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D-Drones LLC

UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL 

AVIATION ADMINISTRATION

WASHINGTON, DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

D-Drones LLC

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 PHANTHOM 3 PROFESSIONAL & DJI PHANTOM 2 VISION+

UNMANNED AIRCRAFT SYSTEMS 

PURSUANT TO SECTION 333 OF 

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

D-Drones LLC

185 Bricknell Ln.

Coppell, TX 75019

Ph: 469-233-4694
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TABLE OF CONTENTS

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

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

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

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

A. NAME AND ADDRESS OF THE PETITIONER ............................................................................................................................................................7

B. THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH D-DRONES LLC SEEKS EXEMPTION .........................................................7

C. THE EXTENT OF RELIEF D-DRONES LLC SEEKS AND THE REASON D-DRONES LLC SEEKS THE RELIEF................................ 10

D. THE REASONS WHY GRANTING D-DRONES LLC REQUEST WOULD BE IN THE INTEREST; THAT IS, HOW IT WOULD 

BENEFIT THE PUBLIC AS A WHOLE................................................................................................................................................................................... 13

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 

D-DRONES LLC SEEKS EXEMPTION ................................................................................................................................................................................. 15

F. A SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER STATING: THE RULES FROM WHICH D-DRONES 

LLC SEEKS EXEMPTION ........................................................................................................................................................................................................... 25

G. ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT D-DRONES LLC'S REQUEST

.............................................................................................................................................................................................................................................................. 25

H. IF YOU WANT TO EXERCISE THE PRIVILEGES OF YOUR EXEMPTION OUTSIDE THE UNITED STATES, THE REASON 

WHY YOU NEED TO DO SO................................................................................................................................................................................................. 25

CONCLUSION.............................................................................................................................................................................................................................. 26

APPENDIX....................................................................................................................................................................................................................................... 27
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GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest 

ATC Air Traffic Control 

ATO Air Traffic Organization

AV Aerial Vehicle 

CFR Code of Federal Regulations 

COA Certificate Of Authorization

DJI2+ DJI Phantom 2 Vision+

DJI3P DJI Phantom 3 Professional

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station 

GPS Global Positioning System

LOL Loss Of Link 

NAS National Airspace System

NOTAM Notice To Airman

PIC Pilot In Command

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

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft 

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line Of Site 

VMC Visual Meteorological Conditions

VTOL Vertical Take-Off and Landing
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SUMMARY

D-Drones LLC 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 to operate an Unmanned Aircraft System (UAS) for the 

commercial purpose of conducting aerial video and photography of construction sites, real estate 

and landscape over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

D-Drones LLC provides his clients with expertise and knowledge in advanced photography and 

video solutions to increase efficiency, productivity and effectiveness. D-Drones LLC has over 9 years 

of experience in Photography and Video Technology. He has over 5 years recreational and hobby 

experience in all aspects of aerial video and photography.

The objective of D-Drones LLC’s aerial video and photography operations is to provide high quality 

imaging for a variety of commercial, public and residential uses specifically targeting:

• Construction sites before, after and during the different phases

• Appraisals Real-estate & marketing/advertising

• Aerial acquisitions used for inspections of public and private structures. 

• Search and Rescue operations 

• Flood prevention/monitoring
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BACKGROUND

Unmaned Aircraft Systems: DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P) UAS's 

D-Drones LLC seeks an exemption to operate DJI2+ & DJI3P systems for compensation or hire within 

the NAS. The DJI2+ and DJI3P are vertical take off and landing (VTOL) Unmanned Aircraft (UA) with 

a Ground Control Station (GCS) Utilizing a 2.4Ghz Remote Control system.

The DJI2+ has a maximum gross weight (including Battery, Camera and Propellers) of approximately 

2 pounds 12 ounces, while having a width of 11.2 inches and a height of 7 inches, and a maximum 

speed of approximately 5 m/s.

The DJI3P has a maximum gross weight (including Battery, Camera and Propellers) of 2 pounds 13

ounces, a length of 12.3 inches, width of 11.5 inches, height of 7.1 inches, and a maximum speed 

of Approximately 5 m/s. 

Both units are equipped with 4 main rotors utilizing Lithium Polymer batteries to power the electric 

motors. Both units has also GPS and intelligent safety landing sensors to prevent any accidents and 

ensure safety flights during operations, detecting any malfunctions, battery problems and returning 

automatically to the safety take-off/landing location. Their maximum time on air is approx. 15

minutes.

The DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P) UAS's that will be operated 

by D-Drones LLC 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, D-Drones LLC , pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 

11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for 

Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate the 

DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P) UAS's 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, D-Drones LLC’s operation of DJI Phantom 2 Vision+ (DJI2+) & 

DJI Phantom 3 Professional (DJI3P) UAS's 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, D-Drones LLC 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. 
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D-Drones LLC submits that the requested relief is proper since an equivalent level of safety will be 

ensured. D-Drones LLC will use experienced personnel or technicians to perform maintenance, 

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

prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 Vision+ 

(DJI2+) & DJI Phantom 3 Professional (DJI3P) Instruction Manual). 

Furthermore, D-Drones LLC will document and maintain all maintenance records for the DJI 

Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P) UAS's. 

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

limitations: Pilot in command, is requested by D-Drones LLC to the extent necessary to allow a Pilot in 

Command (PIC) holding a private pilot or higher level certificate, as well as an airman medical 

certificate, and who has demonstrated, by meeting minimum flight- hour and current requirements, 

that the PIC is able to safely operate the DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional

(DJI3P) UAS's in a manner consistent with this exemption, including evasive and emergency 

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

D-Drones LLC seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the DJI 

Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P) UAS's do not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, D-Drones LLC submits that he will 

ensure that the DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P) UAS's are in an 

airworthy condition, prior to every flight, by determining that the UAS's are in compliance with the 

operating documents (i.e., Monthly Maintenance Log, DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 

3 Professional (DJI3P) Instruction Manual), and that the aircraft are in a condition for safe flight. DDrones LLC also seeks an exemption from the requirements of Section 91.121, entitled Altimeter 

Settings, as the DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P) UAS's will not have 

a typical barometric altimeter onboard. However, altitude information of the DJI Phantom 2 Vision+ 

(DJI2+) & DJI Phantom 3 Professional (DJI3P) UAS's will be provided to the PIC via Global Positioning 

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

UAS to the GCS for active monitoring of the flight path. This altitude information, combined with DDrones LLC’s operation of the DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P) 

UAS's within visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to 

Section 91.121. 

Additionally, D-Drones LLC seeks an exemption from the requirements of Section 91.151(b), entitled 

Fuel requirements for flight in VFR conditions. D-Drones LLC submits that safety will not be affected by 

operation of the DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P) UAS's 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 10 minutes for the intended photo shoot 

and, assuming normal cruising speed, to fly after that for at least 2.5 minutes for recovery and 

landing. 
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In accordance with 14 C.F.R. § 11.81, D-Drones LLC 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: 

D-Drones LLC

185 Bricknell Ln. Coppell, Texas 75019 

Ph. 469-233-4694

Email: rolomeli@d-drones.com

B. The Specific Sections Of 14 C.F.R. From Which D-Drones LLC seeks Exemption 

1. D-Drones LLC Seeks Exemption From The Requirements Of 

 Section 61.113(a) And (b). 

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

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

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

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

for compensation or hire, act as PIC of an aircraft. 

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

any business or employment if—

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

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

2 D-Drones LLC 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. 

3. D-Drones LLC Seeks Exemption From The Requirements Of Section 91.121. 

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: 
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(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that 

aircraft, as the case may be, by reference to an altimeter that is set, when operating--

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

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

100 nautical miles of the aircraft; 

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

section, the current reported altimeter setting of an appropriate available 

station ;or 

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

departure airport or an appropriate altimeter setting available before 

departure. 

4. D-Drones LLC Seeks Exemption From The Requirements Of Section91.151(b). 

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

following: 

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

and forecast weather conditions) there is enough fuel to fly to the first point of intended 

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

5. D-Drones LLC Seeks Exemption From The Requirement Of Section91.405(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[.] 

6. D-Drones LLC 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. 
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7. D-Drones LLC Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 

91.409(a)(2). 

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

provided in paragraph (c) of this section, no person may operate an aircraft unless, within the 

preceding 12 calendar months, it has had --

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

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

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

part 21 of this chapter. 

8. D-Drones LLC Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b). 

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following: 

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

owner or operator shall keep the following records for the periods specified in paragraph (b) 

of this section: 

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

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

appropriate, for each aircraft (including the airframe) and each engine, propeller, 

rotor, and appliance of an aircraft. The records must include--

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

work performed; and 

(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 
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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. 

C. The Extent Of Relief D-Drones LLC Seeks And The Reason D-Drones LLC Seeks The Relief. 

1. Extent Of Relief D-Drones LLC Seeks And The Reason D-Drones LLC Seeks Relief From Section 

61.113(a) And (b). 

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

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

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

or hire. 

