September 2, 2015

Exemption No. 12727

Regulatory Docket No. FAA−2015−2519

Mr. Craig Fonseca

Sparktech Imagery LLC

1500 Beville Road, 606-416

Daytona Beach, FL 32114

Dear Mr. Fonseca:

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

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

including the date it ends.

By letter dated June 2, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Sparktech Imagery LLC (hereinafter petitioner or operator) for an exemption. The 

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

videography and photography.

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

the regulations that the petitioner seeks an exemption.

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

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

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

Airworthiness Certification

The UAS proposed by the petitioner are the DJI Phantom 2 Vision +, DJI Phantom 3 

Professional, and DJI Inspire.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 
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consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1

. The FAA has issued grants of 

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

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

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

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

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

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

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

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

by this exemption is in the public interest.

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

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

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

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

11213 also apply to the situation you present; and 

• A grant of exemption is in the public interest.

Our Decision

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

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

delegated to me by the Administrator, Sparktech Imagery LLC is granted an exemption from 

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

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to 

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

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

 

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

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

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

instruments aboard the UA.
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Conditions and Limitations

In this grant of exemption, Sparktech Imagery LLC is hereafter referred to as the operator.

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

grounds for the immediate suspension or rescission of this exemption.

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

Vision +, DJI Phantom 3 Professional, and DJI Inspire when weighing less than 

55 pounds including payload. Proposed operations of any other aircraft will require a 

new petition or a petition to amend this exemption.

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

not permitted. 

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

exemption holder may use either groundspeed or calibrated airspeed to determine 

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

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

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

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

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

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license.

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

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

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

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

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

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

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

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

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

limitations in this exemption and the procedures outlined in the operating documents, 
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the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

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

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

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

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

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

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

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

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

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

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

in a condition for safe operation.

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

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

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

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

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

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

aircraft components.

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

safety bulletins.

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

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

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

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

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

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.
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14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

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

operated under this exemption, including evasive and emergency maneuvers and 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

to the Administrator or any law enforcement official upon request.

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

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

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

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

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

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

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

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

power recommended by the manufacturer if greater.

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

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

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

operations that cannot be conducted under the terms of the attached COA.
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22. All aircraft operated in accordance with this exemption must be identified by serial 

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

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

be as large as practicable.

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

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

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

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

official upon request.

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

activities at all times. 

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

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

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

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

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

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

nonparticipating persons under this exemption.

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

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

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

contained on the NTSB Web site: www.ntsb.gov.
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If this exemption permits operations for the purpose of closed-set motion picture and 

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

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

as documented in this grant of exemption.

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

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

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

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

must include at least the following:

a. Dates and times for all flights;

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

under this grant of exemption;

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

the UAS;

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

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

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

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

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

g. Signature of exemption holder or representative; and

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

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

essential to accomplish the operation.

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

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

exemption holder’s MPTOM.

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

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

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

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

SPARKTECH IMAGERY LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14

OF THE CODE OF FEDERAL REGULATIONS SECTIONS 

14 C.F.R §§ 45.23(b); Part 21, Subpart H; 61.23(a); 61.113(a); 91.7(a); 91.119(c); 91.121; 91.151(a); 

91.405(a); 91.407(a)(1); 91.409(a)(1)&(2); 91.417(a)&(b);

CONCERNING COMMERCIAL OPERATION OF DJI UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on June 2nd 2015

Craig Fonseca

Sparktech Imagery LLC

1500 Beville Road, 606-416, 

Daytona Beach, FL, 32114

Tel: 386-675-4879

support@sparktechimagery.com
 Petition for Exemption SPARKTECH IMAGERY LLC

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Sparktech Imagery LLC, formally requests exemption from the requirements of 14 C.F.R §§ 45.23(b); Part 

21, Subpart H; 61.23(a); 61.113(a); 91.7(a); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 

91.409(a)(1)&(2); 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 Sparktech Imagery LLC to 

operate its Unmanned Aircraft System(s) (UAS) for the commercial purpose of conducting aerial video 

and photography in airspace regulated by the Federal Aviation Administration over various locations, 

including landscapes, waterways and oceans within the United States of America. 

