UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

Brent K Baker 

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

14 C.F.R ~~ 61.23(a). 61.101(34) 61.113(a) & (b). 61.315 (a). 91.7(a). 91.119 (c). 91.119 (c). 91.121. 91.151(b), 

91.405(a). 91.407(a)(l ). 91.409(a)(l) & (a)(2). and 91.417(a) & (b). CONCERNING COMMERCIAL 

OPERATION OF DJI PHANTOM 3VISION+ AND DJI INSPIRE 1 UNMANNED AIRCRAFT SYSTEMS 

PURSUANT TO SECTION 333 OF 

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

Submitted on June 2, 2015 / 

Brent K Baker 

4176 Maple St. 

Chino, CA. 91710 

909-703-0225 

the brent 1Sl@gmail.corn 

(PUBLIC LAW 112-95) 
of Contents 

GLOSSARY OF ABBREVIATIONS .................................................................................................................. 2 

SUMMARY ......................................................................................................................................................... 3 

INTRODUCTION AND INTERESTS OF THE PETITIONER .......................................................................... 3 

BACKGROUND .................................................................................................................................................. 3 

BASIS FOR PETITION ....................................................................................................................................... 3 

Name And Address Of The Petitioner .................................................................................................................. 5 

The Specific Sections Of 14 C.F.R. From Which Applicant Seeks Exemption .................................................... 5 

The Extent Of Relief Applicant Seeks And The Reason Applicant Seeks The Relief. ......................................... 7 

The Reasons Why Granting Applicant Request Would Be In The Public Interest; That Is, How It Would Benefit 

The Public As A Whole ........................................................................................................................................ 9 

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 Applicant Seeks 

Exemption .......................................................................................................................................................... 1 0 

CONCLUSION .................................................................................................................................................. 17 

l 
LOSSARY OF 

AGL 

AOI 

ATC 

ATO 

AV 

CFR 

COA 

FAA 

FAR 

GCS 

GPS 

LOL 

NAS 

NOT AM 

PIC 

Section 333 

so 

SOP 

UA 

UAS 

VFR 

VLOS 

VMC 

VTOL 

Above Ground Level 

Area of Interest 

Air Traffic Control 

Air Traffic Organization 

Aerial Vehicle 

Code ofFederal Regulations 

Certificate of Authorization 

Federal Aviation Administration 

Federal Aviation Regulation 

Ground Control Station 

Global Positioning System 

Loss ofLink 

National Airspace System 

Notice to Aim1an 

Pilot In Command 

FAA Modernization and Reform Act of 2012 

Safety Observer 

Standard Operating Procedures 

Umnanned Aircraft 

Unmanned Aircraft System 

Visual Flight Rules 

Visual Line of Site 

Visual Meteorological Conditions 

Vertical Takeoff and Landing 
M 

Brent K Baker (APPlicant) seeks exemption from the reauirements of 14 C.F.R ~~ 61.23(a). 61.101(34) 

61.113(a) & (b). 61.315 (a).91.7(a). 91.119 (c). 91.119 (c). 91.121. 91.151(b), 91.405(a), 91.407(a)(l). 

91.409(a)(l) & (a)(2). and 91.417(a) & (b). to operate an Unmanned Aircraft Svstem pursuant to Section 333 of 

the FAA Modernization and Refonn Act of2012 (FMRA). This exemption will permit APPlicant to operate an 

Unmanned Aircraft Svstem (UAS) for the commercial puroose of conducting aerial video and photography of 

to be used in television commercials, weather traffic and news reports, and sporting events over certain areas of 

the United States. 

INTRODUCTION AND ! OF THE 

Mv name is Brent K Baker, I am 46 years old, with an Bachelors Degree in Electronics Engineering 

Technology 

I've completed mv Flight Training and single engine land private pilot's license in 1996 followed bv mv 

instrument rating in 2000. I have 400+ total hours pilot in command. Also video ground school in VTAL 

rotating wing. 

I wish to provide high quality imaging for a variety of commercial and public uses, specifically targeting: 

• Aerial Survey 

• Commercial Photography 

• Management of Construction Progress. 

• Site Health and Safety Plan inspections 

• Insure implementation of Environmental Controls such as storm water discharge requirements and 

pollution prevention mitigation 

• Inspections of Conm1ercial Real Estate 

ROUND 

Umnanned Aircraft Systems: DJI Phantom 3Vision+, blade 350Qx3 and Blade 450X Helicopter. 

APPlicant seeks an exemption to operate DJI svstemsfor compensation or hire within the NAS. The DJI 

Phantom 3Vision+ and DJI Inspire 1 are vertical takeoff and landing (VTAL) Unmanned Aircraft (UA) with a 

Ground Control Station (GCS) utilizing electronic tablet or smart phone svstems. The DJI Phantom 3Vision+ 

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 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 3Vision+ and DJI Inspire 1 UAs are 

equippedwith four main rotors; driven by Lithium Polymer battery powered electric motors. 

