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UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

Regulatory Docket No. _______________ 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: EDWARD STANZA 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, DJI 

Inspire 1 UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF 

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95) 

Submitted on September 11, 2015 

Edward Stanza

1954 Argyle Ave. #D

Los Angeles, CA 90068

409-599-9846
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TABLE OF CONTENTS 

Page 

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

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

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

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

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

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

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH EDWARD STANZA SEEKS 

EXEMPTION...........................................................................................................................6

THE EXTENT OF RELIEF EDWARD STANZA AND THE REASON EDWARD STANZA

SEEKS THE RELIEF.............................................................................................................9 

THE REASONS WHY GRANTING EDWARD STANZA REQUEST WOULD BE IN 

THE PUBLIC INTEREST ....................................................................................................11 

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY 

AFFECT SAFETY.................................................................................................................13 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER............................23 

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT EDWARD STANZA’S REQUEST...........................................................24 

CONCLUSION......................................................................................................................24 

APPENDICES....................................................................................................25 
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GLOSSARY OF ABBREVIATIONS 

AGL Above Ground Level 

AOI Area of Interest 

ATC Air Traffic Control 

ATO Air Traffic Organization 

AV Aerial Vehicle 

CFR Code of Federal Regulations 

COA Certificate of Authorization 

FAA Federal Aviation Administration 

FAR Federal Aviation Regulation 

GCS Ground Control Station 

GPS Global Positioning System LOL Loss of Link 

NAS National Airspace System 

NOTAM Notice to Airman 

PIC Pilot In Command 

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

SO Safety Observer 

SOP Standard Operating Procedures 

UA Unmanned Aircraft 

UAS Unmanned Aircraft System

VFR Visual Flight Rules 

VLOS Visual Line of Site 

VMC Visual Meteorological Conditions 

VTOL Vertical Takeoff and Landing 
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SUMMARY 

Edward Stanza 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 EDWARD 

STANZA to operate an Unmanned Aircraft System (UAS) for the commercial purpose of 

conducting aerial video and photography of construction sites, real estate, Special Events 

and landscape over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

Edward Stanza provides clients with expertise in advanced photography and 

videography technologies to increase productivity and effectiveness. 

He has over 4 years recreational/hobby experience in remote controlled vehicles. 

Additionally, he currently has 41 hours flight in Airplane Single Engine Land; The objective 

of Edward Stanza’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 and private property aerial photography

 Aerial event photography 

 Search and Rescue

 Aerial images used for inspections of public and private structures, and

 Increase public knowledge of UAS and promote safe UAS operations.

BACKGROUND 

Unmanned Aircraft Systems: DJI Phantom 3, DJI Inspire 1

Edward Stanza seeks an exemption to operate DJI systems for compensation or 

hire within the NAS. 

 DJI Models: DJI Phantom 3, and Inspire 1 are lightweight (under 55 lbs), battery operated 

Multi-Rotor VTOL aircraft 

 An on-board flight computer with GPS navigation and location ability that receives signals 

for flight controls from a ground-based transmitter/controller 

 An on-board camera attached to the UA via three axis gimbal, capable of capturing full 

color, high definition imagery 

 An on-board telemetry system that delivers flight data from the on-board flight computer 

to the on-board radio transmitter including altitude AGL, horizontal and vertical speed, 

compass direction of flight and direction back to its launch site 

The DJI UAS that will be operated by Edward Stanza 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. 
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BASIS FOR PETITION 

Petitioner, Edward Stanza, 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, DJI Inspire 1 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, Edward Stanza’s operation of DJI Phantom 3, DJI 

Inspire 1 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, Edward Stanza 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. 

Edward Stanza submits that the requested relief is proper since an equivalent level 

of safety will be ensured. Edward Stanza will use experienced personnel or technicians to 

perform maintenance, alterations, or preventive maintenance on the UASs using the 

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

Maintenance Log, and DJI Phantom 3, DJI Inspire 1 Instruction Manual). Furthermore 

Edward Stanza will document and maintain all maintenance records for the DJI Phantom 3, 

DJI Inspire 1 UAS. 

