UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

DOCKET MANAGEMENT SYSTEM

1200 NEW JERSEY AVENUE,

WASHINGTON, DC 20590

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

PRICE EDWARDS & COMPANY

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF THE FAA REFORM 

ACT AND PART 11 OF THE FEDERAL AVIATION REGULATIONS FROM

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 61.113(a) & (b), 61.101(e)(4) & (e)(5), 61.315(a), 91.7(a),91.119(c), 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 2 Vision+ and 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 September 24, 2015

Submitted by: 

DeBee Gilchrist, P.C.

1200 NW 63rd Street

Oklahoma City, Oklahoma 73116

On Behalf of:

Price Edwards & Company

210 Park Ave, Suite 1000

Oklahoma City, Oklahoma 73102
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TABLE OF CONTENTS

GLOSSARY OF ABBREVIATIONS 3

SUMMARY 4

INTRODUCTION AND INTERESTS OF THE PETITIONER 4

EQUIPMENT 4

BASIS FOR PETITION 5

A. NAME AND ADDRESS OF THE PETITIONER 8

B. THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH PRICE 

EDWARDS & COMPANY SEEKS EXEMPTION 8

C. THE EXTENT OF RELIEF PRICE EDWARDS & COMPANY 

SEEKS AND THE REASON PRICE EDWARDS & COMPANY 

SEEKS THE RELIEF 13

D. THE REASONS WHY GRANTING PRICE EDWARDS & 

COMPANY’S REQUEST WOULD BE IN THE PUBLIC INTEREST 

AND HOW IT WOULD BENEFIT THE PUBLIC AS A WHOLE 17

E. THE REASONS WHY GRANTING THE EXEMPTION WOULD 

NOT ADVERSELY AFFECT SAFETY, OR HOW THE EXEMPTION

WOULD PROVIDE A LEVEL OF SAFETY AT LEAST EQUAL 

TO THAT PROVIDED BY THE REGULATION FROM WHICH 

PRICE EDWARDS & COMPANY SEEKS EXEMPTION 21

F. A SUMMARY THAT CAN BE PUBLISHED IN THE 

FEDERAL REGISTER STATING THE RULES FROM WHICH 

PRICE EDWARDS & COMPANY SEEKS EXEMPTION 35

G. ANY ADDITIONAL INFORMATION, VIEWS, OR

ARGUMENTS AVAILABLE TO SUPPORT PRICE 

EDWARDS & COMPANY’S REQUEST 35

CONCLUSION 35

APPENDICES 38

APPENDIX A – DJI PHANTOM 2 VISION+ 

MANUFACTURER’S USER MANUAL 39

APPENDIX B – DJI PHANTOM 3 PROFESSIONAL 

MANUFACTURER’S USER MANUAL 40

APPENDIX C – MONTHLY MAINTENANCE LOG FORM 41
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GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

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

SO Safety Observer

SOP Standard OperatingProcedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing
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SUMMARY

Price Edwards & Company seeks exemption from the requirements of 14 C.F.R §§ 

61.113(a) & (b), 61.101(e)(4) & (e)(5), 61.315(a), 91.7(a), 91.119(c), 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 Price Edwards & Company 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

Price Edwards & Company is a commercial real estate company founded in 1988. Price 

Edwards & Company is based out of Oklahoma but also serves commercial real estate markets 

in Texas, Kansas, Missouri, and Arkansas. Price Edwards & Company seeks to use camera 

equipped UAS to provide its clients with a better and more detailed aerial view of the real 

property assets it represents on behalf of clients. Price Edwards & Company feels that UAS 

based aerial video and photography operations would provide safe, low cost, and high quality 

imaging in furtherance of its core real estate brokerage business.

EQUIPMENT

Price Edwards & Company seeks an exemption to operate DJI systems for compensation 

or hire within the NAS. The DJI Phantom 2 Vision+ and DJI Phantom 3 Professional are vertical 

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

utilizing remote transmitter, electronic tablet and/or smart phone systems. The DJI Phantom 2 

Vision+ has a maximum gross weight of approximately 2 pounds 12 ounces, while having a 
5

length of 20 inches, including propellers, width of 20 inches, including propellers, height of 8 

inches, and a maximum speed of approximately 29 knots. The DJI Phantom 3 Professional has a 

maximum gross weight of approximately 2 pounds 13 ounces, while having a length of 20 

inches, including propellers, width of 20 inches including propellers, height of 8 inches, and a 

maximum speed of approximately 31 knots. The DJI Phantom 2 Vision+ and DJI Phantom 3 

Professional are equipped with four main rotors which are driven by Lithium Polymer battery 

powered electric motors.

The DJI Phantom 2 Vision+ and DJI Phantom 3 Professional that will be operated by 

Price Edwards & Company 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 markedin

accordance with 14 C.F.R. Part 45, Identification and Registration Marking.

BASIS FOR PETITION

Petitioner, Price Edwards & Company, 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 allow for commercial operate of the DJI Phantom 2 Vision+ and theDJI 

Phantom 3 Professional UASs in the National Airspace System (NAS), and for an exemption 

fromthe requirements of 14 C.F.R §§ 61.113(a) & (b), 61.101(e)(4) & (e)(5), 61.315(a), 

91.7(a), 91.119(c), 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, operational capability, and limited 

operations and limited operating area associated with the unmanned aircraft, Price Edwards & 

Company’s operation of the DJI Phantom 2 Vision+ and DJI Phantom 3 Professional meets 
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the conditions of FMRA Section333 and therefore, will not require an airworthiness certificate

in accordance with 14 C.F.R. Part 21, Subpart H. Accordingly, Price Edwards & Company

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.

Price Edwards & Company submits that the requested relief is proper since an 

equivalent level of safety will be ensured. Price Edwards & Company will use experienced

personnel or technicians to perform maintenance, alterations, or preventive maintenance on the 

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

- the Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJI Phantom 3 Professional 

Instruction Manuals). Furthermore, Price Edwards & Company will document and maintain all 

maintenance records for the DJI Phantom 2 Vision+ and DJI Phantom 3 Professional via 

designated Monthly Maintenance Logs.