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

pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or 

employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft 

does not carry passengers or property for compensation or hire. 

As set forth more fully below, D-Drones LLC submits that an equivalent level of safety will be 

maintained because no PIC will be allowed to operate DJI Phantom 2 Vision+ (DJI2+) or DJI 

Phantom 3 Professional (DJI3P) UAS's unless that PIC has met certain flight-hour and current 

requirements, demonstrating that the PIC is able to safely operate either the DJI Phantom 2 Vision+ 

(DJI2+) or DJI Phantom 3 Professional (DJI3P) UAS's 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, D-Drones LLC submits that all flights of the DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 

Professional (DJI3P) UAS's, conducted by the PIC pursuant to the grant of this Petition: (1) will be 
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incidental to D-Drones LLC's business; and (2) will not carry passengers or property for compensation 

or hire. 

2.Extent Of Relief D-Drones LLC Seeks And The Reason D-Drones LLC 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 D-Drones LLC to determine that the DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 

Professional (DJI3P) UAS's are in airworthy condition prior to every flight by ensuring that the UAS is in 

compliance with the operating documents (i.e., the Monthly Maintenance Log and DJI Phantom 2 

Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P) instruction manuals. 

D-Drones LLC seeks the requested relief because the DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 

Professional (DJI3P) UAS's do not require an airworthiness certificate in accordance with C.F.R. Part 

21, Subpart H. 

Therefore, D-Drones LLC will ensure that the DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 

Professional (DJI3P) UAS's are in airworthy condition based upon its compliance with the operating 

documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 

Professional (DJI3P) Instruction Manual) prior to every flight, and further, determine that the aircraft 

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

3. Extent Of Relief D-Drones LLC Seeks And The Reason D-Drones LLC Seeks Relief From Section 

91.121. 

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

operations of the DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P) UAS's, which 

utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data 

link to downlink altitude information from the UA to the PIC at the ground control station (GCS). 

Since the FAA requires that any altitude information concerning UAS operations be reported 

to air traffic control (ATC) in feet above ground level (AGL), D-Drones LLC seeks the requested relief 

because the DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P) 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 2 Vision+ 

(DJI2+) & DJI Phantom 3 Professional (DJI3P) UAS's are equipped with a barometric pressure sensor 

and GPS equipment, which automatically ensures that a ground level pressure setting will be 

established prior to each flight, and provides the PIC with altitude information of the UA on the 

heads-up display of the GCS. 

4. Extent Of Relief D-Drones LLC Seeks And The Reason D-Drones LLC Seeks Relief From Section 
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91.151(b). 

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

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

(DJI2+) & DJI Phantom 3 Professional (DJI3P) UAS's during daylight hours in visual meteorological 

conditions (VMC), under visual flight rules (VFR), for a total duration of 10 minutes to the first point of 

intended landing and, assuming normal cruising speed, to fly after that for at least 2.5 minutes. DDrones LLC seeks the requested relief because without an exemption from Section 91.151(b), the 

flight time duration of the battery powered DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 

Professional (DJI3P) UAS's will severely constrain the practicality of any aerial video or still photo flight 

operations that D-Drones LLC proposes to conduct pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the DJI Phantom 2 Vision+ (DJI2+) & 

DJI Phantom 3 Professional (DJI3P) UAS's, DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional

(DJI3P) operating documents and D-Drones LLC's proposed operating limitations, ensure that DDrones LLC will safely operate the battery powered DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 

Professional (DJI3P) UAS's during daylight hours in visual meteorological conditions (VMC), under 

visual flight rules (VFR), with enough battery power to fly for a total duration of 10 minutes to the 

first point of intended landing and, assuming normal cruising speed, to fly after that for at least 2.5 

minutes. 

5.Extent Of Relief D-Drones LLC Seeks And The Reason D-Drones LLC 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, D-Drones LLC requests relief from these Sections because 

the DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P) UAS's do not require 

airworthiness certificates. As set forth more fully below, the DJI Phantom 2 Vision+ (DJI2+) & DJI 

Phantom 3 Professional (DJI3P) UAS's meet the conditions of FMRA Section 333 for operation without 

an airworthiness certificate. 

Accordingly, D-Drones LLC will use trained technicians to perform maintenance, alterations, or 

preventive maintenance on the UAS's using the methods, techniques, and practices prescribed in 

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

DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P) Instruction Manual). 

Furthermore, D-Drones LLC will document and maintain all maintenance records for the DJI 

Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P) UAS's. 
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D. The Reasons Why Granting D-Drones LLC Request Would Be In The Interest; That Is, How It Would 

Benefit The Public As A Whole. 