The DJI Phantom 3Vision+ and DJI Inspire 1 UAs that will be operated bv APPlicant will be registered in 

accordance with 49 U.S.C. 44103, Rezistration 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, APPlicant, pursuant to the provisions of the Federal Aviation Regulations 04 C.F.R. ~ 11.61) and the 

FAA Modernization and Reform Act of2012 (FMRA). Section 333. Soecial Rules for Certain Unmanned 

Aircraft Svstems, hereby petitions the Administrator to commercially operate the DJI Phantom 3Vision+, DJI 

Inspire 1 UASs in the National Airspace Svstem (NAS). and for an exemption from the reauirements of 14 

C.F.R ~~ 61.23(a), 61.101(e4) 61.113(a) & (b), 61.315 (a), 91.7(a), 91.119 (c), 91.119 (c), 91.121, 91.151(b), 

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

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

3 
its operation, Applicant operation ofDJI Phantom 3Vision+ and DJI Inspire 1 UASs meets the conditions of 

FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 

21, Subpart H. 

Accordingly, Applicant requests relief from Sections 91.405(at 91.407( a)(l )_ 91.409(a)(l) & (a)(2\ and 

91.417(a) & (b)_ as these sections set forth requirements for maintenance that only apply to aircraft with an 

airworthiness certificate. 

APPlicant submits that the requested relief is proper since an equivalent level of safetv will be ensured. 

Applicant 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._ Monthlv Maintenance Log, and DJI Phantom 3Vision+ and DJI Inspire 1 Instruction Manual). 

Furthermore, Applicant will document and maintain all maintenance records for the DJI Phantom 3Vision+ and 

DJI Inspire 1 UASs. 

Relief from certain requirements of Section 61.113(a) and (b)_ entitled Private vilot vrivilezes and limitations: 

Pilot in command, is requested bv APPlicant 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 safelv operate the DJI 

Phantom 3Vision+ 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. 

Applicant seeks relief from Section 91.7 (at entitled Civil aircraft airworthiness, because the DJI Phantom 

3Vision+ and DJI Inspire 1 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 

21, Subpart H. As such, APPlicant submits that he will ensure that the DJI Phantom 3 Vision+ and DJI Inspire 

1 UASs are in an airworthv condition, prior to everv flight, bv determining that the UASs are in compliance with 

the operating documents (i.e., Monthlv Maintenance Log, and DJI Phantom 3Vision+ and DJI Inspire 1 

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

APPlicant also seeks an exemption from the requirements of Section 91.119 ( c t entitled Minimum Safe 

Altitudes: General, as the DJI Phantom 3Vision+ and DJI Inspire 1 UAs operate at low altitudes of 400 feet or 

less. 

Applicant also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settinzs, as the 

DJI Phantom 3Vision+ and DJI Inspire 1 UAs will not have a typical barometric altimeter onboard. However, 

altitude information ofthe DJI Phantom 3Vision+ and DJI Inspire 1UAs will be provided to the PIC via Global 

Positioning Svstem (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 infonnation, combined with APPlicant's 

operation of the DJI Phantom 3Vision+ and DJI Inspire 1 UASs within visual line of sight, at or below 500 feet 

AGL, will ensure a level of safety equivalent to Section 91.121. 

Additionally, Applicant seeks an exemption from the requirements of Section 91.151 (b), entitled Fuel 

reauirements for flizht in VFR conditions. APPlicant submits that safetv will not be affected bv operation of the 

DJI Phantom 3Vision+ and DJI Inspire 1 UAs during davlight hours in visual meteorological conditions (VMC) 

under visual flight rules (VFR )_ with enough battery power to flv for a total 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, Applicant provides the following information in support of its petition for 

exemption: 

4 
me And Of Petitioner. 

The name and address of the Petitioner and point of contact is: Brent K Baker 

Applicant 

4176 Maple St 

Chino, CA. 91710 

The brent 182@gmail.com 

The Specific C.F.R. From Which Applicant ption. 

Annlicant Seeks Exemntion From The Requirements Of Section 61.23(a). Medical certificates: 

Requirement and duration. 

(a) Operations requiring a medical certificate. Except as provided in paragraphs (b) and (c) of this section. 

Annlicant Seeks Exemption From The Requirements Of Section 61.101(e4)Recreational pilot privileges 

and limitations. 

(e) Except as provided in paragraphs (d) and (i) of this section, a recreational pilot may not act as pilot in 

command of an aircraft-

(iv) With retractable landing gear; 

Applicant 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 oilot certificate mav act as a pilot in command (PIC) of an aircraft that is 

carrving 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. 

Applicant Seeks Exemption From The Requirements Of Section 315 (a). 

61.315 What are the privileges and limits of my sport pilot certificate? 

(a) If you hold a sport pilot certificate you may act as pilot in command of a light-sport aircraft, except as 

specified in paragraph (c) of this section. 

Applicant Seeks Exemption From The Requirements Of Section 91.7(a). 

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

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

Applicant Seeks Exemption From The Requirements Of Section 91.119 (c). 

Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes: 

Applicant 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--

5 
(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)(l)(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. 

Applicant 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 verson mav bezin a flizht in a rotorcraft under VFR conditions unless (considerinz wind and forecast 

weather conditions) there is enouzh fuel to flv to the first point of intended landing and, assuming normal 

cruising speed, to fly after that for at least 20 minutes. 

Applicant 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 

4 3 of this chapter[.] 

Applicant Seeks Exemption From The Requirements Of Section 91.407(a)(1) 

Section 91.407. entitled Overation 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[.] 

Applicant 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 ofthis chapter and has been approved for return to service 

by a person authorized by § 4 3. 7 of this chapter; or 

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

Applicant 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 perfonned 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 

(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 

6 
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 safetv directives including. for each, the 

method of compliance. the AD or safetvdirective 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 bv ~ 43.9(d) ofthis 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) ofthis 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 be retained 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 ofthis chapter shall be retained 

until the defects are repaired and the aircraft is approved for return to service. 

Extent Rei Applicant Seeks And The ica 

Extent Of Relief Applicant Seeks And The Reason Applicant Seeks Relief From Section 61.23(a). 

Medical certificates: Requirement and duration. (a) Operations requiring a medical certificate. Except as 

provided in paragraphs (b) and (c) of this section. The PIC will not be operating a aircraft which is capable of 

carrying passengers or the pilot. 

Extent Of Relief Applicant Seeks And The Reason Applicant Seeks Relief From Section 61.101(e4). 

61.1 01 Recreational Pilot privileges and limitations. (e) Except as provided in paragraphs (d) and (i) of this 

section. a recreational pilot mav not act as pilot in command of an aircraft-(iv) With retractable landing gear; 

as the DJI Inspire 1 has retractable landing gear which is integral to the operation ofthe camera. The landing 

gear lifts to allow 360 degree rotation of the camera without interference bv the landing gear. This operation is 

ultimately safer than rotating the entire DJI Inspire 1 do the simplification of the rotation process. 

Extent Of Relief Applicant Seeks And The Reason Applicant Seeks Relief From Section 61.113(a) And (b). 

Relief from Section 61.113(a) and (b) entitled Private vilot vrivilezes and limitations: Pilot in command. is 

requested to the extent necessarv to allow a PIC holding a orivate 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 

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 anv business or emplovment if: (1) The 

flight is onlv incidental to that business or employment; and (2) The aircraft does not can-y passengers or 

property for compensation or hire. 

As set forth more fullv below. Applicant submits that an equivalent level of safetv will be maintained because 

no PIC will be allowed to operate the DJI Phantom 3Vision+ UAS or DJI Inspire 1 UAS unless that PIC has 

met certain flight-hour and currency requirements. demonstrating that the PIC is able to safelv operate either the 

DJI Phantom 3Vision+ 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. APPlicant submits that all flights of the DJI Phantom 3Vision+ and DJI Inspire 1 UASs. conducted by 

the PIC pursuant to the grant of this Petition: (1) will be incidental to Applicant's business; and (2) will not 

carry passengers or property for compensation or hire. 

Extent Of Relief Applicant Seeks And The Reason Applicant 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 

Applicant to determine that the DJI Phantom 3Vision+ 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 Applicant 
Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3Vision+ and DJI Inspire 1 Instruction 

Manual). 

Aoolicant seeks the requested relief because the DJI Phantom 3Vision+ and DJI Insoire 1 UASs do not require 

an airworthiness certificate in accordance with 14 C.F .R. Part 21. Subpart H. Therefore. AoPlicant will ensure 

that the DJI Phantom 3Vision+ and DJI Inspire 1 UASs are in airworthy condition based upon its compliance 

with the ooeratimz documents (i.e .. Monthly Maintenance Log, and DJI Phantom 3Vision+ 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. 

Extent Of Relief Applicant Seeks And The Reason Applicant Seeks Relief From Section 91.119 (c). 

Relief from Section 91.119 (c). entitled Minimum Safe Altitudes: General, as the DJI Phantom 3Vision+ and 

DJI Inspire 1 UAs operate at low altitudes of 400 feet or less. 

Extent Of Relief Applicant Seeks And The Reason ApplicantSeeks Relief From Section 91.121. 

Relief from Section 91.121. entitled Altimeter settings. may be required to allow flight operations of the DJI 

Phantom 3Vision+ and DJI Inspire 1 UASs. which utilize a barometric pressure sensor. GPS equioment 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). Aoolicant seeks the requested relief 

because the DJI Phantom 3Vision+ 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 orooosed ooerations. relief from 14 CFR 91.121 is sought to the extent 

necessarv 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 3Vision+ and DJI Inspire 1 UAs are 

eouipoed 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. 

Extent Of Relief Applicant Seeks And The Reason Applicant 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 batterv oowered DJI Phantom 3Vision+ and DJI Insoire 1 UAs during davlight 

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.Aoolicant seeks the requested reliefbecause without an exemotion from Section 91.151(b), the 

flight time duration ofthe batterv powered DJI Phantom 3Vision+ and DJI Insoire 1 UAs will severely 

constrain the practicality of any aerial video or still photo flight operations that Applicant proposes to conduct 

pursuant to this Petition. 