Relief from the requirements of Sections 61.113(a) and (b), 61.101(e)(4) and (e)(5),

and 61.315(a) concerning the privileges and limits of private pilots, recreational pilots, and 

sport pilots is requested by Price Edwards & Company to the extent necessary to allow a Pilot 

in Command (PIC) holding a private, recreational, or sport pilot certificate, or higher level 

certificate, as well as an airman medical certificate, and who has demonstrated, by meeting 

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

Phantom 2 Vision+ and DJI Phantom 3 Professional in a manner consistentwith this 

exemption, including evasive and emergency maneuvers and maintainingappropriate

distances from people, vessels, vehicles and structures.

Price Edwards & Company seeks relief from Section 91.7(a), entitled Civilaircraft 
7

airworthiness, because the DJI Phantom 2 Vision+ and DJI Phantom 3 Professional UASs do 

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

such, Price Edwards & Company submits that it will ensure that the DJI Phantom 2 Vision+

and 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., the Monthly 

Maintenance Log, and DJI Phantom 2 Vision+ and DJI Phantom 3 Professional Instruction 

Manuals), and that the aircraft are in a condition for safe flight.

Price Edwards & Company seeks relief from Section 91.119(c), entitled Minimum safe 

altitudes: General, because the DJI Phantom 2 Vision+ and DJI Phantom 3 Professional UASs 

will need to fly at elevations lower than 500 feet to perform their intended function under this 

petition for exemption and to comply with additional conditions and limitations proposed 

under this petition for exemption. However, relief from this section will not decrease safety. 

An equivalent or greater level of safety to Section 91.119(c) will be achieved given the size, 

weight, speed of the DJI Phantom 2 Vision+ and DJI Phantom 3 Professional UASs as well as 

the restricted areas and location where they will be operated.

Price Edwards & Company also seeks an exemption from the requirements of Section 

91.121, entitled Altimeter settings, as the DJI Phantom 2 Vision+ and DJI Phantom 3 

Professional UA will not have a standard adjustable barometric altimeter onboard. However, 

altitude information of the DJI Phantom 2 Vision+ and DJI Phantom 3 Professional UA will be 

provided to the PIC via electronic barometric pressure sensor, Global Positioning System 

(GPS) equipment, and radio communications telemetry data link, which downlinks from the 

UA to the GCS for active monitoring of the flight path. This altitude information, combined 

with Price Edwards & Company’s operation of the DJI Phantom 2 Vision+ and DJI Phantom 3 
8

Professional UAS within visual line of sight, at or below 400 feet AGL,will ensure a level of 

safety equivalent to Section 91.121.

Additionally, Price Edwards & Company seeks an exemption from the requirements 

of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. Price Edwards 

& Company submits that safety will not be affected by operation of the DJI Phantom2 

Vision+ and DJI Phantom 3 Professional UA during daylight hours in visual meteorological

conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a

total duration of approximately 14 minutes to the first point of intended landing and,

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

In accordance with 14 C.F.R. § 11.81, Price Edwards & Company 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:

Phillip Jackson

Price Edwards & Company

210 Park Ave, Suite 1000

Oklahoma City, OK 73102

Tel: (405) 236-1849

Email: pjackson@priceedwards.com

B. The Specific Sections of 14 C.F.R. From Which Price Edwards & Company Seeks 

Exemption

1. Price Edwards & Company 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.
9

(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. Price Edwards & Company Seeks Exemption From The Requirements Of 

Section 61.101(e)(4) and (e)(5)

 

Section 61.101, entitled Recreational pilot privileges and limitations, subsections

(e)(4) and (e)(5), state the following:

(e) Except as provided in paragraphs (d) and (i) of this section, a recreational pilot may 

not act as a pilot in command of an aircraft-

(4) For compensation or hire;

(5) In furtherance of a business;

3. Price Edwards & Company Seeks Exemption From The Requirements Of 

Section 61.315(a)

 

Section 61.315, entitled What are the privileges and limits of my sport pilot certificate, 

subsection (a), states the following:

(a) If you hold a sport pilot certificate you may act as a pilot in command of a lightsport aircraft, except as specified in paragraph (c) of this section.

Paragraph (c) goes on to ban a sport pilots from acting as pilot in command for 

compensation or hire.

4. Price Edwards & Company Seeks Exemption From The Requirements Of 

Section 91.7(a)

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), statesthe following:

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

5. Price Edwards & Company Seeks Exemption From The Requirements Of 

Section 91.119(c)

Section 91.119, entitled Minimum safe altitudes: General, subsection (c), statesthe

following:

Except when necessary for takeoff or landing, no person may operate an aircraft below 
10

the following altitudes:

(c) Over other than congested areas. An altitude of 500 feet above the surface, except 

over open water or sparsely populated areas. In those cases, the aircraft may not be 

operated closer than 500 feet to any person, vessel, vehicle, or structure.

6. Price Edwards & Company Seeks Exemption From The Requirements Of 

Section 91.121

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

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

of that aircraft, as the case may be, by reference to an altimeter that isset, 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 anappropriate 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 availablebefore

departure.

7. Price Edwards & Company 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.

8. Price Edwards & Company Seeks Exemption From The Requirement Of 

Section 91.405(a)

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

owner or operator of an aircraft—

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall 
11

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

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

9. Price Edwards & Company Seeks Exemption From The RequirementsOf 

Section 91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive maintenance,

rebuilding, or alteration, subsection (a)(1), states thefollowing:

(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 [.]

10. Price Edwards & Company Seeks Exemption From The Requirements Of 

Sections 91.409(a)(1) And (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 andhas been

approved for return to service by a person authorized by § 43.7 of this chapter;

or

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

with part 21 of this chapter.

11. Price Edwards & Company 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
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(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the

aircraft for return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and 

each rotor.

