UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

Regulatory Docket No. 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

CDC LLC,

dba Computer Depot

Federal Employer ID #: 20-5874531

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 

14 OF THE CODE OF FEDERAL REGULATIONS

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

91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL

OPERATION OF DJI PHANTOM 3 PROFESSIONAL

UNMANNED AIRCRAFT SYSTEM 

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95)

Submitted on October 21, 2015

CDC LLC, dba Computer Depot

Thomas Carrington, President

984 Knaust Road

Cottleville, MO 63376

636-244-4902

thomas@officialcomputerdepot.com
2

TABLE OF CONTENTS

Page

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

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

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

BACKGROUND......................................................................................................................5

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

A. NAME AND ADDRESS OF PETITIONER....................................................................6

B. THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH, SCOTT PHOTO WORKS

SEEKS EXEMPTION ...............................................................................................7

C. THE EXTENT OF RELIEF SCOTT PHOTO WORKS SEEKS AND THE REASON

SCOTT PHOTO WORKS SEEKS THE RELIEF ............................................................10

D. THE REASONS WHY GRANTING SCOTT PHOTO WORKS’S REQUEST WOULD

BE IN THE PUBLIC INTEREST ...........................................................................................13

E. THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY

AFFECT SAFETY....................................................................................................................15

F. A SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER..............25 

G. ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO

SUPPORT SCOTT PHOTO WORKS' REQUEST..................................................................25

CONCLUSION........................................................................................................................26
3

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration 

FAR Federal Aviation Regulation 

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

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

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing
4

SUMMARY

CDC LLC, dba COMPUTER DEPOT, seeks exemption from the requirements of 

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

(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to 

Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption 

will permit COMPUTER DEPOT to operate an Unmanned Aircraft System (UAS) for the 

commercial purpose of conducting aerial video and photography of real estate properties, 

aerial surveying, and other special events, over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

My name is Thomas P. Carrington and I am the owner and president of CDC LLC, 

dba Computer Depot. My company provides photography services to the real estate market 

in St. Louis Missouri, in addition to aerial photography services for local construction

companies. We also provide similar services to various special events in the same area. 

The objective of Computer Depot’s aerial video and photography operations is to provide 

high quality imaging for a variety of commercial, public, and residential uses, specifically 

targeting:

• Real Estate Videography and Photography

• Special Event Videography and Photography

• Land survey & appraisals

• Construction sites before & after

• Agricultural Surveying
5

BACKGROUND

Unmanned Aircraft System: DJI Phantom 3 Professional UAS

COMPUTER DEPOT seeks an exemption to operate DJI systems for compensation or

hire within the NAS. The DJI Phantom 3 Professional is a vertical takeoff and landing 

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

electronic tablet or smart phone systems. The DJI Phantom 3 Professional 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. It 

is equipped with four main rotors; driven by Lithium Polymer battery powered electric 

motors. 

The DJI Phantom 3 Professional that will be operated by COMPUTER DEPOT will be

registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 

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

C.F.R. Part 45, Identification and Registration Marking.

BASIS FOR PETITION

Petitioner, COMPUTER DEPOT, pursuant to the provisions of the Federal Aviation

Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 

(FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, 

hereby petitions the Administrator to commercially operate the DJI Phantom 3 Professional 

UAS in the National Airspace System (NAS), and for an exemption from the 

requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a),

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

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

the unmanned aircraft and its operation, COMPUTER DEPOT operation of DJI Phantom 3

Professional UAS 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, COMPUTER DEPOT requests relief from Sections 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth 

requirements for maintenance that only apply to aircraft with an airworthiness certificate.

COMPUTER DEPOT submits that the requested relief is proper since an equivalent

level of safety will be ensured. COMPUTER DEPOT will use experienced personnel or

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

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

Monthly Maintenance Log, and DJI Phantom 3 Professional Instruction Manual). 

Furthermore, COMPUTER DEPOT will document and maintain all maintenance records for

the DJI Phantom 3 Professional UAS. 
6

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

privileges and limitations: Pilot in command, is requested by COMPUTER DEPOT to the

extent necessary to allow a Pilot in Command (PIC) holding a sport pilot or higher level 

certificate, as well as an airman medical certificate or valid U.S. drivers license, and who has 

demonstrated, by meeting minimum flight- hour and currency requirements, that the PIC is 

able to safely operate the DJI Phantom 3 Professional UAS in a manner consistent with this 

exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures.