Granting the present Petition will further the public interest by allowing D-Drones LLC to safely, 

efficiently, and economically perform aerial video and photography of construction sites, real 

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

Additionally, use of the DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P) UAS's will 

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

Notably, the benefits of D-Drones LLC's proposed operation of the DJI Phantom 2 Vision+ (DJI2+) & 

DJI Phantom 3 Professional (DJI3P) UAS's will be realized without implicating any privacy issues. 

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

The DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P) UAS's are battery powered 

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

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

aerial acquisitions, an exemption allowing the use of the DJI Phantom 2 Vision+ (DJI2+) & DJI 

Phantom 3 Professional (DJI3P) UAS's 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 2 Vision+ (DJI2+) 

& DJI Phantom 3 Professional (DJI3P) UAS's do not require an airport to takeoff or land. Likewise, a 

reduction of manned aircraft conducting aerial video and photography missions would result in 

fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, 

arrival, and landing phases of flight operations. 

2. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 2 Vision+ (DJI2+) & DJI

Phantom 3 Professional (DJI3P) UAS's. 

Conducting aerial acquisitions with the DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional

(DJI3P) UAS's instead of manned aircraft, will greatly benefit the public by drastically reducing the 

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

operations. By using battery power and electric motors, the DJI Phantom 2 Vision+ (DJI2+) & DJI 

Phantom 3 Professional (DJI3P) UAS's produce 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 2 Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P) 

UAS's, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as 

the UA's are propelled by battery powered electric motors, rather than an internal combustion 

engine. 

By using the DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P) UAS's to perform 

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

usually associated with traditional manned aircraft flight operations, will be substantially reduced or 

completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the 
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DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P) UAS's (weighing approximately 2 

pounds 12 ounces and 2 pounds 13 ounces respectively, at their maximum gross weights with 

respectively (and with no fuel on board) has less physical potential for collateral damage to life and 

property on the ground, and in the air, compared to the manned aircraft that typically conduct 

similar operations (weighing approximately 6,000 pounds, and a fuel capacity of 180 gallons. 

3. Performing Aerial Video and Photography Operations With The DJI Phantom 2 Vision+ (DJI2+) & DJI 

Phantom 3 Professional (DJI3P) UAS's Will Benefit The Economy. 

In addition to being safe and efficient, the DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 

Professional (DJI3P) UAS's are also an economical alternative to using manned aircraft to conduct 

similar aerial operations. As such, operation of the DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 

Professional (DJI3P) UAS's will allow United States based companies, like D-Drones LLC's to remain 

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

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

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

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

(DJI2+) & DJI Phantom 3 Professional (DJI3P) UAS's is one such technology that not only allows 

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

without the high operational cost of a traditional manned aircraft. 

By operating the DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P) UAS's, 

companies such as D-Drones LLC's 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 2 Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P) UAS's, 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, DDrones LLC's proposed operation of the DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional

(DJI3P) UAS's will not implicate any privacy issues. Specifically, the DJI Phantom 2 Vision+ (DJI2+) & 

DJI Phantom 3 Professional (DJI3P) UAS's will be operated only in compliance with operating 

documents (i.e. Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ 

(DJI2+) & DJI Phantom 3 Professional (DJI3P) Instruction Manual's) 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 

D-Drones LLC Seeks Exemption. 

1. Reasons Why The DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P) UAS's Meet 

The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333. 

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

unmanned aircraft and its operation, D-Drones LLC’s operation of the DJI Phantom 2 Vision+ (DJI2+) 

& DJI Phantom 3 Professional (DJI3P) UAS's meet 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, D-Drones LLC submits that the DJI Phantom 2 Vision+ (DJI2+) & DJI 

Phantom 3 Professional (DJI3P) UAS's can operate safely in the NAS pursuant to FMRA Section 333, as 

demonstrated by: (a) the characteristics of the DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 

Professional (DJI3P) UAS's; (b) the pilot certification requirement; and (c) the specific operating 

limitations. 
16

a. The Specifications Of The DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional 

(DJI3P) UAS's Demonstrate Its Safe Characteristics. 

The DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P) UAS's do not create a hazard 

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

weight, speed, and operational capability. 

i. Technical Specifications Of The DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional 

(DJI3P) UAS's. 

The technical specifications of the DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional

(DJI3P) UAS's are set forth by the DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional

(DJI3P) Specifications and Data Sheet, attached hereto as Exhibit A and B. 

ii. The DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P) UAS's Autonomous 

Flight And Navigation Modes Enable The UAS's To Remain Within A Defined Operational Area. 