(ii) The current status of life-limited parts of each airframe,engine,

propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are 

required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the last 

inspection required by the inspection program under whichthe 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 foreach 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:

(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 beretained 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.
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C.The Extent Of Relief Price Edwards & Company Seeks And The Reason Price 

Edwards & Company Seeks The Relief

1. Extent Of Relief Price Edwards & Company Seeks And The Reason Price 

Edwards & Company Seeks Relief From Sections 61.113(a) And (b), 

61.101(e)(4) And (e)(5), and 61.315(a)

Relief from Sections 61.113(a) and (b), 61.101(e)(4) and (e)(5), and 61.315(a)

concerning the privileges and limits of private pilots, recreational pilots, and sport pilots, is 

requested to the extent necessary to allow a PIC holding a private pilot, recreational pilot, sport

pilot or higher level certificate, as well as a current and valid airman medical certificate, and 

who has met certain flight-hour and currency requirements, to conductthe proposed UAS flight

operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b), 

61.101(e)(4) and (e)(5), and 61.315(a) state that sport pilots and recreational pilots may not act 

as PIC of an aircraft for hire or compensation and that a private pilot may only act as PIC of an 

aircraft for compensation or hire in connection with any business or employment if: (1) The 

flight is only incidental tothat business or employment; and (2) The aircraft does not carry 

passengers or property for compensation or hire.

As set forth more fully below, Price Edwards & Company submits that an equivalent 

level of safety will be maintained because no PIC will be allowed to operate the DJI Phantom 

2 Vision+ UAS or DJI Phantom 3 Professional UASs unless that PIC has met certainflighthour and currency requirements, demonstrating that the PIC is able to safely operate either the 

DJI Phantom 2 Vision+ or DJI Phantom 3 Professional UAS in a manner consistent with the

operation specifications as described in this exemption, including evasive and emergency

maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and 

structures.
14

2. Extent Of Relief Price Edwards & Company Seeks And The Reason Price 

Edwards & Company 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 Price Edwards & Company to determine that the DJI Phantom2 

Vision+ and DJI Phantom 3 Professional UAS are in airworthy condition prior to every flight

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

Maintenance Log, and DJI Phantom 2 Vision+ and DJI Phantom 3 Instruction Manual).

Price Edwards & Company seeks the requested relief because the DJI Phantom 2 

Vision+ and DJI Phantom 3 Professional UAS do not require an airworthiness certificate in

accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Price Edwards & Company will 

ensure that the DJI Phantom 2 Vision+ and DJI Phantom 3 Professional UAS are in airworthy 

condition based uponits compliance with the operating documents (i.e., the Monthly

Maintenance Log, and DJI Phantom 2 Vision+ and DJI Phantom 3 Professional Instruction

Manual) prior to every flight, and further, determine that the aircraft are in condition for safe 

flight, as stated in the conditions and limitations below.

3. Extent Of Relief Price Edwards & Company Seeks And The Reason Price 

Edwards & Company seeks Relief From Section 91.119(c)

Relief from Section 91.119(c) entitled Minimum safe altitudes: General, is requested to

the extent required to allow Price Edwards & Company to operate the DJI Phantom2 Vision+ 

and DJI Phantom 3 Professional UASs in a manner consistent with the intended operations for 

which this petition is submitted (i.e., for the commercial purpose of conducting aerial video

and photography of construction sites, real estate, and landscape over certain areas of the 

United States). In order to operate the DJI Phantom2 Vision+ and DJI Phantom 3 Professional 

UASs in such a manner, the DJI Phantom2 Vision+ and DJI Phantom 3 Professional UASs 
15

will need to fly at an altitude below 500 feet over non-congested areas.

Additionally, relief from Section 91.119(c) is sought so that Price Edwards & 

Company’s operation of the DJI Phantom2 Vision+ and DJI Phantom 3 Professional UASs 

can comply with the applicable conditions and limitations stated below, specifically those 

relating to maximum operating altitude. The maximum operating altitude limitations and 

conditions set forth below are suggested to allow for maximum safety with regard to other 

aircraft operating in the NAS, especially manned aircraft.

Considering the specifications of the DJI Phantom2 Vision+ and DJI Phantom 3 

Professional UASs and the conditions and limitation to their operations by Price Edwards & 

Company, as proposed herein, the requested relief from Section 91.119(c) will not decrease 

safety to persons or property on the ground or to other aircraft operating in our NAS. As more 

fully set forth herein, an equivalent or greater level of safety will be achieved given the size, 

weight, speed of the DJI Phantom 2 Vision+ and DJI Phantom 3 Professional UASs as well as 

the limited operations they seek to undertake and the restricted locations where they will be 

operated.

4. Extent Of Relief Price Edwards & Company Seeks And The Reason Price 

Edwards & Company Seeks Relief From Section 91.121

Relief from Section 91.121, entitled Altimeter settings, is required to allow flight 

operations of the DJI Phantom 2 Vision+ and DJI Phantom 3 Professional UASs, 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) based on local barometric pressure,

Price Edwards & Company seeks the requested relief because the DJI Phantom 2 Vision+ and 
16

DJI Phantom 3 Professional UA altimeter and GPS system 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 C.F.R

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 2 Vision+ and DJI Phantom 3 Professional UA are equipped

with a barometric pressure sensor and GPS equipment, which automatically ensures that a

ground level pressure setting will be established prior to each flight, and provides the PIC with 

altitude information of the UA on the heads-up display of theGCS.

5. Extent Of Relief Price Edwards & Company Seeks And The Reason Price 

Edwards & Company Seeks Relief From Section 91.151(b)

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

is requested to the extent required to allow flights of the battery powered DJI Phantom 2 

Vision+ and DJI Phantom 3 Professional UA during daylight hours in visual meteorological

conditions (VMC), under visual flight rules (VFR), for a total duration of 14 minutes to the 

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

5 minutes. Price Edwards & Company seeks the requested relief because withoutan exemption 

from Section 91.151(b), the flight time duration of the battery powered DJI Phantom 2 

Vision+ and DJI Phantom 3 Professional will severely constrain the practicality of any aerial 

video or still photo flight operations that Price Edwards & Company proposes to conduct 

pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the DJI Phantom 2 

Vision+ and DJI Phantom 3 Professional UASs, the DJI Phantom 2 Vision+ and DJI Phantom 

3 Professional operating documents, and Price Edwards & Company’s proposed operating 
17

limitations, ensure that Price Edwards & Company will safely operate the battery powered DJI 

Phantom 2 Vision+ and DJI Phantom 3 Professional UA during daylight hours in visual 

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

to fly for a total duration of 14 minutes to the first point of intended landing and, assuming

normal cruising speed, to fly after that for at least 5 additional minutes.