COMPUTER DEPOT seeks relief from Section 91.7(a), entitled Civil aircraft

airworthiness, because the DJI Phantom 3 Professional UAS does not require an 

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

COMPUTER DEPOT submits that they will ensure that the DJI Phantom 3 Professional

UAS is in an airworthy condition, prior to every flight, by determining that the UAS is in 

compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 

3 Professional Instruction Manual), and that the aircraft is in a condition for safe flight.

COMPUTER DEPOT also seeks an exemption from the requirements of Section

91.121, entitled Altimeter Settings, as the DJI Phantom 3 Professional UAS will not have a 

typical barometric altimeter on-board. However, altitude information of the DJI Phantom 3

Professional UAS will be provided to the PIC via Global Positioning System (GPS) 

equipment and radio communications telemetry data link, which down-links from the UA to

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

COMPUTER DEPOT’s operation of the DJI Phantom 3 Professional UAS within visual line

of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, COMPUTER DEPOT seeks an exemption from the requirements of

Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. COMPUTER 

DEPOT submits that safety will not be affected by operation of the DJI Phantom 3

Professional UAS during daylight hours in visual meteorological conditions (VMC) under 

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

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, COMPUTER DEPOT provides the following

information in support of its petition for exemption:

A. Name And Address Of The Petitioner.

The name and address of the Petitioner and point of contact is:

Thomas Carrington

Computer Depot

984 Knaust Road

Cottleville, MO 63376

Tel: (636) 244-4902

Email: thomas@officialcomputerdepot.com
7

B. The Specific Sections Of 14 C.F.R. From Which COMPUTER DEPOT seeks

Exemption.

1. COMPUTER DEPOT Seeks Exemption From The Requirements Of

Section Part 21, Subpart H

14 C.F.R. Part 21, Subpart H, establishes the procedural requirements for the 

issuance of airworthiness certificates as required by 14 C.F.R. §91.203(a)(1) 

2. COMPUTER DEPOT Seeks Exemption From The Requirements Of

Section 61.113(a) And (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, 

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

(a) No person who holds a private pilot certificate may act as a pilot in command

(PIC) of an aircraft that is carrying passengers or property for compensation or

hire; nor may that person, for compensation or hire, act as PIC of an aircraft.

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

connection with any business or employment if—

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

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

hire.

(c) COMPUTER DEPOT 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.

4. COMPUTER DEPOT Seeks Exemption From The Requirements Of

Section 91.121.

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

part:

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

level of that aircraft, as the case may be, by reference to an altimeter that is set,

when operating--

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

(i) The current reported altimeter setting of a station along the route and

within 100 nautical miles of the aircraft;

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

this section, the current reported altimeter setting of an appropriate

available station; or

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

the departure airport or an appropriate altimeter setting available before

departure.
8

5. COMPUTER DEPOT Seeks Exemption From The Requirements Of

Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, 

subsection (b), states the following:

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

(considering wind and forecast weather conditions) there is enough fuel to fly to

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

after that for at least 20 minutes.

6. COMPUTER DEPOT Seeks Exemption From The Requirement Of Section

91.405(a).

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

following: Each owner or operator of an aircraft—

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

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

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

7. COMPUTER DEPOT Seeks Exemption From The Requirements Of

Section 91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

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

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

preventive maintenance, rebuilding, or alteration unless--

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

43.7 of this chapter[.]

(b) COMPUTER DEPOT Seeks Exemption From The Requirements Of

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

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

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

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

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

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

chapter; or

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

with part 21 of this chapter.

(b) COMPUTER DEPOT 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:
9

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each

registered owner or operator shall keep the following records for the periods

specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and

records of the 100-hour, annual, progressive, and other required or approved

inspections, as appropriate, for each aircraft (including the airframe) and

each engine, propeller, rotor, and appliance of an aircraft. The records must

include--

(i) A description (or reference to data acceptable to the Administrator) of

the work performed; and

(ii) The date of completion of the work performed; and

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

aircraft for return to service.

(2) Records containing the following information:

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

and each rotor.

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

propeller, rotor, and appliance.

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

are required to be overhauled on a specified time basis.

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

the last inspection required by the inspection program under which the

aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and

safety directives including, for each, the method of compliance, the

AD or safety directive number and revision date. If the AD or safety

directive involves recurring action, the time and date when the next

action is required.

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

major alteration to the airframe and currently installed engines, rotors,

propellers, and appliances.

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

prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained

until the work is repeated or superseded by other work or for 1 year after

the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall 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

of this chapter shall be retained until the defects are repaired and the

aircraft is approved for return to service.
10

C. The Extent Of Relief COMPUTER DEPOT Seeks And The Reason 

COMPUTER DEPOT Seeks The Relief.

1. COMPUTER DEPOT Seeks Exemption From The Requirements Of

Section Part 21, Subpart H 

Given the size and limited operating area associated with the UAS to be utilized by 

COMPUTER DEPOT, an exemption from Part 21 Subpart H meets the requirements 

of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. 