The DJI Phantom 2 Vision+ (DJI2+) may be operated in both manual and fully autonomous 

flight modes. The DJI Phantom 3 Professional (DJI3P)may be operated in manual flight mode 

only. A complete description of the flight and navigational modes of the DJI Phantom 2 

Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P) UAS's is provided in the user manual, 

attached hereto as Exhibit C and D. 

iii. The DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P) UAS's Are Designed 

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

Navigation. 

When the Control Link is lost, the DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional

(DJI3P) will remain stationary in flight, for 3 seconds or more. If, after 3 seconds, the DJI 

Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P) due not reacquire control link 

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

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

shutdown. 

A complete description of the Failsafe Functions of the DJI Phantom 2 Vision+ (DJI2+) & DJI 

Phantom 3 Professional (DJI3P) UAS's are set forth on respective user manual as Exhibit C and 

D. 

iv. The DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P) GCS And Its 

Operation. 

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

(DJI2+) & DJI Phantom 3 Professional (DJI3P) GCS and flight control software is provided on 

respective user manual as Exhibit C and D. 

User Manual: The DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P) User Manuals 

are attached hereto as Exhibits C and D. 
17

b. Flight Operations Of DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P) 

UAS's Are Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer.

D-Drones LLC will only utilize certificated pilots who possess a current and valid airman medical 

certificate to act as a pilot in command (PIC) of the DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 

Professional (DJI3P) UAS's. Additionally, a safety observer will assist all pilots during flight time.

c. Flights Of DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P) UAS's Will Be 

Conducted Pursuant To Specific Operating Limitations. 

In seeking this exemption, D-Drones LLC proposes to commercially operate DJI Phantom 2 Vision+ 

(DJI2+) & DJI Phantom 3 Professional (DJI3P) UAS's 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's weighing less than 20 pounds maximum gross weight: 

DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P) Unmanned Aircraft Systems. 

Proposed operations of any other aircraft will require a new petition or a petition to amend this 

grant. 

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

aerial video and photography. 

3. The UA may not be flown at an indicated airspeed exceeding 20 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 UA's must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the 

PIC to be able to use human vision unaided by any device other than corrective lenses, as specified 

on the PIC’s FAA-issued airman medical certificate. 

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted. 

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

requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be able to 

communicate verbally at all times. Electronic messaging or texting is not permitted during flight 

operations. The PIC must be designated before the flight and cannot transfer his or her designation 

for the duration of the flight. The PIC must ensure that the SO can perform the functions prescribed in 

the operating documents. 

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

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

camera or other instruments. 

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

and made available to the Administrator upon request. If a discrepancy exists between the 
18

conditions and limitations contained in the grant of exemption and the procedures outlined in the 

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

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

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

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

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

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

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

operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration Office 

(AFS-80) may be contacted if questions arise regarding updates or revisions to the operating 

documents. 

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

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

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

found to be in a condition for safe flight. The Ground Control Station must be included in the 

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

records. 

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

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

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

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

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

documents. 

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

replacement, inspection, and life limit requirements.

14. The operator must carry out its maintenance, inspections, and record keeping requirements, in 

accordance with the operating documents. Maintenance, inspection, alterations, and status of 

replacement/overhaul component parts must be noted in the aircraft records, including total time 

in service, description of work accomplished, and the signature of the authorized person returning 

the UAS to service. 

15. Each UAS's operated under this exemption must comply with all manufacturer Safety Bulletins.

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

against discrepancies discovered between inspections. 

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

certificate. 

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

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

with how the UAS will be operated under the exemption, including evasive and emergency 

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

qualification flight hours must be logged in a manner consistent with 14 C.F.R. §61.51(b). Flights for 
19

the purposes of training the operator’s PIC's are permitted under the terms of the exemption. 

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

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

considered nonparticipants, and the PIC must operate the UA with appropriate distance from 

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

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

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

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

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

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

made available to the Administrator upon request. 

21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a 

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

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

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

documents. 

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

accordance with the operating documents. 

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

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

land the UAS with 25% battery power remaining. 

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

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

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

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

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

level and potential transponder requirements. 

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

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

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

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

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

government oversight agency requirements. 

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the 
20

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. 

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

activities at all times. 

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

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

other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless: 

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

and/or debris in the event of an accident. The operator must ensure that nonparticipating persons 

remain under such protection. If a situation arises where nonparticipating persons leave such 

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

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

vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of 

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

hazard, and; 

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

hazard to those persons per § 91.119(a). 

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

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

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

33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of 

the operational area as defined by the applicable COA must be reported to the FAA's UAS 

Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National 

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. 

