercial, private, recreational, or sport pilot certificate, as 

well as an FAA airman medical certificate or a valid U.S. driver's license. The PIC will meet the flight 

review requirements specified in 14 C.F.R. § 61.56 in an aircraft in which the PIC is rated on his or her 

pilot certificate. 

6. Dragonfly will ensure prior to operation that the PIC has demonstrated 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 will be logged in a manner consistent 

with 14 C.F.R. § 61.51(b). 

7. Dragonfly's operating documents will be accessible during UAS operations and made available to the 

Administrator upon request. 
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8. Prior to each flight, the PIC will conduct a pre-flight inspection and determine the UAS is in a condition 

for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the UAS 

will not be operated until the necessary maintenance has been performed and the UAS is found to be in 

a condition for safe flight. 

9. If the UAS has undergone maintenance or alterations that affect the UAS operation or flight 

characteristics, e.g., replacement of a flight critical component, it will undergo a functional test flight 

prior to conducting further operations under this exemption. 

10. Dragonfly will follow the UAS manufacturer's maintenance, overhaul, replacement, inspection, and 

life limit requirements, as well as safety bulletins, for the aircraft and aircraft components. 

11. The PIC will abort the flight in the event of unpredicted obstacles or emergencies, and will yield to all 

manned aviation activities. 

12. Dragonfly will register and mark its UAS in accordance with 14 C.P.R. parts 47 and 45. 

VI. THE FAA'S AUTHORITY TO GRANT THIS PETITION 

The FAA has authority to grant the exemption requested herein under the FMRA and the Federal 

Aviation Act. Section 333 of the FMRA deals specifically with integrating UAS into the national airspace, 

and directs the Secretary of Transportation to determine which UAS, "as a result of their size, weight, 

speed, operational capability, proximity to airports and populated areas, and operation within visual line 

of sight do not create a hazard to users of the national airspace system or the public or pose a threat to 

national security." Section 333 further directs the Secretary to "establish requirements for the safe 

operation of such aircraft systems in the national airspace system. " The Federal Aviation Act authorizes 

the Administrator of the FAA to grant exemptions from regulations prescribed under certain provisions 

of the Act where such exemptions are in the public interest. Part 11 of the Federal Aviation Regulations 

governs the FAA's exemption process and requirements. The FAA has granted more than 2,600

exemptions to date pursuant to its Section 333 and exemption authority, enabling commercial UAS 

operations in a wide variety of industries. 

VII. SUMMARY TO BE PUBLISHED IN THE FEDERAL REGISTER 

Should the FAA determine that publication in the Federal Register is required, Dragonfly offers the 

following summary pursuant to section 11.81 of the FAA's rules:

Petitioner: Dragonfly Guys
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Sections of 14 C. FR. Affected: 14 C.F.R. §§ 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. § 

91.15l(a)(l); 14 C.F.R. § 91.405(a); 14 C.F.R. § 91.407(a)(l); 14 C.F.R. §§ 91.409(a)(1) and (2); 14 C.F.R. §§ 

91.417(a) and (b). 

Description of Relief Sought: Petitioner seeks relief from the requirements of 14 C.F.R. §§ 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); 

14C.F.R. § 91.119(c); 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a)(l); 14 C.F.R. § 91.405(a); 14 C.F.R. § 

91.407(a)(1); 14 C.F.R. §§ 91.409(a)(l) and (2); 14 C.F.R. §§ 91.417(a) and (b) to operate unmanned aerial 

systems for photography, aerial inspections, and commercial production.

VIII. CONCLUSION 

As demonstrated above, the UAS operations Dragonfly has proposed in this petition for 

exemption will garner significant public benefits by the creation of economic activity, while presenting 

minimal safety risks. 

Dragonfly's petition satisfies the criteria of Section 333 of the FMRA and respectfully requests that the 

FAA grant this petition to enhance Dragonfly's ability to provide beneficial services to business and the 

public. 

Sincerely, 

James R. Adair

Dragonfly Guys