Edward Stanza seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, 

because the DJI Phantom 3, DJI Inspire 1 UAS does not require an airworthiness 

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

submits that he will ensure that the DJI Phantom 3, DJI Inspire 1 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, DJI Inspire 1 

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

Edward Stanza also seeks an exemption from the requirements of Section 91.121, 

entitled Altimeter Settings, as the DJI Phantom 3, DJI Inspire 1 UA will not have a typical 

barometric altimeter onboard. However, altitude information of the DJI Phantom 3, DJI 

Inspire 1 UAS will be provided to the PIC via Global Positioning System (GPS) equipment 

and radio communications telemetry data link, which downlinks from the UA to the GCS for 
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active monitoring of the flight path. This altitude information, combined with Edward 

Stanza’s operation of the DJI Phantom 3, DJI Inspire 1 UAS within visual line of sight, at or 

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

Additionally, Edward Stanza seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. EDWARD STANZA 

submits that safety will not be affected by operation of the DJI Phantom 3, DJI Inspire 1 UA 

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, EDWARD STANZA 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: 

EDWARD STANZA

1954 ARGYLE AVE. #D

LOS ANGELES, CA 90068

Tel: (409) 599-9846

Email: edwardstanza@yahoo.com 

B. The Specific Sections Of 14 C.F.R. From Which Edward Stanza Seeks Exemption. 

1. Edward Stanza 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. Edward Stanza 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. 
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3. EDWARD STANZA Seeks Exemption From The Requirements Of Section 91.121. 

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

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

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

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

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

miles of the aircraft; 

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

section, the current reported altimeter setting of an appropriate available station; or 

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

or an appropriate altimeter setting available before departure. 

4. EDWARD STANZA Seeks Exemption From The Requirements Of Section 

91.151(b). 

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

(b), states the following: 

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

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

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

5. EDWARD STANZA 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[.] 

6. EDWARD STANZA 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--
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(1) It has been approved for return to service by a person authorized under § 43.7 of this 

chapter [.] 

7. EDWARD STANZA 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. EDWARD STANZA 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. 
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(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. 

C. The Extent Of Relief EDWARD STANZA Seeks And The Reason EDWARD STANZA

Seeks The Relief. 

1. Extent Of Relief EDWARD STANZA Seeks And The Reason EDWARD STANZA

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, EDWARD STANZA submits that an equivalent level of 
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safety will be maintained because no PIC will be allowed to operate the DJI Phantom 3, DJI 

Inspire 1 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, DJI Inspire 1 UAS 

in a manner consistent with the operations specifications as described in this exemption, 

including evasive and emergency maneuvers, as well as maintaining appropriate distances 

from people, vessels, vehicles and structures. 

Further, EDWARD STANZA submits that all flights of the DJI Phantom 3, DJI Inspire 1 

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

EDWARD STANZA business; and (2) will not carry passengers or property for 

compensation or hire. 

2. Extent Of Relief EDWARD STANZA Seeks And The Reason EDWARD STANZA

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 EDWARD STANZA to determine that the DJI Phantom 3, DJI Inspire 1 

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

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

Inspire 1 Instruction Manual). 

EDWARD STANZA seeks the requested relief because the DJI Phantom 3, DJI Inspire 1 

UAS does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, 

Subpart H. Therefore, EDWARD STANZA will ensure that the DJI Phantom 3, DJI Inspire 1 

UAS is in airworthy condition based upon its compliance with the operating documents (i.e., 

Monthly Maintenance Log, and DJI Phantom 3, DJI Inspire 1 UAS 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. 

3. Extent Of Relief EDWARD STANZA Seeks And The Reason EDWARD STANZA

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, DJI Inspire 1 UAS, 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), EDWARD STANZA seeks the 

requested relief because the DJI Phantom 3, DJI Inspire 1 UA 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, DJI Inspire 1 UA 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. 
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4. Extent Of Relief EDWARD STANZA Seeks And The Reason EDWARD STANZA

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, DJI 

Inspire 1 UA during daylight hours in visual meteorological conditions (VMC), under visual 

flight rules (VFR), for a total duration of 13.5 minutes to the first point of intended landing 

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

STANZA seeks the requested relief because without an exemption from Section 91.151(b), 

the flight time duration of the battery powered DJI Phantom 3, DJI Inspire 1 UA will severely 

constrain the practicality of any aerial video or still photo flight operations that EDWARD 

STANZA proposes to conduct pursuant to this Petition. 