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

Adversely Affect Safety. 

D-Drones LLC submits that the equivalent level of safety established by Section 61.113(a) and (b) will 

be maintained because no PIC will be allowed to operate the DJI Phantom 2 Vision+ (DJI2+) or DJI 

Phantom 3 Professional (DJI3P) UAS's unless that PIC has demonstrated, by meeting minimum flighthour and currency requirements, that the PIC is able to safely operate the DJI Phantom 2 Vision+ 

(DJI2+) or DJI Phantom 3 Professional (DJI3P) UAS in a manner consistent with the exemption, 

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

vessels, vehicles and structures. 

Considering D-Drones LLC’s proposed area of operations, and the operating limitations set forthabove; the parallel nature of private pilot aeronautical knowledge requirements to those of 

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

safely operate the DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P) UAS, D-Drones 
21

LLC submits that the additional manned airmanship experience of a commercially certificated pilot 

would not correlate to the airmanship skills necessary for D-Drones LLC's specific proposed flight 

operations. 

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

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 

11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 

11158, 11159, 11160, 11161). 

D-Drones LLC will not allow any PIC to operate the DJI Phantom 2 Vision+ (DJI2+) or DJI Phantom 3 

Professional (DJI3P) UAS unless that PIC has demonstrated, by meeting minimum flight-hour 

requirements of the DJI Phantom 2 Vision+ (DJI2+) or DJI Phantom 3 Professional (DJI3P) UAS training 

and currency requirements, that the PIC is able to safely operate the DJI Phantom 2 Vision+ (DJI2+) 

& DJI Phantom 3 Professional (DJI3P) UAS in a manner consistent with this exemption, including 

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

vehicles and structures. 

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 

61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as 

a UAS pilot operating the same make and model of UAS to be used for operations under the 

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

the preceding 90 days (for currency purposes). 

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

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

D-Drones LLC’s proposed operations. The Administrator has held that prior documented flight 

experience that was obtained in compliance with applicable regulations would ensure safe 

operations, stating as follows: 

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

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

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

least 10 hours logged as a UAS pilot with a multi-rotor UAS. Prior to operations under Exemption No. 

11062, the PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot 

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

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

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

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

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

currency purposes). The FAA finds that at a minimum, the flight-hour requirements in Exemption No. 

11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the 

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

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

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

accomplish the required flight time. During training, proficiency, and experience-building flights the 

PIC is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119. 

Exemption No. 11138 at page 15. 
22

Accordingly, D-Drones LLC will ensure safe operations by not allowing any PIC to operate the DJI 

Phantom 2 Vision+ (DJI2+) or DJI Phantom 3 Professional (DJI3P) UAS unless that PIC has 

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

safely operate the DJI Phantom 2 Vision+ (DJI2+) or DJI Phantom 3 Professional (DJI3P) UAS in a 

manner consistent with the exemption, including evasive and emergency maneuvers and 

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

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

Safety. 

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

every flight, D-Drones LLC will ensure that the DJI Phantom 2 Vision+ (DJI2+) or DJI Phantom 3 

Professional (DJI3P) UAS is in an airworthy condition based upon the UAS’s compliance with its 

operating documents and as stated in the conditions and limitations herein. Additionally, the FAA 

has previously granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all 

material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 

11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 

11161). 

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect 

Safety. 

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

information of the DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P) UAS's will be 

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

downlinks from the UA to the GCS for active monitoring of the flight path and altitude. This altitude 

information, combined with D-Drones LLC's operation of the DJI Phantom 2 Vision+ (DJI2+) & DJI 

Phantom 3 Professional (DJI3P) UA's 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's at ground level. The FAA has previously granted relief from 

Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented 

herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 

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

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

Affect Safety. 

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 

91.151(b) as a result of (1) the technical specifications of the DJI Phantom 2 Vision+ (DJI2+) & DJI 

Phantom 3 Professional (DJI3P) UAS's; (2) the limitations on the proposed flight operations; and (3) 

the location of the proposed flight operations. Accordingly, D-Drones LLC will ensure that he will 

safely operate the battery powered DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional 

(DJI3P) UA's during daylight hours in VFR conditions, with enough battery power to fly for a total 

duration of 10 minutes to the first point of intended landing and, assuming normal cruising speed, to 

fly after that for at least 2.5 minutes. 