The Federal Aviation Act (49 U.S.C.§ 44701(f)) and Section 333 of the Reform Act 

both authorize the FAA to exempt aircraft from the requirement for an airworthiness 

certificate, upon consideration of the size, weight, speed, operational capability, and 

proximity to airports and populated areas of the particular UAS. 

In all cases, an analysis of these criteria demonstrates that the UAS operated without 

an airworthiness certificate, in the restricted environment and under the conditions 

proposed will be at least as safe, or safer, than a conventional rotorcraft operating with 

an airworthiness certificate without the restrictions and conditions of the proposed 

UAS operations. 

2. Extent Of Relief COMPUTER DEPOT Seeks And The Reason

COMPUTER DEPOT Seeks Relief From Section 61.113(a) And (b).

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

Pilot in command, is requested to the extent necessary to allow a PIC holding a private 

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

certificate, and who has met certain 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 any business or employment if: (1) The flight is only incidental to that 

business or employment; and (2) The aircraft does not carry passengers or property for 

compensation or hire.

As set forth more fully below, COMPUTER DEPOT submits that an equivalent level 

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

Phantom 3 Professional UAS unless that PIC has met certain flight-hour and currency 

requirements, demonstrating that the PIC is able to safely operate the DJI Phantom 3 

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, COMPUTER DEPOT submits that all flights of the DJI Phantom 3 

Professional UAS, conducted by the PIC pursuant to the grant of this Petition: (1) 

will be incidental to COMPUTER DEPOT' business; and (2) will not carry 

passengers or property for compensation or hire.
11

3. Extent Of Relief COMPUTER DEPOT Seeks And The Reason

COMPUTER DEPOT 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 COMPUTER DEPOT to determine that the DJI Phantom 3

Professional UAS is in airworthy condition prior to every flight by ensuring that the 

UAS is in compliance with the operating documents (i.e., the COMPUTER 

DEPOT Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3

Professional Instruction Manual).

COMPUTER DEPOT seeks the requested relief because the DJI Phantom 3

Professional UAS does not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H. Therefore, COMPUTER DEPOT will ensure that the DJI

Phantom 3 Professional UAS is in airworthy condition based upon its compliance with

the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3

Professional Instruction Manual) prior to every flight, and further, determine that the

aircraft is in condition for safe flight, as stated in the conditions and limitations below.

4. Extent Of Relief COMPUTER DEPOT Seeks And The Reason

COMPUTER DEPOT Seeks Relief From Section 91.121.

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

operations of the DJI Phantom 3 Professional UAS, which utilize a barometric pressure 

sensor, GPS equipment, and a radio communications telemetry data link to down link 

altitude information from the UAS 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), COMPUTER DEPOT

seeks the requested relief because the DJI Phantom 3 Professional UAS’s altimeter may 

be set on the ground to zero feet AGL, rather than the local barometric pressure or field 

altitude, before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 

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

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

be maintained since the DJI Phantom 3 Professional UAS is equipped with a barometric 

pressure sensor and GPS equipment, which automatically ensures that a ground level 

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

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

5. Extent Of Relief COMPUTER DEPOT Seeks And The Reason COMPUTER

DEPOT Seeks Relief From Section 91.151(b).

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

requested to the extent required to allow flights of the battery powered DJI Phantom 3 

Professional UAS during daylight hours in visual meteorological conditions (VMC), 

under visual flight rules (VFR), for a total duration of 13.5 minutes to the first point of 
12

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

minutes. COMPUTER DEPOT seeks the requested relief because without an exemption

from Section 91.151(b), the flight time duration of the battery powered DJI Phantom 3 

Professional UAS will severely constrain the practicality of any aerial 

video or still photo flight operations that COMPUTER DEPOT proposes to conduct

pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the DJI Phantom 3 

Professional UAS, the DJI Phantom 3 Professional operating documents, and 

COMPUTER DEPOT' proposed operating limitations, ensure that COMPUTER 

DEPOT will safely operate the battery powered DJI Phantom 3 Professional UAS during

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

(VFR), with enough battery power to fly for a total duration of 13.5 minutes to the first 

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

least 4.5 minutes.

6. Extent Of Relief COMPUTER DEPOT Seeks And The Reason

COMPUTER DEPOT Seeks Relief From Sections 91.405(a),

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

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only 

apply to aircraft with an airworthiness certificate, COMPUTER DEPOT requests relief

from these Sections because the DJI Phantom 3 Professional UAS does not require 

airworthiness certificates. As set forth more fully below, the DJI Phantom 3 Professional 

UAS meets the conditions of FMRA Section 333 for operation without an airworthiness 

certificate. Accordingly, COMPUTER DEPOT will use trained technicians to perform

maintenance, alterations, or preventive maintenance on the UAS using the methods, 

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

COMPUTER DEPOT Aerial Operations Manual, Monthly Maintenance Log, and DJI

Phantom 3 Professional Instruction Manual). Furthermore, COMPUTER DEPOT will

document and maintain all maintenance records for the DJI Phantom 3 Professional

UAS. 
13

D. The Reasons Why Granting COMPUTER DEPOT' Request Would Be In The Public 

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

Granting the present Petition will further the public interest by allowing COMPUTER DEPOT

to safely, efficiently, and economically perform aerial video and photography of, real estate, 

special events, agriculture, land survey & appraisal, and construction sites over certain areas of 

the United States.