6. Extent Of Relief Price Edwards & Company Seeks And The Reason Price 

Edwards & Company 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, Price Edwards & Company requests

relief from these Sections because the DJI Phantom 2 Vision+ and DJI Phantom 3 

Professional UASs do not require airworthiness certificates. As set forth more fully below, the 

DJI Phantom 2 Vision+ and DJI Phantom 3 Professional UASs meet the conditions of FMRA 

Section 333 for operation without an airworthiness certificate. Accordingly, Price Edwards & 

Company will use trained technicians to perform maintenance, alterations, or preventive 

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

operatingdocuments (i.e., the Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJI 

Phantom 3 Professional Instruction Manuals).Furthermore, Price Edwards & Company will

document and maintain all maintenance records for the DJI Phantom 2 Vision+ and DJI 

Phantom 3 Professional UASs.

D. The Reasons Why Granting Price Edwards & Company’s Request Would Be In The 

Public Interest And How It Would Benefit The Public As A Whole

Granting the present Petition will further the public interest by allowing Price Edwards 

& Company to safely, efficiently, and economically perform aerial video and photography of 

construction sites, real estate, and landscape over certain areas of the United States.
18

Additionally, use of the DJI Phantom 2 Vision+ and DJI Phantom 3 Professional UASs

will decrease congestion of the NAS, reduce pollution, increase safety, and provide significant 

benefits to the economy. Furthermore, the benefits of Price Edwards & Company’s proposed 

operation of theDJI Phantom 2 Vision+ and 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 2 Vision+ and DJI Phantom 3 Professional UA are battery powered 

and offer 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 video and photography, an exemption allowing the use of a the DJI Phantom 2 

Vision+ orDJI Phantom 3 Professional UAS would reduce the amount of manned aircraft in

the NAS and increase the safety of life and property in the air and on the ground.

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

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

Phantom 2 Vision+ and DJI Phantom 3 Professional UA do not require an airport to takeoff 

or land. Accordingly, aerial video and photography missions conducted by the DJI Phantom 2 

Vision+ and DJI Phantom 3 Professional UA 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 Decreased Pollution 

Conducting aerial video and photography with the DJI Phantom 2 Vision+ and 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 photography flight operations. By using battery power and electric motors, the DJI 
19

Phantom 2 Vision+ and DJI Phantom 3 Professional UASs produce no air pollution which is a 

significant improvement over the cabin class, six cylinder, internal combustion engine aircraft 

typically utilized for aerial video andphotography which burn approximately 20-30 gallons 

leaded aviation fuel per hour. The DJI Phantom 2 Vision+ and DJI Phantom 3 Professional 

UA, while reducing the carbon footprint ofaerial acquisitions, also eliminate noise pollution as 

the UAs are propelled by relatively quiet electric motors as opposed to the incredibly loud fuel 

powered engines found on most manned aircraft.

3. The Public Will Benefit From Increased Safety 

By using the DJI Phantom 2 Vision+ and DJI Phantom 3 Professional UASs to 

perform aerial video and photography, the substantial risk to life and property in the air and 

on the ground 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 2 Vision+ and DJI Phantom 3 Professional UA

(each of which contain no onboard fuel and weigh less than three pounds), have 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 which can weigh thousands of 

pounds and carry hundreds of gallons of combustible fuel.

4. The Public Will Benefit From Increased Economic Activity

In addition to being safe and efficient, the DJI Phantom 2 Vision+ and DJI Phantom 3 

Professional UASs are also an economical alternative to using manned aircraft to conduct

similar aerial video and photography operations. As such, operation of the DJI Phantom 2

Vision+ and DJI Phantom 3 Professional UASs will allow United States based companies

with such a need, like Price Edwards & Company, to advance their business, remain 
20

competitive, and therefore contribute to growth of the U.S. economy. Specifically, with the

rising cost of aviation fuel and the high cost of manned aircraft operations, U.S. owned 

companies needing such services must adopt new and alternative technology in order to cost 

effectively continue operations. Operating the battery powered DJI Phantom 2 Vision+ and 

DJI Phantom 3 Professional UASs is one such alternative that allows companies greater 

operational flexibility without the high operational cost of using a traditional manned aircraft.

By operating the DJI Phantom 2 Vision+ and DJI Phantom 3 Professional UASs, 

companiessuch as Price Edwards & Company, can remain competitive and profitable, and 

therefore, provide greater job stability to employees and contractors, which will ultimately 

contribute to growth of the U.S. economy as a whole. Improved financial performance of U.S. 

companies through commercial use of UASs, such as the DJI Phantom 2 Vision+ and DJI 

Phantom 3 Professional, provides astable workforce that increases consumer spending,

improves local, state, and federal tax revenues, and allows companies to invest in their 

industry in order toremain competitive in the United States andabroad.

5. The Public Will Not Suffer Any Additional Privacy Issues

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

decades, Price Edwards & Company’s proposed operation of the DJI Phantom 2 Vision+ and

DJI Phantom 3 Professional UASs will not implicate any privacy issues. Specifically, the DJI 

Phantom 2 Vision+ and DJI Phantom 3 Professional UASs will be operated only in 

compliance with applicable laws, operating documents (i.e., the Monthly Maintenance Log, 

and DJI Phantom 2 Vision+ and DJI Phantom 3 Professional InstructionManual), any 

conditions and limitations imposed, and in accordance with the Federal Aviation Regulations, 

including the minimum altitude requirements of 14 C.F.R. §91.119 to the extent from which 
21

exemption is not granted. Accordingly, there will be no additional privacy concerns when 

compared to manned aerial photography and video operations.