Here, as in Exemption No. 11109, the technical specifications of DJI Phantom 2 Vision+ (DJI2+) & DJI 
23

Phantom 3 Professional (DJI3P) UAS's 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 2 Vision+ (DJI2+) & DJI 

Phantom 3 Professional (DJI3P) UAS's provide audible and visual warnings to the PIC at the GCS 

when the UA's experiences low battery voltage, the first warning occurring at approximately 33% 

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

low battery level, the DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P) UAS's 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, D-Drones LLC 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 D-Drones LLC will use trained 

technicians to perform maintenance, alterations, or preventive maintenance on the UAS's using the 

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

Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional 

(DJI3P) Instruction Manual. Furthermore, D-Drones LLC will document and maintain all maintenance 

records for the DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P) UAS's. 

Since the DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P) UAS's will be inspected 

as prescribed by the operating documents, D-Drones LLC will maintain the equivalent level of safety 

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

Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P) User Manuals are attached hereto as Exhibit C 

and D; a copy of the DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P) UAS 

Maintenance LOG is attached hereto as Exhibit E. 

Likewise, the exemption sought will not adversely affect safety because D-Drones LLC will use trained 

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

methods, techniques, and practices prescribed by the operating documents. 

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

Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI Phantom 2 Vision+ 

(DJI2+) & DJI Phantom 3 Professional (DJI3P) UAS's will be performed by trained technicians. 

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

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

91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the 
24

technical characteristics and operating limitations of the UAS are considered. 

In consideration of D-Drones LLC's proposed operating limitations, the operating documents, and 

the technical aspects of the DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P)

UAS's, D-Drones LLC 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, D-Drones LLC requests that the FAA prescribe special 

conditions for the intended operation of the DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 

Professional (DJI3P) UAS's, 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 UA's for the limited purpose 

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

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

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

and further, provides the authority for such UAS to operate without airworthiness certification in 

accordance with any requirements that must be established for the safe operation of the UAS in the 

NAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. §21.16, for 

operation of the DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P) UAS's, 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 subchapter do not contain adequate or 

appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or 

unusual design feature of the aircraft, aircraft engine or propeller, it may prescribe 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 D-Drones LLC’s intended operation of the DJI Phantom 2 

Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P) UAS's, which contain such safety standards that 

the administrator finds necessary to establish a level of safety equivalent to that established by 14 

C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). 
25

F. A Summary That Can Be Published In The Federal Register stating: The Rules From Which D-Drones 

LLC Seeks Exemption: 

D-Drones LLC 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 D-Drones LLC Seeks: 

This exemption will permit D-Drones LLC 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 D-Drones LLC's 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, D-Drones LLC 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 poses a threat to national security and further, provides 

the authority for such UAS to operate without airworthiness certification. 

As discussed in detail above, D-Drones LLC will operate the DJI Phantom 2 Vision+ (DJI2+) & DJI 

Phantom 3 Professional (DJI3P) UAS's safely in the NAS, without creating a hazard to users of the NAS, 

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

H. If you want to exercise the privileges of your exemption outside the United States, the reason why 

you need to do so. 

D-Drones LLC would like to exercise the privilege of any granted exemption to operated outside the 

United States, such as Mexico or Canada only in those cases where his aerial photography and 

video services are hired directly from USA customers in the United States in the Construction industry

,with operations or participating in big construction projects in those countries, to operate on 

contractual basis only in those two countries for specific cases, operating only the listed UAS in this 

petition such as DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P)

In any case, D-Drones LLC will have to comply with the existing safety rules from FAA Modernization 

and Reform Act of 2012 (FMRA) Section 333 as well as for any additional local or country specific 

regulations to operate safely any UAS in those countries and in accordance to this petition 

exemption.
26

CONCLUSION

As set forth herein, D-Drones LLC seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of 

the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI 

Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P) UAS's commercially, without an 

airworthiness certificate, for the limited purpose of conducting aerial video and photography over 

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

Congressional mandate of the FAA Modernization and Reform Act of 2012, while also 

advancing the interests of the public, by allowing D-Drones LLC to safely, efficiently, and 

economically operate the DJI Phantom 2 Vision+ (DJI2+) & DJI Phantom 3 Professional (DJI3P) UAS's 

commercially within the NAS. 

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

Modernization and Reform Act of 2012, Section 333, D-Drones LLC respectfully requests that the 

Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 

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

91.417(a) & (b), and permit D-Drones LLC to operate the DJI Phantom 2 Vision+ (DJI2+) & DJI 

Phantom 3 Professional (DJI3P) UAS's commercially for the purpose of conducting aerial video and 

photography over certain areas of the United States. 