Additionally, use of the DJI Phantom 3 Professional UAS will decrease congestion of the 

NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits 

of COMPUTER DEPOT’ proposed operation of the DJI Phantom 3 Professional UAS will be 

realized without implicating any privacy issues.

1. The Public Will Benefit From Decreased Congestion Of The NAS.

The DJI Phantom 3 Professional UAS is battery powered and serves as a safe, efficient, 

and economical alternative to the manned aircraft traditionally utilized to obtain aerial 

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

acquisitions, an exemption allowing the use of a DJI Phantom 3 Professional UAS

would reduce the amount of manned aircraft in the NAS, reduce noise and air 

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

ground.

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

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

The DJI Phantom 3 Professional UAS does not require an airport to takeoff or land.

Likewise, a reduction of manned aircraft conducting aerial video and photography 

missions would result in fewer aircraft that must be handled by air traffic control 

during the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 3

Professional UAS.

Conducting aerial acquisitions with the DJI Phantom 3 Professional UAS, instead of 

manned aircraft, will greatly benefit the public by drastically reducing the levels of air 

and noise pollution generated during traditional aerial video and still photography flight 

operations. By using battery power and electric motors, the DJI Phantom 3 Professional 

UAS produces no air pollution, and is the most viable environmentally conscious 

alternative to the cabin class, six cylinder internal combustion engine aircraft that are 

typically utilized for aerial video and photography, while burning approximately 20-30 

gallons per hour of leaded aviation fuel. The DJI Phantom 3 Professional UAS, while 

reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as 

the UAS is propelled by battery powered electric motors, rather than an internal 

combustion engine. 

By using the DJI Phantom 3 Professional UAS to perform aerial acquisitions, the 

substantial risk to life and property in the air and on the ground, which is usually 

associated with traditional manned aircraft flight operations, will be substantially 
14

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

on-board the aircraft, the DJI Phantom 3 Professional UAS (weighing approximately 2

pounds 13 ounces including battery with a length & width of 16 inches), has less 

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

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

approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 

34 feet, and a fuel capacity of 180 gallons).

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

Vision+ and DJI Inspire 1 UAS Will Benefit The Economy.

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

UAS is also an economical alternative to using manned aircraft to conduct similar aerial 

operations. As such, operation of the DJI Phantom 3 Professional

UAS will allow United States based companies, like COMPUTER DEPOT, to remain

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

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

actions phasing out leaded aviation fuels, U.S. owned and operated companies must 

adopt new and alternative technology in order to remain competitive. Operating the 

battery powered DJI Phantom 3 Professional UAS is one such technology that not only 

allows companies greater operational flexibility compared to manned aircraft, but 

provides such flexibility without the high operational cost of a traditional manned 

aircraft.

By operating the DJI Phantom 3 Professional UAS, companies such as COMPUTER 

DEPOT, can remain competitive and profitable, and therefore, provide greater job

stability to employees and contractors, which will ultimately contribute to growth of the 

U.S. economy. Improved financial performance of U.S. companies, through commercial 

use of the DJI Phantom 3 Professional UAS, provides a stable workforce that increases 

consumer spending; improves local, state, and federal tax revenues; and allows 

companies to invest in research and development in order to remain competitive both in 

the United States and abroad.

4. There Are No Privacy Issues.

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

for decades, COMPUTER DEPOT’ proposed operation of the DJI Phantom 3

Professional UAS will not implicate any privacy issues. Specifically, the DJI 

Phantom 3 Professional UAS will be operated only in compliance with operating 

documents (i.e., the COMPUTER DEPOT Aerial Operations Manual, Monthly

Maintenance Log, and DJI Phantom 3 Professional Instruction Manual) which 

requires property owner involvement as well as local law enforcement notification, and 

in accordance with the Federal Aviation Regulations, including the minimum altitude 

requirements of 14 C.F.R. § 91.119. 
15

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

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

Provided By The Rule From Which COMPUTER DEPOT Seeks Exemption.

1. Reasons Why The DJI Phantom 3 Professional UAS Meets The

Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section

333.