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or 

How The Exemption Would Provide A Level Of Safety At Least Equal To That 

Provided By The Regulation From Which Price Edwards & Company Seeks

Exemption

1. Reasons Why The DJI Phantom 2 Vision+ and DJI Phantom 3 Professional UA

Meet The Conditions Of The FAA Modernization and Reform Act of 2012

(FMRA) Section 333

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

the unmanned aircraft and their operation, Price Edward & Company’s operation ofthe DJI 

Phantom 2 Vision+ and DJI Phantom 3 Professional UASs meets the conditions of FMRA

Section 333, and therefore they will not require airworthiness certificates in accordance with 

14 C.F.R. Part 21, Subpart H.

Section 333 provides authority for a UAS to operate without airworthiness certification 

and sets forth requirements for considering whether a UAS will create a hazard to users of the

NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section

333 states the following, in part:

(a) In General.--Notwithstanding any other requirement of this subtitle, and not later 

than 180 days after the date of enactment of this Act, the Secretaryof

Transportation shall determine if certain unmanned aircraft systems may operate 

safely in the national airspace system before completion of the plan and 

rulemaking required by section 332 of this Act or the guidance required by section 

334 of this Act.

(b) Assessment of Unmanned Aircraft Systems.--In making the determinationunder 

subsection (a), the Secretary shall determine, at a minimum--

(1) which types of unmanned aircraft systems, if any, as a result of their size, 

weight, speed, operational capability, proximity to airports and populated 

areas, and operation within visual line of sight do not create a hazard to 

users of the national airspace system or the public or pose a threat to 

national security; and
22

(2) whether a certificate of waiver, certificate of authorization, or airworthiness 

certification under section 44704 of title 49, United States Code, is required 

for the operation of unmanned aircraft systems identified under paragraph

(1).

(c) Requirements for Safe Operation.--If the Secretary determines underthis 

section that certain unmanned aircraft systems may operate safely in the

national airspace system, the Secretary shall establish requirements for the safe

operation of such aircraft systems in the national airspace system.

In seeking this exemption, Price Edwards & Company submits that the DJI Phantom2 

Vision+ and DJI Phantom 3 Professional UASs can operate safely in the NAS pursuant to 

FMRASection 333, as demonstrated by: (a) the characteristics of the DJI Phantom 2 Vision+ 

andDJI Phantom 3 Professional UASs; (b) the pilot certification requirements necessary to 

operate the DJI Phantom 2 Vision+ andDJI Phantom 3 Professional UASs; and (c) the specific

operating limitations of the DJI Phantom 2 Vision+ andDJI Phantom 3 Professional UASs.

a. The Specifications Of The DJI Phantom 2 Vision+ and DJI Phantom 3 

Professional UASs Demonstrate Their Safe Characteristics

The DJI Phantom 2 Vision+ and DJI Phantom 3 Professional UASs do not create a

hazard to users of the NAS or the public, or otherwise pose a threat to national security 

considering their size, weight, speed, and operational capability.

i. The DJI Phantom 2 Vision+ and DJI Phantom 3 Professional UASs

Autonomous Flight And Navigation Modes Enable The UASs To 

Remain Within A Defined Operational Area

The DJI Phantom 2 Vision+ and DJI Phantom 3 Professional UASs may be operated in

both manual and fully autonomous flight modes. A complete description of the flightand

navigational modes of the DJI Phantom 2 Vision+ and DJI Phantom 3 Professional UASs is 

provided in the DJI Phantom 2 Vision+ and DJI Phantom 3 Professional User Manuals, 

attached hereto as Exhibit A and B.
23

ii. The DJI Phantom 2 Vision+ and DJI Phantom 3 Professional UASs 

AreDesigned For Automatic Return To Home Point Or Hover In The 

Event Of Loss Of The Control Link Or Navigation

If the Control Link is lost, the DJI Phantom 2 Vision+ and DJI Phantom 3 Professional

UA will remain stationary, in flight, for 3 seconds. If, after 3 seconds, the DJI Phantom 2 

Vision+ and DJI Phantom 3 Professional UA do not re-establish Control Link data from the 

GCS, the UA will assume that the Control Link is lost and the UA will return to the home 

position (i.e., Failsafe Function) via GPS, and will descend to the original takeoff position and

shutdown.

A complete description of the Failsafe Functions of the DJI Phantom 2 Vision+ and

the DJI Phantom 3 Professional UASs are available in the DJI Phantom 2 Vision+ and DJI

Phantom 3 Professional User Manuals, attached hereto as Exhibit A and B.

iii. The DJI Phantom 2 Vision+ and DJI Phantom 3 Professional

GCS AndIts Operation

A complete description of the operation and specifications of the DJI Phantom 2 

Vision+ and DJI Phantom 3 Professional GCSs and flight control software is provided in the

DJI Phantom 2 Vision+ and DJI Phantom 3 Professional User Manuals attached hereto as 

Exhibits A and B.

b. Flight Operations Of DJI Phantom 2 Vision+ and DJI Phantom 3 

ProfessionalUASs Are Limited To The Line Of Sight Of A Certificated 

Pilot in Command With A Safety Observer

Price Edwards & Company will only utilize eligible certificated pilots who possess a

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

act as a pilot in command (PIC) of the DJI Phantom 2 Vision+ and DJI Phantom 3 Professional

UASs. Additionally, a safety observer will assist the PIC during all flights.
24

c. Flights Of DJI Phantom 2 Vision+ and DJI Phantom 3 Professional

UASs Will Be Conducted Pursuant To Specific Operating Limitations

In seeking this exemption, Price Edwards & Company proposes to commercially 

operate DJI Phantom 2 Vision+ and DJI Phantom 3 Professional UASs for the special purpose

of conducting aerial video and photography over certain areas of United States, pursuant to the 

following specific operating conditions limitations:

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

Vision+ and the DJI Phantom 3 Professional UASs 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. UAS operations under this exemption will be limited to conducting operations for 

the purpose of aerial video and photography.

3. The UA may not be flown at an indicated airspeed exceeding 32 knots. Groundspeed 

or calibrated airspeed may be used to determine compliance with the 32 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) unless a special request is made and approved by ATC or a separate COA 

allowing for such is obtained. Altitude must be reported in feet AGL.