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

Inspire 1 UAS, the DJI Phantom 3, DJI Inspire 1 operating documents, and EDWARD 

STANZA’S proposed operating limitations, ensure that EDWARD STANZA will safely 

operate the battery powered DJI Phantom 3, DJI Inspire 1 UA during daylight hours in visual 

meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power 

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

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

5. Extent Of Relief EDWARD STANZA Seeks And The Reason EDWARD STANZA

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, EDWARD STANZA requests relief 

from these Sections because the DJI Phantom 3, DJI Inspire 1 UAS does not require 

airworthiness certificates. As set forth more fully below, the DJI Phantom 3, DJI Inspire 1 

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

certificate. Accordingly, EDWARD STANZA will use trained technicians to perform 

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

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

Maintenance Log, and DJI Phantom 3, DJI Inspire 1). Furthermore, EDWARD STANZA will 

document and maintain all maintenance records for the DJI Phantom 3, DJI Inspire 1 UAS. 

D. The Reasons Why Granting EDWARD STANZA’s Request Would Be In The Public 

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

Granting the present Petition will further the public interest by allowing EDWARD STANZA

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

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

Additionally, use of the DJI Phantom 3, DJI Inspire 1 UAS will decrease congestion of the 

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

benefits of EDWARD STANZA’S proposed operation of the DJI Phantom 3, DJI Inspire 1 

UAS will be realized without implicating any privacy issues. 
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1. The Public Will Benefit From Decreased Congestion Of The NAS. 

The DJI Phantom 3, DJI Inspire 1 UA 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, DJI Inspire 1 UAS would reduce the 

amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase 

the safety of life and property in the air and on the ground. 

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

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

3, DJI Inspire 1 UA 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, DJI 

Inspire 1 UAS. 

Conducting aerial acquisitions with the DJI Phantom 3, DJI Inspire 1 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, DJI Inspire 1 

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, DJI Inspire 1 UA, while reducing the carbon 

footprint of aerial acquisitions, also eliminates noise pollution, as the UAs are propelled by 

battery powered electric motors, rather than an internal combustion engine. 

By using the DJI Phantom 3, DJI Inspire 1 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 access methods, will be substantially reduced or completely eliminated. 

Aside from the lack of flight crew members located onboard the aircraft, the DJI Phantom 3, 

DJI Inspire 1 UA (under 3lbs, and 6.5lb. gross weight respectively) and with no fuel on 

board), has less physical potential for collateral damage to life and property on the ground, 

and in the air, compared to the manned aircraft that typically conduct similar operations 

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

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

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

Inspire 1 UAS Will Benefit The Economy. 

In addition to being safe and efficient, the DJI Phantom 3, DJI Inspire 1 UAS is also an 

economical alternative to using manned aircraft to conduct similar aerial operations. As 

such, operation of the DJI Phantom 3, DJI Inspire 1 UAS will allow United States based 

companies, like EDWARD STANZA’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 
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and operated companies must adopt new and alternative technology in order to remain 

competitive. Operating the battery powered DJI Phantom 3, DJI Inspire 1 UASs is one such 

technology that not only allows companies greater operational flexibility compared to 

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

manned aircraft. 

By operating the DJI Phantom 3, DJI Inspire 1 UAS, companies such as EDWARD 

STANZA’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 3, DJI Inspire 1 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, EDWARD STANZA’s proposed operation of the DJI Phantom 3, DJI Inspire 1 

UAS will not implicate any privacy issues. Specifically, the DJI Phantom 3, DJI Inspire 1 

UAS will be operated only in compliance with operating documents (i.e., Monthly 

Maintenance Log, and DJI Phantom 3, DJI Inspire 1) which requires property owner 

involvement as well as local law enforcement notification, and in accordance with the 

Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 

91.119. 

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

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

Provided By The Rule From Which EDWARD STANZA Seeks Exemption. 

1. Reasons Why The DJI Phantom 3, DJI Inspire 1 UA 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, EDWARD STANZA’S operation of the DJI 

Phantom 3, DJI Inspire 1 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. 
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(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, EDWARD STANZA submits that the DJI Phantom 3, DJI Inspire 

1 UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: 

(a) the characteristics of the DJI Phantom 3, DJI Inspire 1 UAS; (b) the pilot certification 

requirement; and (c) the specific operating limitations. 

a. The Specifications Of The DJI Phantom 3, DJI Inspire 1 UAS Demonstrate Its 

Safe Characteristics. 