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

the unmanned aircraft and its operation, COMPUTER DEPOT’ operation of the DJI

Phantom 3 Professional UAS meets the conditions of FMRA Section 333, and will not 

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

Section 333 provides authority for a UAS to operate without airworthiness 

certification and sets forth requirements for considering whether a UAS will create a 

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

security. Specifically, FMRA Section 333 states the following, in part:

(a) In General.--Notwithstanding any other requirement of this subtitle, and

not later than 180 days after the date of enactment of this Act, the Secretary of

Transportation shall determine if certain unmanned aircraft systems may

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

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

by section 334 of this Act.

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

determination under subsection (a), the Secretary shall determine, at a

minimum--

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

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

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

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

threat to national security; and

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

airworthiness certification under section 44704 of title 49, United

States Code, is required for the operation of unmanned aircraft

systems identified under paragraph (1).

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

section that certain unmanned aircraft systems may operate safely in the

national airspace system, the Secretary shall establish requirements for the

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

In seeking this exemption, COMPUTER DEPOT submits that the DJI Phantom 3

Professional UAS can operate safely in the NAS pursuant to FMRA Section 333, as 

demonstrated by: (a) the characteristics of the DJI Phantom 3 Professional

UAS; (b) the pilot certification requirement; and (c) the specific operating limitations. 
16

a. The Specifications Of The DJI Phantom 3 Professional UAS Demonstrate

Its Safe Characteristics.

The DJI Phantom 3 Professional UAS does not create a hazard to users of

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

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

i. Technical Specifications Of The DJI Phantom 3 Professional

UAS. The technical specifications of the DJI Phantom 3 Professional

UAS are set forth by the DJI Phantom 3 Professional Specifications

Sheet, attached hereto as Exhibit A.

ii. The DJI Phantom 3 Professional UAS Autonomous Flight

And Navigation Modes Enable The UAS To Remain Within A

Defined Operational Area.

The DJI Phantom 3 Professional UAS may be operated in both manual

and

fully autonomous flight modes. A complete description of the flight

and navigational modes of the DJI Phantom 3 Professional UAS are

provided at pages 11 and 26 of the DJI Phantom 3 Professional User

Manual, attached hereto as Exhibit B.

iii. The DJI Phantom 3 Professional UAS Is Designed For

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

Of The Control Link Or Navigation.

When the Control Link is lost, the DJI Phantom 3 Professional UAS

will remain stationary, in flight, for 3 seconds or more. If, after 3

seconds, the DJI Phantom 3 Professional UAS does not reacquire

control link data from the GCS, the UAS will assume that the Control

Link is lost and the UAS will return to the home position

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

shutdown. A complete description of the Failsafe Functions for the DJI

Phantom 3 Professional UAS are set forth on page 14 of the DJI Phantom

3 Professional User Manual attached hereto as Exhibit B.

iv. The DJI Phantom 3 Professional GCS And Its Operation.

A complete description of the operation and specifications of the DJI

Phantom 3 Professional GCS and flight control software is provided at

pages 22 through 29 of the DJI Phantom 3 Professional User Manual

attached hereto as Exhibits B.

b. Flight Operations Of DJI Phantom 3 Professional UAS Is Limited To

The Line Of Sight Of A Certificated Pilot in Command With A Safety

Observer.

COMPUTER DEPOT 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 3 Professional UAS. Additionally, a safety observer will assist all pilots 

during flight time.
17

c. Flights Of DJI Phantom 3 Professional UAS Will Be Conducted

Pursuant To Specific Operating Limitations.

In seeking this exemption, COMPUTER DEPOT proposes to

commercially operate DJI Phantom 3 Professional UAS 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 UAS

weighing less than 55 pounds maximum gross weight: DJI Phantom 3

Professional Unmanned Aircraft System. 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 31 knots.

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

ground level (AGL), as indicated by the procedures specified in the operating

documents unless a special request is made and approved by ATC. All

altitudes reported to ATC must be in feet AGL.

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

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

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

airman medical certificate.

6. All operations must utilize a safety observer (SO). The SO may be used to

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

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

Electronic messaging or texting is not permitted during flight operations. The

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

designation for the duration of the flight. The PIC must ensure that the SO can

perform the functions prescribed in the operating documents.

7. The SO must not perform any other duties beyond assisting the PIC with

seeing and avoiding other air traffic and other ground based

obstacles/obstructions and is not permitted to operate the camera or other

instruments.

8. The operating documents and the grant of exemption must be accessible

during UAS operations and made available to the Administrator upon request. If

a discrepancy exists between the conditions and limitations contained in the grant

of exemption and the procedures outlined in the operating documents, the

conditions and limitations contained in the grant of exemption take precedence
18

and must be followed. Otherwise, the operator must follow the procedures as 

outlined in its operating documents. The operator may update or revise its 

operating documents. It is the operator’s responsibility to track such revisions 

and present updated and revised documents to the Administrator upon request. 

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

extension or amendment to the grant of exemption. If the operator determines 

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

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

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

questions arise regarding updates or revisions to the operating documents.