Sirnificantlv. as set forth below. the technical specifications of the DJI Phantom 3Vision+ and DJI Insoire 1 

UASs. the DJI Phantom 3Vision+ and DJI Inspire 1 operating documents. and Applicant's oroposed ooerating 

limitations. ensure that Applicant will safely operate the batterv powered DJI Phantom 3Vision+ and DJI 

Insoire 1 UAs during davlight hours in visual meteorological conditions (VMCt under visual flight rules (VFR), 

with enough batterv 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. 

Extent Of Relief Aoolicant Seeks And The Reason Aoolicant 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(at 91.407(a)(l). 91.409(a)(l) & (a)(2). and 91.417(a) & (b) onlv aoolv to aircraft with an 

airworthiness certificate. Aoolicant requests relief from these Sections because the DJI Phantom 3Vision+ and 

DJI Inspire 1 UASs do not require airworthiness certificates. As set forth more fully below. the DJI Phantom 

3Vision+ and DJI Insoire 1 UASs meet the conditions ofFMRA Section 333 for ooeration without an 

airworthiness certificate. Accordinglv. AoPlicant 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 APPlicant Aerial Ooerations ManuaL Monthly Maintenance Log, and 

DJI Phantom 3Vision+ and DJI Inspire 1 Instruction Manual). Furthermore. Applicant will document and 

maintain all maintenance records for the DJI Phantom 3Vision+ and DJI Inspire 1 UASs. 

8 
Reasons Why Granting ld In Public I That Is, How It 

Would blic A Whole. 

Granting the oresent Petition will further the public interest bv allowing APPlicantto safelv. efficientlv. and 

economically perform aerial video and photography of construction sites, real estate, and landscape over certain 

areas of the United States. 

Additionallv. use of the DJI Phantom 3Vision+ and DJI Inspire 1 UASs will decrease congestion of the NAS. 

reduce pollution. and provide significant benefits to the economv. Notablv. the benefits of APPlicant's proposed 

operation of the DJI Phantom 3Vision+ and DJI Inspire 1 UASs will be realized without implicating any 

pnvacy 1ssues. 

The Public Will Benefit From Decreased Congestion Of The NAS. 

The DJI Phantom 3Vision+ and DJI Inspire 1 UAs are batterv powered and serve as a safe. efficient and 

economical alternative to the manned aircraft traditionally utilized to obtain aerial imagerv. Bv reducing the 

amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJI 

Phantom 3Vision+ 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, bv reducing the number of manned aircraft operating in the NAS. congestion around airports 

caused bv arriving and departing aircraft will be reduced. The DJI Phantom 3Vision+ and DJI Inspire 1 UAs do 

not require an aimort 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. 

The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 3Vision+ and DJI Inspire 

1 UASs. 

Conducting aerial acquisitions with the DJI Phantom 3Vision+ and DJI Inspire 1 UASs. instead of manned 

aircraft. will greatlv benefit the public bv drastically reducing the levels of air and noise pollution generated 

during traditional aerial video and still photography flight operations. Bv using batterv power and electric 

motors. the DJI Phantom 3Vision+ and DJI Inspire 1 UASs produce no air pollution. and is the most viable 

environmentally conscious alternative to the cabin class, six cvlinder internal combustion engine aircraft that 

are tvoicallv utilized for aerial video and photography, while burning aporoximatelv 20-30 gallons per hour of 

leaded aviation fuel. The DJI Phantom 3Vision+ and DJI Inspire 1 UAs. while reducing the carbon footorint of 

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

rather than an internal combustion engine. 

Bv using the DJI Phantom 3Vision+ 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 usuallv associated with traditional manned aircraft 

flight operations. will be substantially reduced or completely eliminated. Aside from the lack of fli~ht crew 

members located onboard the aircraft. the DJI Phantom 3Vision+ and DJI Inspire 1 UAs (weighing 

approximately 2 pounds 11 ounces and 6 pounds 7.5 ounces respectivelv. 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 tvoicallv conduct similar operations (weighing approximately 6.000 

pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons). 

Performin!! Aerial Video and Photography Operations With The DJI Phantom 3Vision+ and DJI Inspire 

1 UASs Will Benefit The Economy. 

In addition to being safe and efficient the DJI Phantom 3Vision+ 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 3Vision+ and DJI Inspire 1 UASs will allow United States based companies. like APPlicant to 

remain competitive and contribute to growth ofthe U.S. economv. Specifically, with the rising cost of aviation 

fuel and the Environmental Protection Agencv ("EPA") regulatorv 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 batterv powered DJI Phantom 3Vision+ and DJI Inspire 1 UASs is one such technology that not 

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

without the high operational cost of a traditional manned aircraft. 