Sparktech Imagery LLC’s objective is to capture, document and archive images and 

video using aerial photographic & video technology, thus providing its clients low cost, 

high quality imaging and views from different perspectives. 

THE UNMANNED AIRCRAFT SYSTEMS of SPARKTECH IMAGERY LLC : 

(1) DJI Phantom 2 Vision +

(2) DJI Phantom 3 Professional

(3) DJI Inspire

The petitioner requests permission to operate the DJI Phantom 2 Vision +, the DJI Phantom 3 Professional

and the DJI Inspire UAS within the National Airspace System for hire or compensation. All of the DJI 

systems listed above are vertical takeoff and landing, unmanned aircraft with a ground control station 

utilizing electronic tablet or smart phone systems. They also have a maximum speed under 50 knots and 

weighing less than 7 pounds. No operation will be conducted within 5NM of an airport. Included as the 

appendix to this document are the data specifications and links to the user manuals to the UAS. Similar 

exemptions utilizing such UAS have been approved and deemed airworthy, not requiring any 

airworthiness certification, including exemptions Nos. 11109 Clayco, Inc, 11595 Gary Huett, 11669 

Photobird LLC.

In accordance with 14 C.F.R § 11.81, Sparktech Imagery LLC provides the following information in 

support of its petition for exemption.
 Petition for Exemption SPARKTECH IMAGERY LLC

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NAME AND ADDRESS OF PETITIONER:

Sparktech Imagery LLC

Attn: Mr. Craig Fonseca

Mailing address: 1500 Beville Road, 606-416, Daytona Beach, FL, 32114

Email: support@sparktechimagery.com

Tel: 386-675-4879

Sparktech Imagery LLC submits that proper safety will be ensured and can serve to 

benefit the general public and pose no threat to national security.

Sparktech Imagery LLC will use experienced personnel or technicians to perform maintenance, 

alterations, or preventative maintenance on the UAS using the methods, techniques and practices 

prescribed in the operating documents. Sparktech Imagery LLC will document and maintain a 

maintenance record for its UAS. 

Sparktech Imagery LLC will have a Pilot in Command (PIC) that holds either an airline transport, 

commercial, private, recreational, or sport pilot certificate and medical certificate or valid US driver’s 

license. The PIC will operate the UAS within visual line of sight and use a visual observer at all times. All 

operations will be at a maximum of 400ft above ground level. The PIC will conduct pre-flight inspections 

with every flight; in addition a post-flight inspection will also be performed. To ensure further safety, no 

PIC will be allowed to operate the UAS unless that PIC has met certain flight-hour requirements, 

demonstrating that the PIC is able to safely operate either of the UAS including evasive and emergency 

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

Utilization of the built-in features in the DJI systems such as flight telemetry and records will be logged. 

Sparktech Imagery LLC’s operations utilizing the UAS will provide a great benefit to the general public 

and serve the interest of the public by providing a service that was once only available by hiring a 

much larger manned aircraft. In comparison, the UAS will provide a service of quality aerial 

photographic images and video to many different business and individuals for considerably less cost 

than that of utilizing a manned aircraft. In addition to saving money, the time required for setup and 

flight is also considerably shorter, including the fact that you are documenting on site versus taking off 

from an airport to then go to the location or site. These UAS have significant safety, noise, emission, 

security and environmental benefits, not available to larger manned aircrafts, by using battery power 

and electric motors. They also have numerous safety features such as ‘Failsafe mode’, automatic 

landing should the signal between PIC and the UAS be interrupted, GPS based altitude and distance 

locks, flight limit functions and low battery warnings. 

The use of the UAS will decrease congestion of the National Airspace System and reduce air and noise 

pollution. Further, by this reduction it can increase the safety of life and property in the air and on the 

ground. Airport congestion will also be reduced as the UAS do not require an airport for takeoff or 
 Petition for Exemption SPARKTECH IMAGERY LLC

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landing, thus aiding to reduce the load on the air traffic control during ground, departure, arrival and 

landing phases of flight operations.

Sparktech Imagery LLC proposed commercial operations would not implicate any privacy issues. The 

UAS will be operated in compliance with property owners, as well as any local law enforcement 

requests or notifications if applicable and in accordance with the Federal Aviation Regulations. 