5. The UAs must be operated within visual line of sight (VLOS) of the PIC at all 

times. This requires the PIC to be able to use human vision unaided by any 

device other than corrective lenses, as specified on the PIC’s FAA-issued airman 

medical certificate.

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

the 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 forthe duration of the flight. The PIC must 

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

7. The exemption and all documents needed to operate the UAS, including 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 contained in the grant of exemption and the procedures outlined in 

the operating documents,the conditions and limitations contained in the grant of 

exemption take precedence and must be followed. Otherwise, the operator must 

follow the procedures as outlined in its operating documents. The operator may 
25

update or revise its operating documents. It is the operator’s responsibility to track 

such revisions and present updated and revised documents to the Administrator 

upon request. The operator must also present updated and revised documents if it

petitions for extension or amendment to the grant of exemption. If the operator

determines that any update or revision would affect the basis upon which the FAA

granted the exemption, then the operator must petition for amendment to its grant of 

exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if 

questions arise regarding updates or revisions to the operating documents.

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

operation or flight characteristics 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 inspect the UAS to ensure that it is in a 

condition for safe flight. The pre-flight inspection must account for all potential 

discrepancies. If the inspection reveals a condition that affects the safe operation 

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

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

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

inspection. All maintenance and alterations must be properly documented in the 

aircraft records.

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

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

components.

12. The operator must carry out its maintenance, inspections, and recordkeeping

requirements, in accordance with the operating documents.Maintenance, inspection, 

alterations, and status of replacement/overhaul component parts must be noted in the 

aircraft records, including total time in service, description of work accomplished, 

and the signature of the authorized person returning the UAS to service.

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

Safety Bulletins.

14. A PIC must hold 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 government.

15. The operator may not permit any PIC to operate unless the PIC meets the operator’s 
26

qualification criteria and demonstrates the ability to safely operate the UAS in a 

manner consistent with how the UAS will be operated under the exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances 

from persons, vessels, vehicles and structures. PIC qualification flight hours must

be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes 

of training the operator’s PICs and VOs are permitted under the terms of the 

exemption. However, training operations may only be conducted during dedicated 

training sessions. During training flights, all persons not essential for flight 

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

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

16. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. 

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

flight at night is required, a special request will be made to the FAA via COA 

request or other appropriate channel. Flights under special visual flight rules (SVFR) 

are not authorized.

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

as denoted on the most current FAA-published aeronautical chart or directory 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.

18. 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.

19. 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.

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

emergencies.

21. 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.

22. All operations shall be conducted in accordance with an Air Traffic Organization 

(ATO) Certificate of Waiver or Authorization (COA). 

23. All aircraft operated in accordance with the exemption must be identified by 

serial number, registered in accordance with 14 C.F.R. part 47, andhave

identification (N- Number) markings in accordance with 14 C.F.R. part 45, 

Subpart C. Markings must be as large as practicable.

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

UAS and any document required under 14 C.F.R. §§ 91.9 and 91.203 must be 

available to the PIC at the Ground Control Station of the UAS any time the UA
27

is operating. These documents must be made available to the Administrator or 

any law enforcement official upon request.

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

operations and activities at all times.

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

27. All flight operations must be conducted at least 500 feet from all nonparticipating 

persons (excluding the PIC, VO, operator trainees or persons deemed essential), 

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 leavesuch protection and are 

within 500 feet of the UA, flight operations must cease immediately in a 

manner ensuring the safety of nonparticipating persons; and/or

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

permission for operations 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.

28. 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.

29. 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) within24 hours.

Accidents must be reported to the National Transportation Safety Board (NTSB) 

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

2. Reasons Why An Exemption From The Requirements Of Sections 61.113(a) 

And (b), 61.101(e)(4) And (e)(5), & 61.315(a) Would Not Adversely Affect

Safety

Price Edwards & Company submits that the equivalent level of safety establishedby 

Section 61.113(a) and (b), 61.101(e)(4) and (5), and 61.315(a) will be maintained because no 

PIC will be allowed to operate the DJI Phantom 2 Vision+ and DJI Phantom 3 Professional

UASs unless that PIC has demonstrated, by meeting minimum flight-hour and currency 

requirements, that the PIC is able to safely operate the DJI Phantom 2 Vision+ or DJI Phantom 
28

3 Professional UAS in a manner consistent with the exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and

structures.

Considering Price Edwards & Company’s proposed area of operations, and the 

operating limitations set forth-above; the parallel nature of private pilot, recreational pilot, and 

sport pilot aeronautical knowledge requirements to those of commercial pilot requirements and 

the airmanship skills necessary to safely operate the DJI Phantom 2Vision+ or DJI Phantom 3 

Professional UASs, Price Edwards & Company submits that the additionalmanned airmanship 

experience of a commercially certificated pilot would not correlate to the airmanship skills 

necessary for Price Edwards & Company’s specific proposed flight operations of the DJI 

Phantom 2Vision+ or DJI Phantom 3 Professional UASs.

Price Edwards & Company will not allow any PIC to operate the DJI Phantom2 

Vision+ or DJI Phantom 3 Professional UASs unless that PIC has demonstrated, by meeting

minimum flight-hour requirements for the DJI Phantom 2 Vision+ or DJI Phantom 3 

Professional UAS trainingand currency requirements, that the PIC is able to safely operate the 

DJI Phantom 2 Vision+or DJI Phantom 3 Professional UAS in a manner consistent with this 

exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. Specifically, the PIC must have 

accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total 

time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot

operating the same make and model of UAS to be used for operations under the exemption). 

In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the 

preceding 90 days (for currency purposes).
29

Accordingly, Price Edwards & Company will ensure safe operations by not allowing

any PIC to operate the DJI Phantom 2 Vision+ or DJI Phantom 3 Professional UAS unless 

that PIChas demonstrated, by meeting minimum flight-hour and currency requirements, that 

the PICis able to safely operate the DJI Phantom 2 Vision+ or DJI Phantom 3 Professional

UAS in amanner consistent with the exemption, including evasive and emergency maneuvers

and maintaining appropriate distances from people, vessels, vehicles and structures.