Bv operating the DJI Phantom 3Vision+ and DJI Inspire 1 UASs. companies such as APPlicant can remain 

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

9 
ultimately contribute to growth of the U.S. economv. Improved financial performance ofU.S. companies, 

throu!ili commercial use of the DJI Phantom 3Vision+ 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. 

There Are No Privacy Issues. 

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

proposed operation of the DJI Phantom 3Vision+ and DJI Insoire 1 UASs will not imolicate anv orivacv issues. 

Specifically, the DJI Phantom 3Vision+ and DJI Inspire 1 UASs will be ooerated onlv in compliance with 

operating documents (i.e., the Applicant Aerial Operations Manual. Monthly Maintenance Log, and DJI 

Phantom 3Vision+ and DJI Inspire 1 Instruction Manual) which reauires orooertv 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.P.R. § 91.119. 

The Why Granting Exemption Would Not Adversely Safety, The 

ption Would Provide A Level Of At That Provided By 

Which nt ption. 

Reasons Whv The DJI Phantom 3Vision+ and DJI Insuire 1 UAs Meet The Conditions Of The FAA 

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

In consideration of the size, weight soeed, and limited ooerating area associated with the unmanned aircraft and 

its operation. APolicant's operation of the DJI Phantom 3Vision+ and DJI Inspire 1 UASs meet the conditions 

ofFMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.P.R. Part 21, 

Subpart H. 

Section 333 Provides authoritv for a UAS to overate 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.--Notwithstandinz anv other reauirement of this subtitle. and not later than 180 davs after the 

date of enactment of this Act. the Secretarv ofTransvortation shall determine if certain unmanned aircraft 

svstems mav overate safelv in the national airsvace svstem before comvletion of the vlan and rulemaking 

required by section 332 of this Act or the guidance required by section 334 of this Act. 

(b) Assessment of Unmanned Aircraft Svstems.--In making the determination under subsection (a), the 

Secretmy shall determine, at a minimum--

(]) which tvves of unmanned aircraft svstems. if anv. as a result of their size. weizht. sveed. overational 

cavabilitv. vroximitv to airvorts and vovulated areas. and overation within visual line of sizht 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) Reauirements for Safe Overation.--Ifthe Secretarv determines under this section that certain unmanned 

aircraft svstems mav overate safelv in the national airsvace svstem. the Secretary shall establish requirements 

for the safe operation of such aircraft systems in the national airspace system. 

In seeking this exemption. Aoolicant submits that the DJI Phantom 3Vision+ and DJI Inspire 1 UASs can 

operate safelv in the NAS pursuant to FMRA Section 333. as demonstrated bv: (a) the characteristics of the DJI 

Phantom 3Vision+ and DJI Inspire 1 UASs; (b) the pilot certification requirement; and (c) the specific operating 

limitations. 

a. The Suecifications Of The DJI Phantom 3Vision+ and DJI Inspire 1 UASs Demonstrate Its Safe 

Characteristics. 

The DJI Phantom 3Vision+ and DJI Inspire 1 UASs do not create a hazard to users ofthe 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 3Vision+ and DJI Inspire 1 UASs. 

The technical specifications of the DJI Phantom 3Vision+ and DJI Inspire 1 UASs are set forth by the 

10 
DJI Phantom 3Vision+ and DJI Inspire 1 Specifications and Data Sheet, attached hereto as Exhibit A 

and B. 

ii. The DJI Phantom 3Vision+ and DJI Insoire 1 UASs Autonomous Fli!!ht And Navigation 

Modes Enable The UASs To Remain Within A Defined Operational Area. 

The DJI Phantom 3Vision+ 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 3Vision+ and DJI Inspire 1 UASs is provided at pages 25-35 of the DJI Phantom 3Vision+ 

and pages 12-16 and 45-50 of the DJI Inspire 1 User Manuals, attached hereto as Exhibit C and D. 

iii. The DJI Phantom 3Vision+ and DJI Insoire 1 UASs Are Desi!!ned 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 3Vision+ and DJI Inspire 1 UAs will remain stationary, 

in flight for 3 seconds or more. If. after 3 seconds. the DJI Phantom 3Vision+ and DJI Inspire 1 UAs 

do not reacauire 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 3Vision+ UAS are set forth at 

pages 27 through 29 and for the DJI Inspire 1 at pages 13 through 15 of the DJI Phantom 3Vision+ and 

DJI Inspire 1 User Manuals, attached hereto as Exhibit C and D. 

iv. The DJI Phantom 3Vision+ and DJI Inspire 1 GCS And Its Operation. 

A complete description of the operation and specifications of the DJI Phantom 3Vision+ and DJI 

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

3Vision+ User Manual and pages 40 through 47 of the DJI Inspire 1 User Manual. DJI Phantom 

3Vision+ and DJI Inspire 1 User Manuals are attached hereto as Exhibits C and D. 

b. Fli!!ht Ooerations OIDJI Phantom 3Vision+ and DJI Insoire 1 UASs Are Limited To The Line Of Sight 

Of A Certificated Pilot in Command With A Safety Observer. 