9. Prior to each flight the PIC must inspect the UAS to ensure that it is in a

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

discrepancies, e.g. inoperable components, items, or equipment, not already

covered in the relevant sections of the operating documents. If the inspection

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

prohibited from operating until the necessary maintenance has been performed

and the UAS is found to be in a condition for safe flight. The Ground Control

Station must be included in the preflight inspection. The PIC will make an entry

in the aircraft record of the corrective action taken against discrepancies

discovered between inspections.

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

UAS operation or flight characteristics, e.g. replacement of a flight critical

component, must undergo a functional test flight. The functional test flight must

be conducted in such a manner so as to not pose an undue hazard to persons and

property.

11. The operator must follow the UAS manufacturer’s aircraft/component,

maintenance, overhaul, replacement, inspection, and life limit requirements.

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

manufacturer Safety Bulletins.

13. The 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.

14. The operator may not permit any PIC to operate unless the PIC meets

the operator’s qualification criteria and demonstrates the ability to safely operate

the UAS in a manner consistent with how the UAS will be operated under the

exemption, including evasive and emergency maneuvers and maintaining

appropriate distances from persons, vessels, vehicles and
19

structures. PIC qualification flight hours must be logged in a manner 

consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the 

operator’s PICs are permitted under the terms of the exemption. However, 

training operations may only be conducted during dedicated training 

sessions. During training, proficiency, and experience-building flights, all 

persons not essential for flight operations are considered nonparticipants, 

and the PIC must operate the UA with appropriate distance from 

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

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

§ 1.1. All operations must be conducted under visual meteorological conditions

(VMC). If flight at night is required, a special request will be made at the FAA

office closest to proposed area of operations. Flights under special visual flight

rules (SVFR) are not authorized.

16. The UAS 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 notdenoted 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. The

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 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.

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 power to fly at normal cruising

speed to the intended landing point and land the UA with 25% battery power

remaining.

21. The operator must obtain an Air Traffic Organization (ATO) issued

Certificate of Waiver or Authorization (COA) prior to conducting any

operations under the grant of exemption. All operations shall be conducted in

accordance with the ATO-issued COA.

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

serial number, registered in accordance with 14 C.F.R. part 47, and have
20

identification (N- Number) markings in accordance with 14 C.F.R. 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 C.F.R. 91.9 and 91.203 must

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

UAS is operating. These documents must be made available to the

Administrator or any law enforcement official upon request.

24. The UA must remain clear and yield the right of 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. Flight operations must be conducted at least 500 feet from all

nonparticipating persons, vessels, vehicles, and structures unless (The PIC,

VO, operator trainees or essential persons are not considered nonparticipating

persons):

a. Barriers or structures are present that sufficiently protect nonparticipating

persons from

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

that nonparticipating persons remain under such protection. If a situation

arises where nonparticipating persons leave such protection and are within

500 feet of the UA, flight operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the

owner/controller of such vessels, vehicles or structures has granted permission

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, 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).

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

with permission from the land owner/controller or authorized representative.

Permission from land owner/controller or authorized representative will be

obtained for each flight to be conducted.

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.
21

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

(b) Would Not Adversely Affect Safety.

COMPUTER DEPOT submits that the equivalent level of safety established by

Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate 

the DJI Phantom 3 Professional UAS unless that PIC has demonstrated, by meeting 

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

the DJI Phantom 3 Professional UAS in a manner consistent with the exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from 

people, vessels, vehicles and structures.

Considering COMPUTER DEPOT’ proposed area of operations, and the

operating limitations set forth-above; the parallel nature of FAA-certified pilot 

aeronautical knowledge requirements to those of commercial pilot requirements (See 

Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI 

Phantom 3 Professional UAS, COMPUTER DEPOT submits that the additional manned

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

airmanship skills necessary for COMPUTER DEPOT’ specific proposed flight

operations.

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

UAS, in circumstances similar, in all material respects, to those presented herein 

(e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110,

11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

COMPUTER DEPOT will not allow any PIC to operate the DJI Phantom 3

Professional UAS unless that PIC has demonstrated that the PIC is able to safely operate 

the DJI Phantom 3 Professional UAS in a manner consistent with this exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from 

people, vessels, vehicles and structures.

Specifically, the the PIC must have accumulated and logged, in a manner 

consistent with 14 CFR 61.51(b), a minimum of 25 hours of total time as a UAS 

rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor UAS 

(with a minimum of 5 hours of those hours as a UAS pilot operating the same make and 

model of UAS to be used for operations under the exemption). In addition to the hour

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

(for currency purposes). 

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

Not Adversely Affect Safety.

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

because prior to every flight, COMPUTER DEPOT will ensure that the DJI Phantom 3

Professional UAS is in an airworthy condition based upon the UAS'
22

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

limitations herein.