The FAA has recently granted relief from Section 61.113(a) and (b), 61.101(e)(4) and 

(e)(5), and 61.315(a) specific to UASs, in circumstances similar, in all material respects, to 

those presented herein (e.g. Exemption Nos. 11998, 12426, 12468, & 12220).

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) 

Would Not Adversely Affect Safety

The equivalent level of safety established by Section 91.7(a) will be maintained because 

prior to every flight, Price Edwards & Company will ensure that the DJI Phantom 2 Vision+ or

DJI Phantom 3 Professional UAS is in an airworthy condition based upon the UAS’s

compliance with its operating documents and as stated in the conditions and limitations

described herein.

Additionally, the FAA has recently granted relief from Section 91.7(a) specific to

UAS, in circumstances similar, in all material respects, to those presented herein (e.g.

Exemption Nos. 11998, 12426, 12468, & 12220).

4.Reasons Why An Exemption From The Requirements Of Section 91.119(c) 

Would Not Adversely Affect Safety

The equivalent level of safety established by Section 91.119(c) will be maintained given 

the size, weight, and speed of the DJI Phantom 2 Vision+ and DJI Phantom 3 Professional 

UASs as well as the limited operations Price Edwards & Company seeks to undertake with the 
30

DJI Phantom 2 Vision+ and DJI Phantom 3 Professional UASs and the restricted locations 

where the DJI Phantom 2 Vision+ and DJI Phantom 3 Professional UAS will be operated. 

The DJI Phantom 2 Vision+ and DJI Phantom 3 Professional UASs are relatively small, 

light, and slow aircraft when compared to manned aircraft and the DJI Phantom 2 Vision+ and

DJI Phantom 3 Professional UASs will only be operated in permitted non-congested areas. 

Operations of the DJI Phantom 2 Vision+ and DJI Phantom 3 Professional UASs by Price 

Edwards & Company will be conducted in accordance with the conditions and limitations set 

forth herein and only on property for which permission for such operations has been obtained.

Additionally, the relief sought from Section 91.119(c) along with the conditions and 

limitations set forth herein will virtually ensure that operations of the DJI Phantom 2 Vision+

and DJI Phantom 3 Professional UASs by Price Edwards & Company will not interfere with 

manned aircraft operations in the NAS due to the fact that manned aircraft rarely operate at 

such a low altitude. Such operations by Priced Edwards & Company will reduce air traffic in 

the more heavily trafficked air spaces. 

The FAA has recently granted relief from Section 91.119(c) specific to UAS, in

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 

11998, 12426, 12468, & 12220).

5.Reasons Why An Exemption From The Requirements Of Section 91.121 

Would Not Adversely Affect Safety

The equivalent level of safety established by Section 91.121 will bemaintained

because the altitude information of the DJI Phantom 2 Vision+ and DJI Phantom 3 

Professional UAwill be provided to the PIC via GPS equipment, an electronic barometric 

pressure sensor, and a radio communications telemetry data link, which downlinks from the

UA to the GCS for active monitoring of the flight path and altitude. This altitude information, 
31

combined with Price Edwards & Company’s operation of the DJI Phantom 2 Vision+ and DJI

Phantom 3 Professional UA within visual line of sight, at or below 400 feet AGL, will ensure 

a level of safety equivalent to Section 91.121. The altitude information will be generated by 

GPS equipment and a barometric pressure sensor installed onboard the aircraft. Priorto each 

flight, a zero altitude initiation point is automatically established by the UAS at ground level 

so that altitude can be measured in feet AGL.

The FAA has recently granted relief from Section 91.121 specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 

11998, 12426, 12468, & 12220).

6.Reasons Why An Exemption From The Requirements Of Section 91.151(b) 

Would Not Adversely Affect Safety

A grant of this exemption would ensure an equivalent level of safety established by 14 

C.F.R. Section 91.151(b) as a result of (1) the technical specifications of theDJI Phantom 2 

Vision+ and DJI Phantom 3 Professional UASs; (2) the limitations on the proposed flight

operations; and (3) the location of the proposed flight operations. Accordingly, Price Edwards

& Company will ensure safe operations of the battery powered DJI Phantom2 Vision+ and 

DJI Phantom 3 Professional UA during daylight hours in VFR conditions, withenough battery 

power to fly for a total duration of 14 minutes to the first point of intended landing and, 

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

Furthermore, safety will be ensured as the DJI Phantom2 Vision+ and DJI Phantom 3 

Professional UASs provide audible and visual warnings to the PIC atthe GCS when the UA

experiences low battery voltage, the first warning occurringat approximately 33% remaining 

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

battery level, the DJI Phantom Vision+ and DJIPhantom 3 Professional UASs will descend 
32

and land automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151 

establish that safety is not adversely affected when the technical characteristicsand operating 

limitations of the UAS are considered. Moreover, the FAA has recently granted relief from 

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

presented herein (e.g. Exemption Nos. 11998, 12426, 12468, & 12220).

7.Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not 

Adversely Affect Safety

In seeking this exemption, Price Edwards & Company submits that, given the

technical characteristics and operating limitations of the DJI Phantom 2 Vision+ and DJI 

Phantom 3 Professional UASs, the equivalent level of safety with regard to the regulatory 

maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) &(b) will be met because Price Edwards & Company

will use trained technicians to perform maintenance, alterations, or preventive maintenance 

on the UASs using themethods, techniques, and practices prescribed in the operating 

documents (i.e., theMonthly Maintenance Logs, and DJI Phantom 2 Vision+ and DJI 

Phantom 3 Professional Instruction Manuals). Furthermore, Price Edwards & Company will 

document and maintain all maintenance records for the DJI Phantom 2 Vision+ and DJI 

Phantom 3 Professional UASs to ensure quality of repairs and allow for detailed review of 

such repairs.

Since the DJI Phantom 2 Vision+ and DJI Phantom 3 professional UASs will be 

inspected as prescribed by the operating documents, Price Edwards & Company will maintain

the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 
33

91.409(a)(2). A copy of the DJI Phantom 2 Vision+ and DJI Phantom 3 Professional User

Manuals are attached hereto as Exhibit A and B and a copy of the DJI Phantom 2 Vision+ 

and DJI Phantom 3 Professional UAS Maintenance Log form is attached hereto as Exhibit C.