Specific Sections of 14 C.F.R from which Sparktech 

Imagery LLC seeks exemption:

1. 45.23(b) Aircraft markings

2. Part 21, Subpart H Certification procedures; Airworthiness Certificates

3. 61.23(a) Medical Certificate requirements

4. 61.113(a) Private pilot privileges

5. 91.7(a) Airworthiness certificate

6. 91.119(c) Minimum safe altitudes

7. 91.121 Altimeter settings

8. 91.151(a) Fuel requirements for flights in VFR conditions

9. 91.405(a) Maintenance required

10. 91.407(a) (1) Operation after maintenance

11. 91.409(a)(1)and(2) Inspections

12. 91.417(a)&(b) Maintenance records

Extent of Relief and Reasons Requesting Relief

14 C.F.R.45.23(B): DISPLAY OF MARKS; GENERAL

Sparktech Imagery LLC has Unmanned Aircraft Systems, which, as unmanned, do not have a cabin, 

cockpit or pilot station to mark certain words. Furthermore, the two-inch lettering is also difficult to place 

on such a small aircraft. Sparktech Imagery LLC’s UAS will have identification by serial number, 

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

accordance with 14 C.F.R. Part 45, Subpart C. Markings will be large as possible. The FAA has previously 

issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10700 and 11595.

14 C.F.R. PART 21, SUBPART H & 14 C.F.R. 91 – AIRWORTHINESS CERTIFICATES, MANUALS AND OTHER REQUIREMENTS

Sparktech Imagery LLC uses UAS that when considering their size, weight, speed, and the limited 

operating area associated with the aircrafts and their operations meet the conditions of Section 333, 

and requests relief from the regulation. With regards to the requirements 14 C.F.R 91.7(a); considering 

the exemption of requiring an airworthiness certificate, size and unmanned status of the UAS the 
 Petition for Exemption SPARKTECH IMAGERY LLC

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regulations are inapplicable to this operation. The petitioner will meet all safety requirements and 

registrations of the FAA and maintain a safety record and manual for the UAS. To ensure the UAS are 

airworthy, proper maintenance will be regularly applied. 

14 C.F.R. §61.23(A), 61.113 (A): MEDICAL CERTIFICATE & PRIVATE PILOT PRIVILEGES AND LIMITATIONS: OPERATOR.

Sparktech Imagery LLC’s UAS will not carry any persons on board. It will be remotely controlled and 

operated by a PIC holding either an airline transport, commercial, private, recreational, or sport pilot 

certificate ensuring that the PIC has the skills to safely operate the system in a manner acceptable to 

the FAA. In addition all PIC operators will go through guidance, training and meet certain flight-hour

requirements, demonstrating that the PIC is able to safely operate either of the UAS including evasive 

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

and structures prior to operating any of Sparktech Imagery LLC’s UAS. The PIC will hold either a current 

FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, 

Puerto Rico, a territory, a possession, or the Federal Government. All Sparktech Imagery LLC operations 

will be controlled and limited. All flights will be coordinated ahead of time ensuring a level of safety that 

is in accordance with FAA requirements.

14 C.F.R. § 91.119 : MINIMUM SAFE ALTITUDES

Sparktech Imagery LLC’s UAS will never operate at an altitude greater than 400 feet AGL unless other 

altitude limits are forthcoming by the FAA. The petitioner will operate the UAS in a manner protecting 

the public and any consenting participants, providing a level of safety at least equivalent to or below 

those in relation to minimum safe altitudes. 

14 C.F.R. § 91.121: ALTIMETER SETTINGS

Sparktech Imagery LLC’s UAS have no altimeter settings. They, however, utilize electronic global 

positioning systems with a barometric sensor providing instantaneous telemetry to the PIC as to the 

altitude (AGL) of the UAS above the takeoff location.