Additionally, the FAA has previously granted relief from Section 91.7(a) 

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

herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 

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

11160, 11161).

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would

Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained 

because the altitude information of the DJI Phantom 3 Professional UAS will be 

provided to the PIC via GPS equipment and a radio communications telemetry data 

link, which down links from the UA to the GCS for active monitoring of the flight path 

and altitude. This altitude information, combined with COMPUTER DEPOT’

operation of the DJI Phantom 3 Professional UAS within visual line of sight, at or 

below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121. The 

altitude information will be generated by GPS equipment installed on-board the 

aircraft. Prior to each flight, a zero altitude initiation point is automatically established 

by the UAS at ground level.

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

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

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

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

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

Would Not Adversely Affect Safety.

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

by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJI 

Phantom 3 Professional UAS; (2) the limitations on the proposed flight operations; and 

(3) the location of the proposed flight operations. Accordingly, COMPUTER DEPOT

will ensure that it will safely operate the battery powered DJI Phantom 3 Professional 

UAS during daylight hours in VFR conditions, with enough battery power to fly for a 

total duration of 13.5 minutes to the first point of intended landing and, assuming 

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

Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom

3 Professional UAS; the limitations on the proposed flight operations; and

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

established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the 

DJI Phantom 3 Professional UAS provides audible and visual warnings to the PIC at 

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

approximately 33% remaining battery power, and again at approximately
23

10% remaining battery power. At the critically low battery level, the DJI Phantom 3 

Professional UAS will descend and land automatically.

Significantly, previous exemptions granted by the FAA concerning Section

91.151 establish that safety is not adversely affected when the technical characteristics

and operating limitations of the UAS are considered. Relief has been granted for 

manned aircraft to operate at less than the minimums prescribed in Section 91.151, 

including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously 

granted

relief from Section 91.151 specific to UAS, in circumstances similar, in all material

respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042,

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 

11150,

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

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

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

Affect Safety.

In seeking this exemption, COMPUTER DEPOT submits that the equivalent

level of safety with regard to the regulatory maintenance and alteration requirements 

established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & 

(b) will be met because COMPUTER DEPOT will use trained technicians to perform

maintenance, alterations, or preventive maintenance on the UAS using the methods,

techniques, and practices prescribed in the operating documents (i.e., the COMPUTER

DEPOT Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3

Professional Instruction Manual). Furthermore, COMPUTER DEPOT will document

and maintain all maintenance records for the DJI Phantom 3 Professional UAS.

Since the DJI Phantom 3 Professional UAS will be inspected as prescribed by 

the operating documents, COMPUTER DEPOT will maintain the equivalent level of

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

DJI Phantom 3 Professional User Manual is attached hereto as Exhibit B; a copy of the 

DJI Phantom 3 Professional UAS Maintenance LOG is attached hereto as Exhibit C.

Likewise, the exemption sought will not adversely affect safety because 

COMPUTER DEPOT will use trained technicians to perform maintenance, alterations

or preventive maintenance on the UAS using the methods, techniques, and practices 

prescribed by the operating documents.

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

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

DJI Phantom 3 Professional UAS will be performed by trained technicians. Maintenance 

will be documented and maintained utilizing the monthly maintenance log.

Significantly, previous exemptions granted by the FAA concerning Sections
24

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

safety is not adversely affected when the technical characteristics and operating 

limitations of the UAS are considered.

In consideration of COMPUTER DEPOT’ proposed operating limitations, the

operating documents, and the technical aspects of the DJI Phantom 3 Professional UAS, 

COMPUTER DEPOT submits that safety will not be adversely affected by granting

exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), 

and 91.417(a) and (b). The FAA has previously granted relief specific 

to UAS in circumstances similar, in all material respects, to those presented herein 

(e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 

11110,

11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

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

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

2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, COMPUTER DEPOT

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

Phantom 3 Professional UAS, which contain such safety standards that the 

Administrator finds necessary to establish a level of safety equivalent to that established 

by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121,

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

special conditions will permit safe operation of the UAS for the limited purpose of 

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

compensation or hire. FMRA Section 333 sets forth the requirements for considering 

whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose 

a threat to national security; and further, provides the authority for such UAS to operate 

without airworthiness certification in accordance with any requirements that must be 

established for the safe operation of the UAS in the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14

C.F.R. § 21.16, for operation of the DJI Phantom 3 Professional UAS, since the

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

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

21.16, entitled Special Conditions, states the following:

If the FAA finds that the airworthiness regulations of this sub-chapter do not contain

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

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

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

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

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

establish a level of safety equivalent to that established in the regulations. See 14

C.F.R. § 21.16.

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

prescribe special conditions for COMPUTER DEPOT' intended operation of the DJI

Phantom 3 Professional UAS, which contain such safety standards that the
Conclusion. 