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

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

Phantom 2 Vision+ and DJI Phantom 3 Professional UASs will be performed by trained

technicians. Maintenance will be documented and maintained utilizing the monthly 

maintenancelog.

In consideration of Price Edwards & Company’s proposed operating limitations, the 

operating documents, and the technical aspects of the DJI Phantom 2 Vision+ andDJI 

Phantom 3 Professional UASs, Price Edwards & Company submits that safety will not be 

adverselyaffected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and

(a)(2), 91.409(a)(2), and 91.417(a) and (b). 

The FAA has recently granted identical relief specific to UAS in circumstances 

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11998, 12426, 

12468, & 12220).

8.The FAA May Prescribe Any Other Conditions For SafeOperation

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Price Edwards & Company

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

Phantom 2 Vision+ and DJI Phantom 3 Professional UASs, which contain such safety 

standards thatthe Administrator finds necessary to establish a level of safety equivalent to that

established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 61.101(e)(4) & 
34

(e)(5), 61.315(a), 91.7 (a), 91.119(c), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1)

& (a)(2), and 91.417(a) & (b). Price Edwards & Company request any such special conditions 

to permit safe operation of the UA for the limited purpose of conducting aerial video and 

photography over certain areas of the United Statesfor compensation or hire. FMRA Section

333 sets forth the requirements for considering whether a UAS will create a hazard to users of

the NAS or the public, or otherwise pose a threat to national security; and further, provides the

authority for such UAS to operate without airworthiness certification in accordance with any

requirements that must be established for the safe operation of the UAS in the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R.

§ 21.16, for operation of the DJI Phantom 2 Vision+ and DJI Phantom 3 Professional UASs,

since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate

safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, 

entitled Special Conditions, states thefollowing:

If the FAA finds that the airworthiness regulations of this subchapter do not contain 

adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller

because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, 

he prescribes special conditions and amendments thereto for the product. The special 

conditions are issued in accordance with Part 11 of this chapter and contain such safety 

standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to 

establish a level of safety equivalent to that established in the regulations.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may 

prescribe special conditions for Price Edwards & Company’s intended operation of the DJI 

Phantom 2 Vision+ and DJI Phantom 3 Professional UASs, which contain such safety 

standards thatthe Administrator finds necessary to establish a level of safety equivalent to that

established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b),

61.101(e)(4) & (e)(5), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(b), 91.405(a),
35

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

F. A Summary That Can Be Published In The Federal Register Stating The Rules 

From Which Price Edwards & Company Seeks Exemption and a Brief Description 

Of The Nature Of The Exemption Price Edwards & Company Seeks.

Price Edwards & Company seeks exemption from the requirements of 14 C.F.R 

Sections 61.113(a)&(b), 61.101(e)(4) & (e)(5), 61.315(a), 91.7(a), 91.119(c), 91.121,

91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

Such exemption will permit Price Edwards & Company to commercially operate an 

Unmanned Aircraft System in the National Air Space for the purpose of conducting 

aerial video and photography over certain areas of the United States.

G. Any Additional Information, Views, Or Arguments Available ToSupport 

Price Edwards & Company’s Requests

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain 

UAS may operate safely in the NAS. As such, Price Edwards & Company’s request for 

exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 

11, as set forth above.

FMRA Section 333 sets forth the requirements for considering whether a UAS will 

create a hazard to users of the NAS or the public, or otherwise pose a threat to national 

security; and further, provides the authority for such UAS to operate without airworthiness

certification.

As discussed in detail above, Priced Edwards & Company will operate the DJI

Phantom 2 Vision+ and DJI Phantom 3 Professional UASs safely in the NAS, without creating

a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.

CONCLUSION

As set forth herein, Price Edwards & Company seeks an exemption pursuant to 14

C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), 
36

which will permit safe operation of the DJI Phantom 2 Vision+ and 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 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 Price Edwards & Company to safely, efficiently, and economically operate

the DJI Phantom 2 Vision+ and DJI Phantom 3 Professional UASs commercially within the

NAS.

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

Modernization and Reform Act of 2012, Section 333, Price Edwards & Company respectfully 

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

14 C.F.R Sections 61.113(a) & (b), 61.101(e)(4) & (e)(5), 61.315(a), 91.7(a), 91.119(c), 

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 Price Edwards & Company to operate the DJI Phantom 2 Vision+ and DJI Phantom 3 

Professional UASs commercially for the purpose ofconducting aerial video and photography 

over certain areas of the United States.

Dated: September 24, 2015
37

Respectfully submitted, 

Price Edwards & Company

Phillip Jackson

Price Edwards & Company

210 Park Ave., Suite 1000

Oklahoma City, OK 73102

(405) 236-1849

pjackson@priceedwards.com
38

Appendices:

A – DJI Phantom 2 Vision+ Manufacturer’s User Manual

B – DJI Phantom 3 Professional Manufacturer’s UserManual

C – Monthly Maintenance Log Form

Price Edwards & Company only utilizes safe and reliable UAS. DJI is an industry leaderin 

small UAS production. DJI UASs are loaded with ground breaking software enabling the user

to set parameters which will not allow flight into controlled airspace. Parameters can also be set 

to limit flight to no higher than a predetermined and set altitude as well as limit flight to a 

predetermined and set distance. In addition, DJI software provides real-time altitude and 

location information to the PIC via the linked monitor (smart phone/tablet devices)
39

APPENDIX – A

DJI Phantom 2 Vision+ Manufacturer’s User Manual

http://download.djiinnovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Plus_User_Manual

_v1.8_en.pdf
40

APPENDIX – B

DJI Phantom 3 Professional Manufacturer’s User Manual

http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.4_en.pdf
41

APPENDIX – C

Monthly Maintenance Log Month: ________ Year: _______

UAS: 

Date Issue 

Discovered

Date Issue 

Resolved

Issue Description & Maintenance 

Conducted

Maintenance 

Performed By 

(Print, Sign, and 

Date)

Software 

Updates

Airframe

Engines

Propellers

Camera & Gimbal

Vibration System

Other