Dated: July 3rd, 2015 

Respectfully submitted, 

D-Drones LLC

185 Bricknell Ln

Coppell, TX 75019

Ph. 469-233-4694
27

APPENDIX:

A – DJI Phantom 2 Vision+ Specifications 

B – DJI Phantom 3 Professional Specifications 

C – DJI Phantom 2 Vision+ User Manual 

D – DJI Phantom 3 Professional User Manual 

E - Monthly Maintenance Log 
28

APPENDIX –A

DJI Phantom 2 Vision + TECHNICAL SPECIFICATIONS

D-Drones LLC only utilizes safe and reliable UAS's. DJI is an industry leader in small UAS production. DJI 

UAS's 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.

Link to technical Specifications: http://www.dji.com/product/phantom-2-vision-plus/spec

Aircraft:

• Supported Battery: DJI 5200mAh LiPo Battery

• Weight (Battery & Propellers Included : 1242g

• Hover Accuracy (Ready To Fly): Vertical: 0.8m; Horizontal: 2.5m

• Max Yaw Angular Velocity: 200°/s

• Max Tiltable Angle: 35°

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

• Max Flight Speed: 15m/s

• Diagonal Motor-Motor Distance: 350mm

Gimbal:

• Working Current: Static : 750mA; Dynamic : 900mA

• Control Accuracy: ±0.03°

• Controllable Range: Pitch : -90°-0°

• Maximum Angular Speed: Pitch : 90°/s

Camera:

• Sensor Size : 1/2.3" 

• Effective Pixels: 14 Megapixels

• Resolution: 4384×3288

• HD Recording : 1080p30 & 720p

Remote Control:

• Operating Frequency: 5.728 GHz-5.85 GHz

• Communication Distance (Open Area): CE Compliance: 400m; FCC Compliance: 800m

• Receiver Sensitivity (1%PER): -93dBm

• Transmitter Power: CE Compliance: 25mW; FCC Compliance: 100mW

• Working Voltage: 120 mA@3.7V

• Built-In LiPo Battery Working Current/Capacity: 3.7V, 2000mAh 
29

APPENDIX –B

DJI Phantom 3 Professional TECHNICAL SPECIFICATIONS

D-Drones LLC only utilizes safe and reliable UAS's. DJI is an industry leader in small UAS production. DJI 

UAS's 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.

Link to technical Specifications: http://www.dji.com/product/phantom-3/spec

Aircraft:

• Weight (Including Battery And Propellers): 1280 g

• Diagonal Size (Including Propellers): 590 mm

• Hover Accuracy (Ready To Fly): Vertical: 0.1m; Horizontal: 1.5m

• Supported Battery: DJI 5200mAh LiPo Battery

• GPS Mode: GPS/GLONASS

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

• Max Flight Speed: 16m/s

Gimbal:

• Controllable Range: Pitch : -90°+30°

• Stabilization: 3-axis (pitch, roll, yaw)

Camera:

• Sensor Size : Sony EXMOR 1/2.3” Effective pixels: 12.4 M (total pixels: 12.76 M)

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

• Shutter Speed: 8s -1/8000s

• Image Max Size: 4000 x 3000

Vision Positioning:

• Max Velocity: Less than 8 m/s (when 2 m above ground)

• Altitude Range: 30 cm-300 cm

• Operating Range: 30 cm-300 cm

• Operating Environment: Surface with clear pattern and adequate lighting (Lux > 15)

Remote Control:

• Operating Frequency: 2.400 GHz-2.483 GHz

• Max Distance: 2000m (outdoors and unobstructed)

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

• Transmitter Power (EIRP): CE Compliance: 16dBm; FCC Compliance: 20dBm

• Working Voltage: 1.2 A @7.4 V

• Built-In LiPo Battery Working Current/Capacity: 6000 mAh LiPo 2S
30

APPENDIX – C 

DJI Phantom 2 Vision+ - Manufacturer's User Manual

Link to Manufacturer User Manual: http://www.dji.com/product/phantom-2-vision-plus/download

APPENDIX – D 

DJI Phantom 3 Professional - Manufacturer’s User Manual

Link to Manufacturer User Manual: http://www.dji.com/product/phantom-3/download
31

APPENDIX - E

D-Drones LLC Monthly Maintenance and Repair Log

Maintenance Log ID:

Aircraft: 

Hours: 

Date: 

Previous maintenance Log ID:

Date Issue 

Discovered

Date Issue 

Resolved

Issue Description/Maintenance 

Conducted 

Repair/Maintenance 

Performed By 

Airframe 

Motors 

Propellers 

Flight Control 

Update 

Gimbal 

Firmware 

Update

Camera

Radio Control

Miscellaneous