As set forth herein, COMPUTER DEPOT seeks an exemption pursuant to 14 C.F.R. 

§ 11.61 and Section 333 of the FAA Modernization and Reform Act of2012 (FMRA), which

will permit safe operation of the OJI Phantom 3 Professional UAS commercially, without an

airworthines8- certificate, for the limited purpose of conducting aerial video and photography

over certain areas of the United States. By granting this Petition, the FAA Administrator will

be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012,

while also advancing the interests of the public, by allowing COMPUTER DEPOT to safely,

efficiently, and economically operate the OJI Phantom 3 Professional UAS commercially

within the NAS.

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

Modernization and Reform Act of 2012, Section 333, COMPUTER DEPOT respectfully

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

14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.15l(b), 91.405(a), 91.407(a)(l),

91.409(a)(l) & (a)(2), and 91.417(a) & (b), and permit COMPUTER DEPOT to operate the

OJI Phantom 3 Professional UAS commercially for the purpose of conducting aerial video

and photography over certain areas of the United States.

Dated: October 25, 2015 

Respectfully submitted, 

.Thomas Carrington, President 

CDC LLC, dba COMPUTER DEPOT 

984 Knaust Road 

Cottleville, MO 63376 

Tel: 636-244-4902 

Email: thomas@of f icialcomputerdepot.com 

Appendices: 

A -- OJI Phantom 3 Professional Specifications 

B -- OJI Phantom 3 Professional User Manual 

C -- OJI Phantom 3 Professional Maintenance Log 
25

Administrator finds necessary to establish a level of safety equivalent to that established

by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 

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

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

The Rules From Which COMPUTER DEPOT Seeks Exemption: 

COMPUTER DEPOT seeks exemption from the requirements of 14 C.F.R Sections

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

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

A Brief Description Of The Nature Of The Exemption COMPUTER DEPOT

Seeks:

This exemption will permit COMPUTER DEPOT to commercially operate an 

Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and 

photography over certain areas of the United States. 

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

COMPUTER DEPOT’ Request.

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

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

operate safely in the NAS. As such, COMPUTER DEPOT’ request for exemption may be 

granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth 

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

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

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

certification. As discussed in detail above, COMPUTER DEPOT will operate the DJI 

Phantom 3 Professional UAS safely in the NAS, without creating a hazard to users of the 

NAS, or the public, or otherwise pose a threat to national security. 
27

APPENDIX – A

DJI PHANTOM 3 PROFESSIONAL TECHNICAL SPECIFICATIONS

COMPUTER DEPOT only utilizes safe and reliable UAS. DJI is an industry leader in small 

UAS production. DJI UAS 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)

Aircraft

Weight (Including Battery And Propellers) 1280 g

Diagonal Size (Including Propellers) 590 mm 

Max Ascent Speed 5 m/s 

Max Descent Speed 3 m/s 

Hover Accuracy 

Vertical: +/- 0.1 m (when Vision Positioning is active) or +/- 0.5 m 

Horizontal: +/- 1.5 m 

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

Max Altitude Above Sea Level 6000 m 

Operating Temperature 0°C to 40°C 

GPS Mode GPS/GLONASS 

Gimbal

Controllable Range Pitch -90° to +30° 

Stabilization 3-axis (pitch, roll, yaw)

Remote Controller

Operating Frequency 2.400 GHz-2.483 GHz 

Max Distance 2000m (outdoors and unobstructed) 

Video Output Port USB 

Operating Temperature 0°C- 40°C 

Battery 6000 mAh LiPo 2S 

Receiver Sensitivity (1%PER) -101 dBm ±2 dBm

Transmitter Power (EIRP) 

FCC: 20 dBm 

CE: 16 dBm 

Working Voltage 1.2 A @7.4 V 

Battery Charger

Voltage 17.4 V 

Rated Power 100 W 

Phantom 3 Advanced 

Intelligent Flight Battery

Capacity 4480 mAh

Voltage 15.2 V 
28

Battery Type LiPo 4S 

Energy 68 Wh 

Net Weight 365 g

Max Flight Time Approximately 23 minutes 

Operating Temperature -10°C to 40°C

Max Charging Power 100 W
29

APPENDIX – B

DJI PHANTOM 3 PROFESSIONAL 

Manufacturer’s User Manual

User manual can be found at: 

http://www.dji.com/product/phantom-3/download 
30

APPENDIX - C

MONTHLY MAINTENANCE LOG

month: year: _________

UAS:

Date Issue

Discovered

Date Issue

Addressed

Issue Description &

Maintenance conducted

Maintenance Performed By: 

(Print & Sign)

Software

Updates

Airframe

Engines

Propellers

Camera

Gimbal

Landing Gear

Vibration

Dampening

Other: