UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL 

AVIATION ADMINISTRATION WASHINGTON, DC 

Regulatory Docket No. 

IN THE MATTER OF THE PETITION FOR EXEMPTIONOF: 

Jeffrey L. Taliaferro Photography 

FOR AN EXEMPTION SEEKING RELIEF FROMTHE REQUIREMENTS OF TITLE 14 

OF THE CODE OF FEDERAL REGULATIONS 

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

(a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF DJI 

PHANTOM 2 VISION+, DJI PHANTOM 3 PROFESSIONAL AND DJI INSPIRE 1 

UNMANNED AIRCRAFT SYSTEMS 

PURSUANT TO SECTION 333 OF 

THE FAAMODERNIZATION AND REFORMACT OF 2012 (PUBLIC LAW 112-95) 

Submitted on June 22th, 2015 

Jeffrey L. Taliaferro

Jeffrey L. Taliaferro Photography 15906 Cotton Gin Ave

Wayne, OK 73095

Tel: (405) 628-9535
TABLE OFCONTENTS 

Page GLOSSARY OF ABBREVIATIONS. .................................................................................3 

SUMMARY. .........................................................................................................................4 

INTRODUCTION AND INTERESTS OF PETITIONER....................................................4 

BACKGROUND....................................................................................................................4 

BASIS FOR PETITION........................................................................................................ 5 

NAME AND ADDRESS OF PETITIONER............................................................ 7 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH JEFFREY L. TALIAFERRO 

PHOTOGRAPHY SEEKS EXEMPTION................................................................ 8 

THE EXTENT OF RELIEF JEFFREY L. TALIAFERRO PHOTOGRAPHY SEEKS AND THE 

REASON JEFFREY L. TALIAFERRO PHOTOGRAPHY SEEKS THE RELIEF.............. 

.................................................................................................. 11 

THE REASONS WHY GRANTING JEFFREY L. TALIAFERRO PHOTOGRAPHY REQUEST 

WOULD BE IN THE PUBLIC INTEREST ..................................... 15 

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT 

SAFETY......................................................................... 19 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERALREGISTER. .... 34

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT 

JEFFREY L. TALIAFERRO PHOTOGRAPHY REQUEST... 

.................................................................................................................................34 

CONCLUSION................................................................................................................... 35 

APPENDICES........................................................................................37 

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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) Section 333 SO Safety Observer 

SOP Standard Operating Procedures 

UA Unmanned Aircraft 

UAS Unmanned Aircraft System 

VFR Visual Flight Rules 

VLOS Visual Line of Site 

VMC Visual Meteorological Conditions 

VTOL Vertical Takeoff and Landing 

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SUMMARY 

Jeffrey L. Taliaferro Photography seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) 

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

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

Modernization and Reform Act of 2012 (FMRA). This exemption will permit Jeffrey L. Taliaferro 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 

Jeffrey L. Taliaferro provides its clients with expertise and knowledge in the fields of photography 

and videography. Jeffrey L. Taliaferro As well as to provide search and rescue services as required 

with local emergency management and to increase the public’s knowledge of UAS and promote safe 

UAS operations. 

Unmanned Aircraft Systems: DJI Phantom 2 Vision+, DJI Phantom 3 

Professional DJI Inspire 1 UASs 

Jeffrey L. Taliaferro seeks an exemption to operate DJI systems for compensation or hire within the 

NAS. The DJI Phantom 2 Vision+, DJI Phantom 3 Professional and DJI Inspire 1 are vertical takeoff 

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

electronic tablet or smart phone 

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systems. The DJI Phantom 2 Vision+ has a maximum gross weight of approximately 2 pounds 11 

ounces, while having a length of 16 inches width of 16 inches, height of 8 inches, and a maximum 

speed of approximately 29 knots. The DJI Phantom 3 Professional has a maximum gross weight of 2 

pounds 11 ounces, while having a length of 16 inches width and of 16 inches, height of 8 inches and 

a maximum speed of approximately 31 knots. The DJI Inspire 1 has a maximum gross weight of 6 

pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a 

maximum speed of approximately 42 knots. The DJI Phantom 2 Vision+, DJI Phantom 3 

Professional and DJI Inspire 1UAs are equipped with four main rotors; driven by Lithium Polymer 

battery powered electric motors. 

The DJI Phantom 2 Vision+, DJI Phantom 3 Professional and DJI Inspire 1 UAs that will be operated 

by Jeffrey L. Taliaferro will be registered in accordance with 49 U.S.C. 44103, Registration of 

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

Part 45, Identification and Registration Marking. 

BASIS FOR PETITION 

Petitioner, Jeffrey L. Taliaferro, pursuant to the provisions of the Federal Aviation Regulations (14 

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

Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially 

operate the DJI Phantom 2 Vision+, DJI Phantom 3 Professional and DJI Inspire 1 UASs in the 

National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 

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

91.417(a) & (b). 

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

aircraft and its operation, Jeffrey L. Taliaferro Photography operation of DJI 

5	
Phantom 2 Vision+, DJI Phantom 3 Professional and DJI Inspire 1 UASs meets 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, Jeffrey L. Taliaferro Photography 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. 

Jeffrey L. Taliaferro Photography submits that the requested relief is proper since an equivalent level 

of safety will be ensured. Jeffrey L. Taliaferro Photography 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 Jeffrey L. 

Taliaferro Photography Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 

Vision+, DJI Phantom 3 Professional and DJI Inspire 1 Instruction Manual). Furthermore, Jeffrey L. 

Taliaferro Photography will document and maintain all maintenance records for the DJI Phantom 2 

Vision+, DJI Phantom 3 Professional and DJI Inspire 1 UASs. 

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

limitations: Pilot in command, is requested by Jeffrey L. Taliaferro Photography to the extent 

necessary to allow a Pilot in Command (PIC) holding a private pilot 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+, DJI 

Phantom 3 Professional and DJI Inspire 1 UASs in a manner consistent with this exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures. 

Jeffrey L. Taliaferro Photography seeks relief from Section 91.7(a), entitled Civil aircraft 

6	
airworthiness, because the DJI Phantom 2 Vision+, DJI Phantom 3 Professional and DJI Inspire 1 

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

such, Jeffrey L. Taliaferro Photography submits that it will ensure that the DJI Phantom 2 Vision+, 

DJI Phantom 3 Professional and DJI Inspire 1UASs are in an airworthy condition, prior to every 

flight, by determining that the UASs are in compliance with the operating documents (i.e., the Jeffrey

L. Taliaferro Photography Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 

Vision+, DJI Phantom 3 Professional and DJI Inspire 1 Instruction Manual), and that the aircraft are 

in a condition for safe flight. 

Jeffrey L. Taliaferro Photography also seeks an exemption from the requirements of Section 91.121, 

entitled Altimeter Settings, as the DJI Phantom 2 Vision+, DJI Phantom 3 Professional and DJI 

Inspire 1UAs will not have a typical barometric altimeter onboard. However, altitude information of 

the DJI Phantom 2 Vision+, DJI Phantom 3 Professional and DJI Inspire 1UAs will be provided to 

the PIC via 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 Jeffrey L. Taliaferro Photography operation of the DJI Phantom 2 Vision+, 

DJI Phantom 3 Professional and DJI Inspire 1 UASs within visual line of sight, at or below 150 feet 

AGL, will ensure a level of safety equivalent to Section91.121. 

Additionally, Jeffrey L. Taliaferro Photography seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. Jeffrey L. Taliaferro Photography 

submits that safety will not be affected by operation of the DJI Phantom2 Vision+, DJI Phantom 3 

Professional and DJI Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC) 

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

7	
duration of approximately 13.5 minutes to the first point of intended landing and, assuming normal 

cruising speed, to fly after that for at least 4.5 minutes. In accordance with 14 C.F.R. § 11.81, Jeffrey

L. Taliaferro Photography 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: 

Jeffrey L. Taliaferro

Jeffrey L. Taliaferro Photography 15906 Cotton Gin Ave . 

Wayne, OK 73095

Tel: (405) 628-9535

Email: jtaliaferro1@gmail.com

B. The Specific Sections Of 14 C.F.R. From Which Jeffrey L. Taliaferro Photography Seeks 

Exemption. 

1. Jeffrey L. Taliaferro Photography Seeks Exemption From The Requirements Of Section 

61.113(a) And (b). 

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections (a) 

and (b) prescribe the following, in relevant part: 

(a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft 

that is carrying passengers or property for compensation or hire; nor may that person, for 

compensation or hire, act as PIC of an aircraft. 

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any 

business or employment if—

(1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire. 

2. Jeffrey L. Taliaferro Photography Seeks Exemption From The Requirements Of Section 

91.7(a). 

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

8	
(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

3. Jeffrey L. Taliaferro Photography 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 is set, when operating--

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

(i) The current reported altimeter setting of a station along the route and within 100 nautical miles of 

the aircraft; 

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

reported altimeter setting of an appropriate available station; or 

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

appropriate altimeter setting available before departure. 

4. Jeffrey L. Taliaferro Photography Seeks Exemption From The Requirements Of Section 

91.151(b). 

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states the 

following: 

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

(considering wind and forecast weather conditions) there is enough fuel to fly to the first point of 

intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes. 

5. Jeffrey L. Taliaferro Photography 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 between required 

inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as 

prescribed in part 43 of this chapter[.] 

9	
6. Jeffrey L. Taliaferro Photography Seeks Exemption From The Requirements Of Section 

91.407(a)(1) 

Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or 

alteration, subsection (a)(1), states the following: 

(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, 

rebuilding, or alteration unless--

(1) It has been approved for return to service by a person authorized under § 

43.7 of this chapter[.] 

7. Jeffrey L. Taliaferro Photography Seeks Exemption From The Requirements Of Sections 

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

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

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

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

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

to service by a person authorized by § 43.7 of this chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this 

chapter. 

8. Jeffrey L. Taliaferro Photography 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 

10	
(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 which the aircraft and its appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and safety directives including, for 

each, the method of compliance, the AD or safety directive number and revision date. If the AD or 

safety directive involves recurring action, the time and date when the next action is required. 

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the 

airframe and currently installed engines, rotors, propellers, and appliances. 

(b) The owner or operator shall retain the following records for the periods prescribed: 

(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 Jeffrey L. Taliaferro Photography Seeks And The Reason Jeffrey L. 

Taliaferro Photography Seeks The Relief. 

1. Extent Of Relief Jeffrey L. Taliaferro Photography Seeks And The Reason Jeffrey L. 

Taliaferro Photography Seeks Relief From Section 61.113(a) And (b). 

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in 

command, is requested to the extent necessary to allow a PIC holding a private pilot or higher level 

certificate, as well as a current and valid airman medical certificate, and who has met certain flighthour and currency requirements, to conduct the proposed UAS flight operations for compensation or 

hire. 

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

As set forth more fully below, Jeffrey L. Taliaferro Photography submits that an equivalent level of 

safety will be maintained because no PIC will be allowed to operate the DJI Phantom 2 Vision+ 

UAS, DJI Phantom 3 Professional UAS or DJI Inspire 1 UAS unless that PIC has met certain flighthour and currency requirements, demonstrating that the PIC is able to safely operate either the DJI 

Phantom 2 Vision+, DJI Phantom 3 Professional or DJI Inspire 1 UAS in a manner consistent with 

the operations specifications as described in this exemption, including evasive and emergency

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

structures. 

Further, Jeffrey L. Taliaferro Photography submits that all flights of the DJI Phantom 2 Vision+, DJI 

Phantom 3 Professional and DJI Inspire 1 UASs, conducted by the PIC pursuant to the grant of this 

12	
Petition: (1) will be incidental to Jeffrey L. Taliaferro Photography’s business; and (2) will not carry 

passengers or property for compensation or hire. 

2. Extent Of Relief Jeffrey L. Taliaferro Photography Seeks And The Reason Jeffrey L. 

Taliaferro Photography 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 Jeffrey L. Taliaferro Photography to determine that the DJI Phantom2 Vision+, DJI Phantom 3 

Professional and DJI Inspire 1 UASs are in airworthy condition prior to every flight by ensuring that 

the UAS is in compliance with the operating documents (i.e., the Jeffrey L. Taliaferro Photography 

Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+, DJI Phantom 3 

Professional and DJI Inspire 1 Instruction Manual). 

Jeffrey L. Taliaferro Photography seeks the requested relief because the DJI Phantom2 Vision+, DJI 

Phantom 3 Professional and DJI Inspire 1 UASs do not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Jeffrey L. Taliaferro Photography will 

ensure that the DJI Phantom 2 Vision+, DJI Phantom 3 Professional and DJI Inspire 1 UASs are in 

airworthy condition based upon its compliance with the operating documents (i.e., the Jeffrey L. 

Taliaferro Photography Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 

Vision+, DJI Phantom 3 Professional and DJI Inspire 1 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 Jeffrey L. Taliaferro Photography Seeks And The Reason Jeffrey L. 

Taliaferro Photography Seeks Relief From Section 91.121. 

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of 

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

13	
Inspire 1 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), Jeffrey L. 

Taliaferro Photography seeks the requested relief because the DJI Phantom 2 Vision+, DJI Phantom 

3 Professional and DJI Inspire 1 UA’s altimeter may be set on the ground to zero feet AGL, rather 

than the local barometric pressure or field altitude, before each flight. 

Considering the limited altitude of the proposed operations, relief from 14 CFR 

91.121 is sought to the extent necessary to comply with the applicable conditions and limitations 

stated below. As more fully set forth herein, an equivalent level of safety will 

be maintained since the DJI Phantom 2 Vision+, DJI Phantom 3 Professional and DJI Inspire 1 UAs 

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 the GCS. 

4. Extent Of Relief Jeffrey L. Taliaferro Photography Seeks And The Reason Jeffrey L. 

Taliaferro Photography 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+, DJI Phantom 3 

Professional and DJI Inspire 1 UAs during daylight hours in visual meteorological conditions 

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

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

Jeffrey L. Taliaferro Photography seeks the requested relief because without an exemption from 

Section 91.151(b), the flight time 

14	
duration of the battery powered DJI Phantom 2 Vision+, DJI Phantom 3 Professional and DJI Inspire 

1 UAs will severely constrain the practicality of any aerial video or still photo flight operations that 

Jeffrey L. Taliaferro Photography proposes to conduct pursuant to this Petition.

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

Phantom 3 Professional and DJI Inspire 1 UASs, the DJI Phantom 2 Vision+, DJI Phantom 3 

Professional and DJI Inspire 1operating documents, and Jeffrey L. Taliaferro Photography’s 

proposed operating limitations, ensure that Jeffrey L. Taliaferro Photography will safely operate the 

battery powered DJI Phantom 2Vision+, DJI Phantom 3 Professional and DJI Inspire 1 UAs during 

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

enough battery power to fly for a total duration of 

13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after 

that for at least 4.5 minutes. 

5. Extent Of Relief Jeffrey L. Taliaferro Photography Seeks And The Reason Jeffrey L. 

Taliaferro Photography 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, Jeffrey L. Taliaferro Photography requests relief from these 

Sections because the DJI Phantom 2 Vision+, DJI Phantom 3 Professional and DJI Inspire 1 UASs 

do not require airworthiness certificates. As set forth more fully below, the DJI Phantom 2 Vision+, 

DJI Phantom 3 Professional and DJI Inspire 1 UASs meet the conditions of FMRA Section 333 for 

operation without an airworthiness certificate. Accordingly, Jeffrey L. Taliaferro Photography will 

use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs 

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

Jeffrey L. Taliaferro

15	
Photography Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+, DJI 

Phantom 3 Professional and DJI Inspire 1 Instruction Manual). Furthermore, Jeffrey L. Taliaferro 

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

DJI Phantom 3 Professional and DJI Inspire 1 UASs. 

D.The Reasons Why Granting Jeffrey L. Taliaferro Photography’s Request Would Be In The 

Public Interest; That Is, How It Would Benefit The Public As A Whole. 

Granting the present Petition will further the public interest by allowing Jeffrey L. Taliaferro 

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

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

Additionally, use of the DJI Phantom 2 Vision+, DJI Phantom 3 Professional and DJI Inspire 1 UASs 

will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the 

economy. Notably, the benefits of Jeffrey L. Taliaferro Photography’s proposed operation of the DJI 

Phantom 2 Vision+, DJI Phantom 3 Professional and DJI Inspire 1 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+, DJI Phantom 3 Professional and DJI Inspire 1 UAs are battery powered 

and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized 

to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial 

acquisitions, an exemption allowing the use of a DJI Phantom 2 Vision+, DJI Phantom 3 

Professional or DJI Inspire 1 UAS would reduce the amount of manned aircraft in the NAS, reduce 

noise and air pollution, as well as increase the safety of life and property in the air and on the ground. 

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around 

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

16	
DJI Phantom 2 Vision+, DJI Phantom 3 Professional and DJI Inspire 1 UAs do not require an airport 

to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography 

missions would result in fewer aircraft that must be handled by air traffic control during the ground, 

takeoff, departure, arrival, and landing phases of flight operations. 

2. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 2 Vision+, 

DJI Phantom 3 Professional and DJI Inspire 1 UASs. 

Conducting aerial acquisitions with the DJI Phantom 2 Vision+, DJI Phantom 3 Professional and DJI 

Inspire 1 UASs, instead of manned aircraft, will greatly benefit the public by drastically reducing the 

levels of air and noise pollution generated during traditional aerial video and still photography flight 

operations. By using battery power and electric motors, the DJI Phantom 2 Vision+, DJI Phantom 3 

Professional and DJI Inspire 1 UASs produce no air pollution, and are the most 

Viable environmentally conscious alternative to the cabin class, six cylinder internal combustion 

engine aircraft that are typically utilized for aerial video and photography, while burning 

approximately 20-30 gallons per hour of leaded aviation fuel. The DJI Phantom 2 Vision+, DJI 

Phantom 3 Professional and DJI Inspire 1 UAs, while reducing the carbon footprint of aerial 

acquisitions, also eliminates noise pollution, as the UAs are propelled by battery powered electric 

motors, rather than an internal combustion engine. 

By using the DJI Phantom 2 Vision+, DJI Phantom 3 Professional and DJI Inspire 1 UASs to 

perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, 

which is usually associated with traditional manned aircraft flight operations, will be substantially 

reduced or completely eliminated. Aside from the lack of flight crew members located onboard the 

aircraft, the DJI Phantom 2 Vision+, DJI 

17	
Phantom 3 Professional and DJI Inspire 1 UAs (weighing approximately 2 pounds 11 ounces and 6 

pounds 7.5 ounces respectively, at their maximum gross weights with lengths of 16 inches and 17.3 

inches respectively, widths of 16 inches and 17.7 inches respectively, and with no fuel on board), has 

less physical potential for collateral damage to life and property on the ground, and in the air, 

compared to the manned aircraft that typically conduct similar operations (weighing approximately 

6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and afuel capacity of 180 

gallons). 

3. Performing Aerial Video and Photography Operations With The DJI Phantom 2 Vision+, 

DJI Phantom 3 Professional and DJI Inspire 1 UASs Will Benefit The Economy. 

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

DJI Inspire 1 UASs are also an economical alternative to using manned aircraft to conduct similar 

aerial operations. As such, operation of the DJI Phantom 2 Vision+, DJI Phantom 3 Professional and 

DJI Inspire1 UASs will allow United States based companies, like Jeffrey L. Taliaferro Photography, 

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

cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing 

out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative 

technology in order to remain competitive. Operating the battery powered DJI Phantom 2 Vision+, 

DJI Phantom 3 Professional and DJI Inspire 1 UASs is one such technology that not only allows 

companies greater operational flexibility compared to manned aircraft, but provides such flexibility 

without the high operational cost of a traditional manned aircraft. 

By operating the DJI Phantom 2 Vision+, DJI Phantom 3 Professional and DJI Inspire 1 UASs, 

companies such as Jeffrey L. Taliaferro Photography, can remain competitive and profitable, and 

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

18	
will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. 

companies, through commercial use of the DJI Phantom 2 Vision+, DJI Phantom 3 Professional and 

DJI Inspire 1 UASs, provides a stable workforce that increases consumer spending; improves local, 

state, and federal tax revenues; and allows companies to invest in research and development in order 

to remain competitive both in the United States and abroad.

4. There Are No Privacy Issues. 

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

Jeffrey L. Taliaferro Photography’s proposed operation of the DJI Phantom 2 Vision+, DJI Phantom 

3 Professional and DJI Inspire 1 UASs will not implicate any privacy issues. Specifically, the DJI 

Phantom 2 Vision+, DJI Phantom 3 Professional and DJI Inspire 1 UASs will be operated only in 

compliance with operating documents (i.e., the Jeffrey L. Taliaferro Photography Aerial Operations 

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

DJI Inspire 1 Instruction Manual) which requires property owner involvement as well as local law 

enforcement notification, and in accordance with the Federal Aviation Regulations, including the 

minimum altitude requirements of 14 C.F.R. § 91.119. 

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 

Rule From Which Jeffrey L. Taliaferro Seeks Exemption. 

1. Reasons Why The DJI Phantom 2 Vision+, Phantom 3 Professional and DJI Inspire 1 UAs 

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 its operation, Jeffrey L. Taliaferro Photography’s operation of the DJI Phantom 2 

Vision+, DJI Phantom 3 Professional and DJI Inspire 1 UASs meet the conditions of FMRA Section 

333, and will not require an airworthiness certificate in 

19	
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 Secretary of 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 determination under 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 

(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 under this 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, Jeffrey L. Taliaferro Photography submits that the DJI Phantom 2 

Vision+, DJI Phantom 3 Professional and DJI Inspire 1 UASs can operate safely in the NAS pursuant 

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

Phantom 3 Professional and DJI Inspire 1 UASs; (b) the pilot certification requirement; and (c) the 

specific operating limitations. 

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

Inspire 1 UASs Demonstrate Its Safe Characteristics. 

20	
The DJI Phantom 2 Vision+, DJI Phantom 3 Professional and DJI Inspire 1 UASs do not create a 

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

its size, weight, speed, and operational capability. 

i. Technical Specifications Of The DJI Phantom 2 Vision+, DJI Phantom 3 Professional and 

DJI Inspire 1 UASs. 

The technical specifications of the DJI Phantom 2 Vision+, DJI Phantom 3 Professional and DJI 

Inspire 1UASs are set forth by the , DJI Phantom 3 Professional and DJI Inspire 1 Specifications and

Data Sheet, attached hereto as Exhibit A, B and C. 

ii. The DJI Phantom 2 Vision+, DJI Phantom 3 Professional and DJI Inspire 1 UASs

Autonomous Flight And Navigation Modes Enable The UASs To Remain Within A Defined 

Operational Area. 

The DJI Phantom 2 Vision+, DJI Phantom 3 Professional and DJI Inspire 1 UASs may be operated in 

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

navigational modes of the DJI Phantom 2 Vision+, DJI Phantom 3 Professional and DJI Inspire 1 

UASs is provided at pages 25-35 of the DJI Phantom 2 Vision+, pages 11-17 of the DJI Phantom 3 

Professional and pages 12-16 and 45-50 of the DJI Inspire 1 User Manuals, attached hereto as 

Exhibit D, E and F. 

iii. The DJI Phantom 2 Vision+, DJI Phantom 3 Professional and DJI Inspire 1 UASs Are 

Designed For Automatic Return To Home Point Or Hover In The Event Of Loss Of The 

Control Link Or Navigation. 

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

Inspire 1 UAs will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI 

Phantom 2 Vision+, DJI Phantom 3 Professional and DJI Inspire 1 UAs do not reacquire control link 

data from the GCS, the UAS will assume that the Control Link is lost and the UAs will return to the 

home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown. 

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

21	
UAS are set forth at pages 27 through 29, for the DJI Phantom 3 Professional UAS are set forth at 

pages 12 through 14 for the DJI Inspire 1 at pages 13 through15 of the DJI Phantom 2 Vision+, DJI 

Phantom 3 Professional and DJI Inspire 1 User Manuals, attached hereto as Exhibit D, E and F. 

iv. The DJI Phantom 2 Vision+, DJI Phantom 3 Professional and DJI Inspire 1 GCS And Its 

Operation. 

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

Inspire 1 GCS and flight control software is provided at pages 32through 43 of the DJI Phantom 2 

Vision+ User Manual, pages 40 through 55 of the DJI Phantom 3 Professional and pages 40 through 

47 of the DJI Inspire 1 User Manual. DJI Phantom 2 Vision+, DJI Phantom 3 Professional and DJI 

Inspire 1 User Manuals are attached hereto as Exhibits D, E and F. 

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

1UASs Are Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety 

Observer. 

Jeffrey L. Taliaferro Photography will only utilize certificated pilots who possess a current and valid 

airman medical certificate to act as a pilot in command (PIC) of the DJI Phantom 2 Vision+, DJI 

Phantom 3 Professional and DJI Inspire 1 UASs. Additionally, a safety observer will assist all pilots 

during flight time. 

c. Flights Of DJI Phantom 2 Vision+, DJI Phantom 3 Professional and DJI Inspire 1 UASs Will 

Be Conducted Pursuant To Specific Operating Limitations. 

In seeking this exemption, Jeffrey L. Taliaferro Photography proposes to commercially operate DJI 

Phantom 2 Vision+, DJI Phantom 3 Professional and DJI Inspire 1 UASs for the special purpose of 

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

following specific operating limitations: 

1. Operations authorized by this grant of exemption will be limited to the following aircraft described 

in the operating documents, rotorcraft UASs weighing less 

22	
than 55 pounds maximum gross weight: DJI Phantom 2 Vision+, DJI Phantom 3 Professional and DJI

Inspire 1 Unmanned Aircraft Systems. Proposed operations of any other aircraft twill require a new 

petition or a petition to amend this grant. 

2. UAS operations under this exemption will be limited to conducting operations for the purpose of 

aerial video and photography. 

3. The UAs may not be flown at an indicated airspeed exceeding 20 knots. 

4. The UA must be operated at an altitude of no more than 500 feet above ground level (AGL), as 

indicated by the procedures specified in the operating documents unless a special request is made and 

approved by ATC. All altitudes reported to ATC must be 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. The use of first person view (FPV) by the PIC or safety observer (SO) isnot permitted. 

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS 

requirement as long as the PIC always maintains VLOS capability. The SO 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 SO can perform the 

functions prescribed in the operating documents. 

8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other 

air traffic and other ground based obstacles/obstructions and is not permitted to operate the camera or 

other instruments. 

9. The operating documents and the grant of exemption must be accessible during UAS operations 

and made available to the Administrator upon request. Ifa 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 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. 

23	
10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. 

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. 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. 

The PIC who conducts the functional test flight must make an entry in the aircraft records. 

12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable 

components, items, or equipment, not already covered in the relevant sections of the operating 

documents. 

13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, 

replacement, inspection, and life limit requirements. 

14. 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. 

15. Each UASs operated under this exemption must comply with all manufacturer Safety Bulletins. 

16. The authorized person must make an entry in the aircraft record of the corrective action taken 

against discrepancies discovered between inspections. 

17. The PIC must possess at least a private pilot certificate and at least a current third- class medical 

certificate. 

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s 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 are permitted under the terms of 

the 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 C.F.R. § 91.119. 

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

24	
19.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at 

night is required, a special request will be made at the FAA office closest to proposed area of 

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

20. The UA may not operate within 5 nautical miles of an airport reference point as denoted on a 

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

management is obtained, and the operation is conducted in accordance with a NOTAM as required 

by the operator’s COA. The letter of agreement with the airport management must be made available 

to the Administrator upon request. 

21. 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. 

22. If the UA loses communications or loses its GPS signal, it must return to a pre- determined 

location within the planned operating area and land or be recovered in accordance with the operating 

documents. 

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

with the operating documents. 

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

conditions) there is enough power to fly at normal cruising speed to the intended landing point and 

land the UA with 25% battery power remaining. 

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate ofWaiver or 

Authorization (COA) prior to conducting any operations under the grant of exemption. This COA 

will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in 

advance, but not less than 48 hours prior to the operation. All operations shall be conducted in 

accordance with airspace requirements in the ATO issued COA including class of airspace, altitude 

level and potential transponder requirements. 

26. All aircraft operated in accordance with the exemption must be identified by serial number, 

registered in accordance with 14 C.F.R. part 47, and have identification (N- Number) markings in 

accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable. 

27. Before conducting operations, the radio frequency spectrum used for operation and control of the 

UA must comply with the Federal Communications Commission (FCC) or other appropriate 

government oversight agency requirements. 

28. The documents required fewer than 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 UAS is operating. These documents must be made 

available to the Administrator or any law enforcement official upon request. 

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

activities at all times. 

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

31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons 

other than the PIC, SO, operator trainees or essential 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 and/or; 

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such 

vessels, vehicles or structures has granted permission 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, 

and; 

c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present an undue 

hazard to those persons per § 91.119(a). 

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

from the land owner/controller or authorized representative. Permission from land owner/controller 

or authorized representative will be obtained for each flight to be conducted. 

33. 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 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 Section 61.113(a) And (b) Would 

Not Adversely Affect Safety. 

Jeffrey L. Taliaferro Photography submits that the equivalent level of safety established by Section 

61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI Phantom 2 

Vision+, DJI Phantom 3 Professional and DJI Inspire 1 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+, DJI Phantom 3 Professional 

26	
or DJI Inspire 1 UAS in a manner consistent with the exemption, including evasive and emergency 

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

Considering Jeffrey L. Taliaferro Photography’s proposed area of operations, and the operating 

limitations set forth-above; the parallel nature of private pilot aeronautical knowledge requirements 

to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills 

necessary to safely operate the DJI Phantom 2Vision+, DJI Phantom 3 Professional or DJI Inspire 1 

UAS, Jeffrey L. Taliaferro Photography submits that the additional manned airmanship experience of 

a commercially certificated pilot would not correlate to the airmanship skills necessary for Jeffrey L. 

Taliaferro Photography’s specific proposed flight operations. 

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in 

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

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 

11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). 

Jeffrey L. Taliaferro Photography will not allow any PIC to operate the DJI Phantom2 Vision+, DJI 

Phantom 3 Professional or DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting 

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

DJI Inspire 1 UAS training and currency requirements, that the PIC is able to safely operate the DJI 

Phantom 2 Vision+, DJI Phantom 3 Professional or DJI Inspire 1 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 

27	
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). 

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was 

obtained in compliance with applicable regulations will ensure an equivalent level of safety during 

Jeffrey L. Taliaferro Photography’s proposed operations. The Administrator has held that prior 

documented flight experience that was obtained in compliance with applicable regulations would 

ensure safe operations, stating as follows: 

In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of 

motion picture filming (or similar operations), the PIC must have accumulated and logged, in a 

manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at 

least 10 hours logged as a UAS pilot with a multi-rotor UAS. Prior to operations under Exemption 

No. 11062, the PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot 

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

clarification, the FAA considers these minimum hour requirements to be inclusive rather than 

additive; i.e. 5 hours make and model time may be included in the 10 hours of multi-rotor time and 

the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour 

requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for 

currency purposes). The FAA finds that at a minimum, the flight-hour requirements in Exemption 

No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct 

the petitioner’s proposed operations. The FAA also finds that prior documented flight experience that 

was obtained in compliance with applicable regulations would satisfy this requirement. Training, 

proficiency, and experience-building flights can also be conducted under the grant of exemption to 

accomplish the required flight time. During training, proficiency, and 

experience-building flights the PIC is required to operate the UA with appropriate distances in 

accordance with 14 C.F.R 91.119. 

Exemption No. 11138 at page 15. 

Accordingly, Jeffrey L. Taliaferro Photography will ensure safe operations by not allowing any PIC 

to operate the DJI Phantom 2 Vision+, DJI Phantom 3 Professional or DJI Inspire 

28	
1 UAS 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+, DJI Phantom 3 

Professional or DJI Inspire 1 UAS in a manner consistent with the exemption, including evasive and 

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

structures. 

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, Jeffrey L. Taliaferro Photography will ensure that the DJI Phantom 2 Vision+, DJI 

Phantom 3 Professional or DJI Inspire 1 UAS is in an airworthy condition based upon the UAS’s 

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

Additionally, the FAA has previously 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. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

4. 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 be maintained because the altitude 

information of the DJI Phantom 2 Vision+, DJI Phantom 3 Professional and DJI Inspire 1 SUAs will 

be provided to the PIC via GPS equipment 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, combined with Jeffrey L. Taliaferro Photography’s operation of the DJI Phantom 2 

Vision+, DJI Phantom 3 Professional and DJI Inspire 1 UAs within visual line of sight, at or below

500 feet AGL, 

29	
will ensure a level of safety equivalent to Section 91.121. The altitude information will be generated 

by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is 

automatically established by the UASs at ground level. 

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

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

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

5. 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 the DJI Phantom 2 Vision+, DJI 

Phantom 3 Professional and DJI Inspire 1 UASs; (2) the limitations on the proposed flight 

operations; and (3) the location of the proposed flight operations. Accordingly, Jeffrey L. Taliaferro

Photography will ensure that it will safely operate the battery powered DJI Phantom2 Vision+, DJI 

Phantom 3 Professional and DJI Inspire 1 UAs during daylight hours in VFR conditions, with

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

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

Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom2 Vision+, DJI 

Phantom 3 Professional and DJI Inspire 1 UASs; the limitations on the proposed flight operations; 

and the location of the proposed operations, will ensure an equivalent level of safety established by 

14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Phantom2 Vision+, DJI 

Phantom 3 Professional and DJI Inspire 1 UASs provide audible and visual warnings to the PIC at 

the GCS when the UAs experiences low battery voltage, the first warning occurring at approximately 

33% 

30	
remaining battery power, and again at approximately 10% remaining battery power. At the critically 

low battery level, the DJI Phantom Vision+ and DJI Inspire 1 UASs will descend and land 

automatically. 

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that 

safety is not adversely affected when the technical characteristics and operating limitations of the 

UAS are considered. Relief has been granted for manned aircraft to operate at less than the 

minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. 

Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 

10808, 10673, 11042, 11062, 11063, 

11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 

11157, 11158, 11159, 11160, 11161). 

6. 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, Jeffrey L. Taliaferro Photography submits that 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 Jeffrey L. Taliaferro Photography will use trained 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 Jeffrey L. Taliaferro Photography Aerial Operations 

Manual, Monthly Maintenance Log, and DJI Phantom2 Vision+, DJI Phantom 3 Professional and 

DJI Inspire 1 Instruction Manual). Furthermore, Jeffrey L. Taliaferro Photography will document and 

maintain all maintenance records for the DJI Phantom 2 Vision+, DJI Phantom 3 Professional and 

DJI Inspire 1 UASs. 

31	
Since the DJI Phantom 2 Vision+, DJI Phantom 3 Professional and DJI Inspire 1 UASs will be 

inspected as prescribed by the operating documents, Jeffrey L. Taliaferro Photography will maintain 

the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A 

copy of the DJI Phantom 2 Vision+, DJI Phantom 3 Professional and DJI Inspire 1 User Manuals are 

attached hereto as Exhibit D, E and F; a copy of the DJI Phantom 2 Vision+, DJI Phantom 3 

Professional and DJI Inspire 1 UAS Maintenance LOG is attached hereto as Exhibit G. 

Likewise, the exemption sought will not adversely affect safety because Jeffrey L. Taliaferro 

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

maintenance on the UAS using the methods, techniques, and practices prescribed by the operating 

documents. 

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+, 

DJI Phantom 3 Professional and DJI Inspire 1 UASs will be performed by trained technicians. 

Maintenance will be documented and maintained utilizing the monthly maintenance log. 

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the 

technical characteristics and operating limitations of the UAS are considered. 

In consideration of Jeffrey L. Taliaferro Photography’s proposed operating limitations, the operating 

documents, and the technical aspects of the DJI Phantom 2 Vision+, DJI Phantom 3 Professional and

DJI Inspire 1 UASs, Jeffrey L. Taliaferro Photography submits that safety will not be adversely

affected by granting exemption from 14 C.F.R. Sections 

32	
91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously 

granted relief specific to UAS in circumstances similar, in all material respects, to those presented 

herein (e.g. 

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

7. The FAA May Prescribe Any Other Conditions For Safe Operation. 

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, Jeffrey L. Taliaferro Photography requests that the FAA 

prescribe special conditions for the intended operation of the DJI Phantom 2 Vision+, DJI Phantom 3 

Professional and DJI Inspire 1 UASs, which contain such safety standards that the 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), 91.7 (a), 91.121, 

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

special conditions will permit safe operation of the UAs for the limited purpose of conducting aerial 

video and photography over certain areas of the United States for 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+, DJI Phantom 3 Professional and DJI Inspire 1 

UASs, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain 

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adequate or appropriate safety standards, due to the novel or unusual design features of the aircraft. 

Section 21.16, entitled Special Conditions, states the following: 

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. 

See 14 C.F.R. § 21.16. 

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

special conditions for Jeffrey L. Taliaferro Photography’s intended operation of the DJI Phantom 2 

Vision+, DJI Phantom 3 Professional and DJI Inspire 1 UASs, which contain such safety standards 

that the 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), 91.7(a), 91.121, 91.151(b), 

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

F. A Summary That Can Be Published In The Federal Register, stating: The Rules From 

Which Jeffrey L. Taliaferro Photography Seeks Exemption: 

Jeffrey L. Taliaferro Photography seeks exemption from the requirements of 14 C.F.R Sections 

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

91.417(a) &(b). 

A Brief Description Of The Nature Of The Exemption Jeffrey L. Taliaferro Photography 

Seeks: 

This exemption will permit Jeffrey L. Taliaferro Photography to commercially operate an Unmanned 

Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain 

areas of the United States. 

G. Any Additional Information, Views, Or Arguments Available To Support Jeffrey L. 

Taliaferro Photography’s Request. 

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

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

operate safely in the NAS. As such, Jeffrey L. Taliaferro Photography’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 Jeffrey L. Taliaferro Photography will operate the DJI Phantom 2 

Vision+, DJI Phantom 3 Professional and DJI Inspire 1 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 Jeffrey L. Taliaferro Photography seeks an exemption pursuant to 14 

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

will permit safe operation of the DJI Phantom 2 Vision+, DJI Phantom 3 Professional and DJI 

Inspire 1 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 

Jeffrey L. Taliaferro Photography to safely, efficiently, and economically operate the DJI Phantom 2 

Vision+, DJI Phantom 3 Professional and DJI Inspire 1 UASs commercially within the NAS. 

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

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Modernization and Reform Act of 2012, Section 333, Jeffrey L. Taliaferro Photography respectfully

requests that the Administrator grant this Petition for an exemption from the requirements of 14 

C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), and 91.417(a) & (b), and permit Jeffrey L. Taliaferro to operate the DJI Phantom 2 Vision+, 

DJI Phantom 3 Professional and DJI Inspire 1 UASs commercially for the purpose of conducting 

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

Dated: May 29th, 2015 

Respectfully submitted, 

Jeffrey L. Taliaferro Photography 

Jeffrey L. Taliaferro 15906 Cotton Gin Ave 

Wayne, OK73095

(405) 628-9535