APPlicant 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 3Vision+ and DJI Inspire 1 UASs. Additionally, a safety observer 

will assist all pilots during flight time. 

c. Fli!!hts OIDJI Phantom 3Vision+ and DJI Inspire 1 UASs Will Be Conducted Pursuant To Specific 

Operating Limitations. 

In seeking this exemption. APPlicant proposes to commercially operate DJI Phantom 3Vision+ 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 than 55 pounds maximum gross weight: 

DJI Phantom 3Vision+ and DJI Inspire 1 Unmanned Aircraft Systems. Proposed operations of any 

other aircraft will 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 (AGU. 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 reauires 

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) is not permitted. 

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

reauirement as long as the PIC always maintains VLOS capabilitv. 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 

1 
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 oerform anv other duties bevond 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 ooerating documents and the grant of exemotion must be accessible during UAS ooerations and 

made available to the Administrator uoon request. If a discreoancv exists between the conditions and 

limitations contained in the grant of exemotion and the orocedures outlined in the ooerating documents, 

the conditions and limitations contained in the grant of exemotion take orecedence and must be 

followed. Otherwise. the ooerator must follow the orocedures as outlined in its ooerating documents. 

The ooerator mav uodate or revise its ooerating documents. It is the ooerator's resoonsibilitv to track 

such revisions and oresent uodated and revised documents to the Administrator uoon request. The 

ooerator must also oresent uodated and revised documents if it oetitions for extension or amendment to 

the grant of exemotion. If the ooerator determines that anv uodate or revision would affect the basis 

uoon which the FAA granted the exemotion. then the ooerator must oetition for amendment to its grant 

of exemotion. The FAA's UAS Integration Office (AFS-80) may be contacted if questions arise 

regarding updates or revisions to the operating documents. 

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

the insoection reveals a condition that affects the safe ooeration of the UAS. the aircraft is orohibited 

from ooerating until the necessarv maintenance has been oerformed and the UAS is found to be in a 

condition for safe flight. The Ground Control Station must be included in the oreflight inspection. All 

maintenance and alterations must be properly documented in the aircraft records. 

11. Anv UAS that has undergone maintenance or alterations that affect the UAS ooeration or flight 

characteristics. e.g. reolacement of a flight critical comoonent must undergo a functional test flight. 

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

12. The ore-flight insoection must account for all ootential discreoancies. e.g. inooerable components, 

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

13. The ooerator must follow the UAS manufacturer's aircraft/component, maintenance, overhaul, 

replacement, inspection, and life limit requirements. 

14. The ooerator must carrv out its maintenance. insoections. and record keeoing requirements, in 

accordance with the ooerating documents. Maintenance. insoection. alterations. and status of 

reolacement/overhaul comoonent oarts must be noted in the aircraft records. including total time in 

service. descriotion 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 oerson must make an entrv 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 ooerator mav not oermit anv PIC to overate unless the PIC meets the ooerator's qualification 

criteria and demonstrates the abilitv to safelv overate the UAS in a manner consistent with how the 

UAS will be ooerated under the exemotion. including evasive and emergency maneuvers and 

maintaining aoorooriate distances from oersons. 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 oumoses 

of training the ooerator's PICs are oermitted under the terms of the exemotion. However. training 

ooerations mav onlv be conducted during dedicated training sessions. During training. oroficiency, and 

exoerience-building flights. all oersons not essential for flight ooerations are considered 

nonoarticioants. and the PIC must overate the UA with appropriate distance from nonparticipants in 

accordance with 14 C .F .R. § 91.119. 

19. UAS ooerations mav not be conducted during night as defined in 14 C.P.R.~ 1.1. All ooerations 

must be conducted under visual meteorological conditions (VMC). If flight at night is required. a 

soecial request will be made at the FAA office closest to proposed area of operations. Flights under 

special visual flight rules (SVFR) are not authorized. 

12 
20. The UA mav 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 NOT AM as required bv the operator's 

CO A. The letter of agreement with the airport management must be made available to the 

Administrator upon request. 

21. The UA mav 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 ofunpredicted 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 flv 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 of Waiver or 

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

also require the operator to request a Notice to Airman (NOT AM) 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 bv 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 frequencv 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 anv time the UAS is operating. These documents must be made 

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

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 mesent that sufficientlv 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 safetv 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 propertv 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. Anv incident accident or flight operation that transgresses the lateral or vertical boundaries of the 

operational area as defined bv 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: vV\Vw.ntsb.gov. 

Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely 
Affect Safety. 

APPlicant submits that the equivalent level of safetv established bv Section 61.113( a) and (b) will be maintained 

because no PIC will be allowed to operate the DJI Phantom 3Vision+ and DJI Inspire 1 UASs unless that PIC 

has demonstrated. bv meeting minimum flight-hour and currencv requirements. that the PIC is able to safelv 

operate the DJI Phantom 3Vision+ 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 Applicant'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 necessarv to safelv operate the DJI Phantom 3Vision+ or DJI 

Inspire 1 UAS. APPlicant submits that the additional manned airmanshiP experience of a commerciallv 

certificated pilot would not correlate to the airmanship skills necessary for Applicant's specific proposed flight 

operations. 

The FAA has oreviouslv 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). 

Applicant will not allow any PIC to operate the DJI Phantom 3Vision+ or DJI Inspire 1 UAS unless that PIC 

has demonstrated. bv meeting minimum flight-hour requirements or the DJI Phantom 3Vision+ or DJI Inspire 1 

UAS training and currencv requirements. that the PIC is able to safelv operate the DJI Phantom 3Vision+ 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. 

Specificallv. the PIC must have accumulated and logged. in a manner consistent with 14 C.P.R. Q 61.51(b), 25 

hours oftotal time as a UAS rotorcraft Pilot (with a minimum of5 hours ofthose hours as a UAS Pilot 

operating the same make and model ofUAS 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 safetv during Applicant'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 CPR 61.51(b). 25 hours oftotal 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 ofUAS 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 mav be included in the 10 

hours of multi-rotor time and the 10 hours mav be included in the total25 hours ofUAS rotorcraft time. In 

addition to the hour requirements. the PIC must accomplish 3 takeoffs and landings in the preceding 90 days 

(for currencv 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 necessarv 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 satisfv this requirement. Training. proficiency, and experiencebuilding flights can also be conducted under the grant of exemption to accomplish the required flight time. 

During training. proficiencv. 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. Applicant will ensure safe operations by not allowing any PIC to operate the DJI Phantom 

3Vision+ or DJI Inspire 1 UAS unless that PIC has demonstrated. by meeting minimum flight-hour and 

currencv requirements. that the PIC is able to safelv operate the DJI Phantom 3Vision+ 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. 

Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Mfect 

Safety. 

4 
The equivalent level of safetv established by Section 91.7 (a) will be maintained because prior to every flight 

APPlicant will ensure that the DJI Phantom 3Vision+ 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). 

Reasons Whv An Exemotion From The Requirements Of Section 91.119 (c) and91.121 Would Not 

Adversely Affect Safety. 

The equivalent level of safety established by Sections 91.119 (c) and 91.121 will be maintained because the 

altitude information of the DJI Phantom 3Vision+ and DJI Inspire 1 UAs will be orovided 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 Applicant's operation of the 

DJI Phantom 3Vision+ and DJI Inspire 1 UAs within visual line of sight at or below 500 feet AGL. 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 oreviously 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). 

Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely Mfect 

Safety. 

A !rrant 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 3Vision+ and DJI Inspire 1 UASs: (2) the 

limitations on the proposed flight operations: and (3) the location of the proposed flight operations. Accordingly, 

APPlicant will ensure that it will safely operate the batterv powered DJI Phantom 3Vision+ and DJI InsPire 1 

UAs during daylight hours in VFR conditions. with enough batterv 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 Phantom 3Vision+ and DJI Inspire 1 

UASs: the limitations on the proposed flight operations: and the location of the oroposed operations. will ensure 

an equivalent level of safetv established by 14 C.F.R. Section 91.151(b ). Furthermore. safetv will be ensured as 

the DJI Phantom 3Vision+ and DJI Inspire 1 UASs orovide audible and visual warnings to the PIC at the GCS 

when the UAs experiences low batterv voltage. the first warning occuning at approximately 33% remaining 

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

DJI Phantom Vision+ and DJI Inspire 1 UASs will descend and land automatically. 

SignificantlY. orevious exemptions granted by the FAA concerning Section 91.151 establish that safetv 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. 881 L 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

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

Reasons Whv An Exemotion From The Reouirements Of Sections 

91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety. 

In seeking this exemption. Applicant submits that the equivalent level of safety with regard to the regulatorv 

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 APPlicant will use trained technicians to perform maintenance. 

alterations. or oreventive maintenance on the UASs using the methods, techniques. and practices orescribed in 

the operating documents (i.e., the Applicant Aerial Operations ManuaL Monthly Maintenance Log, and DJI 

Phantom 3Vision+ and DJI Inspire 1 Instruction Manual). Furthermore. Applicant will document and maintain 

all maintenance records for the DJI Phantom 3Vision+ and DJI Inspire 1 UASs. 

Since the DJI Phantom 3Vision+ and DJI Inspire 1 UASs will be inspected as prescribed by the operating 

documents, Applicant will maintain the equivalent level of safety established by Sections 91.405(a), 

15 
91.409(a)(l). and 91.409(a)(2). A copy of the DJI Phantom 3Vision+ and DJI Inspire 1 User Manuals are 

attached hereto as Exhibit C and D: a copy of the DJI Phantom 3Vision+ and DJI Inspire 1 UAS Maintenance 

LOG is attached hereto as Exhibit E. 

Likewise. the exemption sought will not adversely affect safety because Applicant 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. 

Furthern1ore. the exemotion sought would maintain an eauivalent level of safety established bv Sections 91.407, 

91.417(a) and 91.417(b). because all maintenance of the DJI Phantom 3Vision+ and DJI Inspire 1 UASs will be 

performed bv trained technicians. Maintenance will be documented and maintained utilizing the monthly 

maintenance log. 

SignificantlY. previous exemptions granted bv the FAA concerning Sections 91.405( a). 91.407 (a )(1). 

91.409(a)(l) & (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 Applicant's proposed operating limitations. the operating documents. and the technical 

asoects of the DJI Phantom 3Vision+ and DJI Insoire 1 UASs. Aoolicant submits that safetv will not be 

adversely affected bv granting exemotion from 14 C.P.R. Sections 91.405(a). 91.407(a)(l) 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. Exemotion Nos. 11062. 11063. 11064. 11065. 

11066.11067,11080,11109,11110,11112,11136,11138,11150,11153,11156,11157,11158,11159,11160, 

11161). 

The FAA May Prescribe Any Other Conditions For Safe Operation. 

In accordance with Section 333 of the FAA Modernization and Reform Act of2012 (FMRA) and 14 C.P.R. & 

21.16 entitled Soecial Conditions. Aoolicant reauests that the FAA orescribe special conditions for the intended 

operation of the DJI Phantom 3Vision+ and DJI Inspire 1 UASs. which contain such safety standards that the 

Administrator finds necessary to establish a level of safetv eauivalent to that established bv 14 C.P.R. Part 21. 

Suboart H. and 14 C.F.R && 61.113(a) & (b). 91.7 (a). 91.12L 91.151(b). 91.405(a). 91.407(a)(l ). 91.409(a)(l) 

& (a)(2). and 91.417(a) & (b). Such special conditions will permit safe operation of the UAs for the limited 

puroose of conducting aerial video and photography over certain areas of the United States for compensation or 

hire. FMRA Section 333 sets forth the reauirements 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 mav orescribe soecial conditions oursuant to 14 C.P.R. 

& 21.16. for operation of the DJI Phantom 3 Vision+ and DJI Insoire 1 UASs. since the airworthiness regulations 

of 14 C.P.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 the following: 

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

safetv standards for an aircraft. aircraft engine. or oropeller 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 soecial conditions are issued in accordance with Part 11 of this chaoter 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.P.R. § 21.16. 

Therefore. in accordance with FMRA Section 3 3 3 and 14 C.F .R. & 21.16. the FAA mav orescribe special 

conditions for the Aoolicant intended operation of the DJI Phantom 3Vision+ and DJI Insoire 1 UASs. which 

contain such safety standards that the Administrator finds necessary to establish a level of safetv equivalent to 

that established bv 14 C.P.R. Part 2L 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)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b). 

• A Summarv That Can Be Published In The Federal Register, stating: The Rules From Which 

Applicant Seeks Exemption: 

Armlicant seeks exemvtion from the reauirements 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 Applicant Seeks: 

16 
This exemvtion will vermit Avvlicant to commerciallv overate an Unmanned Aircraft Svstem (UAS) for the 

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

• Any Additional Information, Views, Or Arguments Available To Support Applicant'sRequest. 

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

(FMRA) Section 333. which directs the Secretarv of Transportation to determine if certain UAS mav ooerate 

safely in the NAS. As such, Applicant'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 oublic. or otherwise oose a threat to national security; and further, provides the authority for 

such UAS to operate without airworthiness certification. 

As discussed in detail above. Aoolicant will operate the DJI Phantom 3Vision+ and DJI Insoire 1 UASs safelv 

in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national 

security. 

As set forth herein. Aoolicant seeks an exemotion oursuant to 14 C.F.R. ~ 11.61 and Section 333 of the FAA 

Modernization and Reform Act of 2012 (FMRA). which will oermit safe operation of the DJI Phantom 

3Vision+ and DJI Insoire 1 UASs commercially, without an airworthiness certificate, for the limited ouroose of 

conducting aerial video and ohotograohv over certain areas of the United States. Bv granting this Petition. the 

FAA Administrator will be fulfilling the Comrressional mandate of the FAA Modernization and Reform Act of 

2012. while also advancing the interests of the public. bv allowing Aoolicant to safelv. efficiently, and 

economically operate the DJI Phantom 3Vision+ and DJI Inspire 1 UASs commercially within the NAS. 

WHEREFORE. in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform 

Act of2012. Section 333. Aoolicant resoectfullv reauests 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). 91.12L 91.151(b). 91.405(a). 

91.407(a)(l). 91.409(a)(l) & (a)(2). and 91.417(a) & (b). and oermit the Aoolicant to operate the DJI Phantom 

3Vision+ and DJI Insoire 1 UASs commercially for the purpose of conducting aerial video and photography rn:rt:J.r f""l't3-rlt:l-in -::::art:t.o::tc A-f t'hP. T Tn-itPrl ~t-::~fp.c 

Brent K Baker 

4176 Maple St. 

Chino, CA. 91710 

thebrent182((7)gmail.com 

909-703-0225 

l