14 C.F.R. §91.151(A) FUEL REQUIREMENTS FOR FLIGHT IN VFR CONDITIONS.

Sparktech Imagery LLC believes that an equivalent level of safety can be achieved by following the 

UAS manufacturer’s operating documents with regard to battery voltage. In order to achieve or 

exceed the level of safety, the PIC will not begin a flight unless (considering wind and forecast weather 

conditions) there is enough power to conduct the intended operation and to operate after that for at 

least 5 minutes.
 Petition for Exemption SPARKTECH IMAGERY LLC

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14 C.F.R. § 91.405(A); 407 (A)(1); 409 (A) (1)&(2); 417(A)&(B): MAINTENANCE INSPECTIONS

Sparktech Imagery LLC operators and PIC will perform preventative and required maintenance on its 

UAS as required by the manufacturer and/or FAA safety/service bulletins. If a mechanical event occurs 

the UA will land immediately. The operator will make sure that the UAS is in an airworthy condition prior 

to each flight operation. The operator will perform maintenance on its UAS and will maintain thorough 

record keeping of any maintenance performed.

In order to meet or exceed level of safety as described in 14 C.F.R operations will include: 

Pre-flight operations: prior to each flight the PIC will conduct and preflight inspection of the UAS and 

Ground Control Station to ensure they are in such condition safe for flight. All discrepancies found 

during the preflight inspection will prohibit flight operations until the necessary maintenance has been 

performed and the UAS is found to be in a condition for safe flight. All discrepancies, maintenance, 

alterations will be properly documented in the aircraft records. 

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

characteristics there will be a functional flight test by the PIC and the PIC will make and entry in the 

aircraft records. All maintenance will follow the UAS manufacturer’s aircraft/component, maintenance, 

overhaul, replacement and inspection requirements.

Each UAS will comply with all manufacturers’ safety bulletins. 

The operator will carry out its maintenance, inspections, and record keeping requirements, in 

accordance with the manufacturers operating documents. All 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. 

Authorized persons will make entry in the aircraft record of corrective action taken against 

discrepancies discovered between inspections.

STATUTORY AUTHORITY FOR EXEMPTION

In accordance with the FMRA, Section 333 & 334 states that the Secretary of Transportation has the 

authority to grant which types of unmanned aircraft systems can be used in the national airspace 

system and whether a certificate of waiver, authorization or airworthiness is required for operation. 

Furthermore, subject to operating restrictions required by the FAA, facilitate the capability of public 

agencies to develop, test and operate unmanned aircraft systems. 

 Petition for Exemption SPARKTECH IMAGERY LLC

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APPENDIX

DJI is an industry leader in small UAS production. DJI UASs are loaded with ground breaking software 

enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can 

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

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

information to the PIC via the linked monitor (smart phone/tablet devices). The following are the 

technical specifications of the DJI UAS to be used by Sparktech Imagery LLC:

DJI Phantom 2 Vision+ Technical Specifications

AIRCRAFT

Supported Battery DJI 5200mAH Li-Po Battery

Weight (Battery & Propellers Included)

Recommended payload

Maximum payload

1242g (2lbs 11.8oz)

≤ 1300g

1350g

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

Max Yaw Angular Velocity 200o/s

Max Tiltable Angle 35o

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

Max Flight Speed 15m/s [29knots] (Not Recommended)

Motor Diagonal Length 350mm

3-AXIAL STABILIZED GIMBAL

Working current Static: 750mA; Dynamic: 900mA

Control Accuracy ±0.03°

Controllable Range Pitch: -90o -0o

Maximum Angular Speed Pitch: 90o/s

Max Tiltable Angle 35o

CAMERA

Operating Environment Temperature 0oC-40oC

Sensor size 1/2.3”

Effective Pixels 14 Megapixels

Resolution 4384 x 3288

HD Recording 1080p30 / 1080i60

Recording FOV 110o / 85o
 Petition for Exemption SPARKTECH IMAGERY LLC

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DJI Phantom 2 Vision+ Technical Specifications cont’d

REMOTE CONTROLLER

Operating Frequency 5.728GHz – 5.85GHz

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

FCC Compliance: 800m

Receiver Sensitivity (1%PER) -93dBm

Transmitting Power (EIRP) CE Compliance: 25mW; 

FCC Compliance: 100mW

Working Current / Voltage 120mA@3.7V

Battery 2000mAh rechargeable Li-Po battery

RANGE EXTENDER

Operating Frequency 2412MHz – 2462MHz

Communication Distance (open area) 500m – 700m

Transmitting power 20dBm

Power consumption 2W

The complete user manual for can be found: http://www.dji.com/product/phantom-2-vision/download

DJI Phantom 3 Professional Technical Specifications

AIRCRAFT

Weight (Battery & Propellers Included) 1280g (2lbs 13.1oz)

Max Ascent/Descent Speed Ascent: 5m/s; Descent: 3m/s

Max Speed 16m/s (ATTI mode, no wind)

Max Flight Altitude 6000m

Max Flight Time Approx. 23minutes

Operating Temperature 0oC - 40oC

GPS mode GPS/GLONASS

GIMBAL

Controllable Range Pitch: -90o to + 30o
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DJI Phantom 3 Professional Technical Specifications cont’d

VISION POSITIONING

Velocity Range < 8m/s (2m above ground)

Altitude Range 30cm – 300cm

Operating Range 30cm – 300cm

Operating Environment Brightly lit (lux > 15) pattern surfaces

CAMERA

Sensor Sony EXMOR 1/2.3” Effective pixels:12.4 M 

(total pixels: 12.76 M)

Lens FOV 94° 20mm (35mm format equivalent) 

f/2.8

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

Electronic Shutter Speed 8s -1/8000s

Image Max size 4000 x 3000

Still Photography Modes Single shot

Burst shooting: 3/5/7 frames

Auto Exposure Bracketing (AEB): 3/5 

Bracketed frames at 0.7EV 

Bias Time-lapse

Supported SD Card Types Micro SD

Max. capacity: 64 GB. Class 10 or UHS-1 

rating required

Video Recording Modes UHD : 4096x2160p 24/25, 

3840x2160p24/25/30 

FHD:1920x1080p 24/25/30/48/50/60 

HD:1280x720p 24/25/30/48/50/60

Max. Bitrate Of Video Storage 60 Mbps

Supported File Formats FAT32/exFAT

Photo: JPEG, DNG

Video: MP4/MOV (MPEG-4 AVC/H.264)

Operating Temperature Range 0°C to 40°C
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page 11

DJI Phantom 3 Professional Technical Specifications cont’d

REMOTE CONTROLLER

Operating Frequency 2.400 GHz-2.483 GHz

Transmitting Distance 2000 m (Outdoor And Unobstructed)

Video Output Port USB

Operating Temperature Range 0°C- 40°C

Battery 6000 mAh LiPo 2S

Mobile Device Holder Tablets and smartphones

Transmitter Power(EIRP) FCC: 20 dbm; CE:16 dbm

Working Voltage 1.2 A @7.4 V

CHARGER

Voltage 17.4 V

Rated Power 100 W

INTELLIGENT FLIGHT BATTERY 

( PH3-4480 MAH-15.2 V )

Capacity 4480 mAh

Voltage 15.2 V

Battery Type LiPo 4S

Energy 68 Wh

Net Weight 365 g

Operating Temperature -10°C- 40°C

Max. Charging Power 100 W

The complete user manual for can be found: http://www.dji.com/product/phantom-3/download
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page 12

DJI Phantom Inspire 1 Technical Specifications

AIRCRAFT

Model T600

Weight (Battery & Propellers Included) 2935g (approx.6lbs 8oz)

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

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

Max Tilt Angle 35°

Max Ascent/Descent Speed Ascent: 5m/s; Descent: 4m/s

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

Max Flight Altitude 4500m

Max Wind Speed Resistance 10 m/s

Max Flight Time Approx. 18minutes

Motor Model DJI 3510

Propeller Model DJI 1345

Indoor Hovering Enabled by default

Operating Temperature -10oC - 40oC

Diagonal Distance 559 to 581mm

Dimensions 438 x 451 x 301 mm

GIMBAL

Model ZENMUSE X3

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

Operating Current Station: 750 mA; Motion: 900 mA 

Detachable

Angular Vibration Range ±0.03°

Mounting Detachable

Controllable Range Pitch: -90o to + 30o

Pan: ±320o

Mechanical Range Pitch: -125° to +45° 

Pan: ±330°

Mac Controllable Speed Pitch: 120° /s

Pan: 180°/s
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page 13

DJI Phantom Inspire 1 Technical Specifications cont’d

CAMERA

Name X3

Model FC350

Total Pixels 12.76M

Effective Pixels 12.4M

Image Max Size 4000 x3000

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

Electronic Shutter Speed 8s -1/8000s

Field of View (FOV) 94o

CMOS Sony EXMOR 1/2.3” 

Lens 20mm (35mm format equivalent) f/2.8 

focus at ∞

9 Elements in 9 groups

Anti-distortion

Still Photography Modes Single shot

Burst shooting: 3/5/7 frames

Auto Exposure Bracketing (AEB): 3/5 

bracketed frames at 0.7EV 

Time-lapse

Video Recording Modes UHD (4K): 4096x2160p 24/25, 

3840x2160p24/25/30 

FHD:1920x1080p 24/25/30/48/50/60 

HD:1280x720p 24/25/30/48/50/60

Max. Bitrate Of Video Storage 60 Mbps

Supported File Formats FAT32/exFAT

Photo: JPEG, DNG

Video: MP4/MOV (MPEG-4 AVC/H.264)

Supported SD Card Types Micro SD

Max. capacity: 64 GB. Class 10 or UHS-1 

rating required

Operating Temperature Range 0°C to 40°C
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page 14

DJI Phantom Inspire 1 Technical Specifications cont’d

REMOTE CONTROLLER

Name C1

Operating Frequency 922.7MHz~927.7 MHz (Japan Only) 

5.725~5.825 GHz;2.400~2.483 GHz

Transmitting Distance 2km (Outdoor And Unobstructed)

EIRP 10dBM@900m, 13dBm@5.8G, 

20dMb@2.4G

Video Output Port USB, Mini-HDMI

Power Supply Built-in battery

Charging DJI Charger

Dual User Capacity Host-and-Slave connection

Mobile Device Holder Tablets or smartphones

Output Power 9W

Operating Temperature Range -10°C- 40°C

Storage Temperature Range Less than 3months: -20oC – 45oC

More than 3months: 22oC – 28oC

Charging Temperature Range 0oC-40oC

Battery 6000 mAh LiPo 2S

CHARGER

Model A14-100P1A

Voltage 26.3 V

Rated Power 100 W

BATTERY (STANDARD)

Name Intelligent Flight Battery

Model TB47

Capacity 4500 mAh

Voltage 22.2 V

Battery Type LiPo 6S high voltage battery

Energy 99.9 Wh

Net Weight 570 g

Operating Temperature -10°C- 40°C

Storage Temperature Less than 3months: -20oC – 45oC

More than 3months: 22oC – 28oC

Charging Temperature 0oC-40oC

Max. Charging Power 180 W
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page 15

DJI Phantom Inspire 1 Technical Specifications cont’d

BATTERY (OPTIONAL)

Name Intelligent Flight Battery

Model TB48

Capacity 5700 mAh

Voltage 22.8 V

Battery Type LiPo 6S

Energy 129.96 Wh

Net Weight 670 g

Operating Temperature -10°C- 40°C

Storage Temperature Less than 3months: -20oC – 45oC

More than 3months: 22oC – 28oC

Charging Temperature 0oC-40oC

Max. Charging Power 180 W

VISION POSITIONING

Velocity Range Below 8 m/s (2 m above ground)

Altitude Range 5-500 cm

Operating Environment Brightly lit (lux > 15) patterned surfaces

Operating Range 0-250 cm

DJI PILOT APP

Mobile Device System Requirements iOS version 7.1 or later; 

Android version 4.1.2 or later

Supported Mobile Devices * iPhone 6 Plus, iPhone 6, iPhone 5S, iPad 

Air 2, iPad Mini 3, iPad Air, iPad Mini 2, 

iPad 4;* Samsung Note 3, Samsung S5, 

Sony Z3 EXPERIA;

* Note: It is recommended that you use a 

tablet for the best experience

The complete user manual for can be found: http://www.dji.com/product/inspire-1/download