The DJI Phantom 3, DJI Inspire 1 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, DJI Inspire 1 UAS. 

The technical specification of the DJI Phantom 3, DJI Inspire 1 UAS is set forth by the DJI 

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

B. 

ii. The DJI Phantom 3, DJI Inspire 1 UAS Autonomous Flight And Navigation Modes 

Enable The UASs To Remain Within A Defined Operational Area. 

The DJI Phantom 3, DJI Inspire 1 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, DJI Inspire 1 UAS is provided in the DJI Phantom 3, DJI Inspire 1 User 

Manual, attached hereto as Exhibit C and D. 

iii. The DJI Phantom 3, DJI Inspire 1 UAS is Designed For Automatic Return 

To Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation. 
15 | Page

When the Control Link is lost, the DJI Phantom 3, DJI Inspire 1 UA will remain stationary, in 

flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 3, DJI Inspire 1 UA 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 of the DJI Phantom 3, DJI Inspire 1 UAS 

are set forth in the DJI Phantom 3, DJI Inspire 1 User Manual, attached 

hereto as Exhibit C and D. 

iv. The DJI Phantom 3, DJI Inspire 1 GCS And Its Operation. 

A complete description of the operation and specifications of the DJI Phantom 3, DJI Inspire 

1 GCS and flight control software is provided in the User Manual. DJI Phantom 3, DJI 

Inspire 1 User Manual is attached hereto as Exhibits C and D. 

b. Flight Operations Of DJI Phantom 3, DJI Inspire 1 UAS is Limited To The Line Of 

Sight Of A Pilot in Command With A Safety Observer. 

EDWARD STANZA will only utilize pilots who possess a current and valid medical 

certificate to act as a pilot in command (PIC) of the DJI Phantom 3, DJI Inspire 1 UAS. 

Additionally, a safety observer will assist all pilots during flight time. 

c. Flights Of DJI Phantom 3, DJI Inspire 1 UAS Will Be Conducted Pursuant To 

Specific Operating Limitations. 

In seeking this exemption, EDWARD STANZA proposes to commercially operate DJI 

Phantom 3, DJI Inspire 1 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 UASs weighing less than 55 pounds 

maximum gross weight: DJI Phantom 3, DJI Inspire 1 Unmanned Aircraft Systems. 

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

this grant. 

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

purpose of aerial video and photography. 

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

4. The UA must be operated at an altitude of no more than 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 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 
16 | Page

lenses. 

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 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 
17 | Page

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 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 current medical certificate. 

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

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

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

emergency maneuvers and maintaining appropriate distances from persons, vessels, 

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

with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator’s PICs are 

permitted under the terms of the exemption. However, training operations may only be 

conducted during dedicated training sessions. During training, proficiency, and experiencebuilding 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 

predetermined 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 
18 | Page

weather conditions) there is enough power to fly at normal cruising speed to the intended 

landing point and land the UA with 25% battery power remaining. 

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

markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as 

large as practicable. 

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

control of the UA must comply with the Federal Communications Commission (FCC) or 

other appropriate government oversight agency requirements. 

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

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

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

upon request. 

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

and activities at all times. 

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

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

(persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, 

and structures unless: 

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

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

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

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

UA, flight operations must cease immediately and/or; 

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

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

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

determined that it does not present an undue hazard, and; 

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

present an undue hazard to those persons per § 91.119(a). 

32. All operations shall be conducted over private or controlled-access property with 
19 | Page

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. 

EDWARD STANZA 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, DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum 

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

Phantom 3, DJI Inspire 1 UAS in a manner consistent with the exemption, including evasive 

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

vehicles and structures. 

EDWARD STANZA’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). 

EDWARD STANZA will not allow any PIC to operate the DJI Phantom 3, DJI Inspire 1 UAS 

unless that PIC has demonstrated, by meeting minimum flight-hour requirements or the DJI 

Phantom 3, DJI Inspire 1 UAS training and currency requirements, that the PIC is able to 

safely operate the DJI Phantom 3, DJI Inspire 1 UAS in a manner consistent with this 

exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. 

Specifically, the PIC must have accumulated and logged, in a manner consistent 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 
20 | Page

that was obtained in compliance with applicable regulations will ensure an equivalent level 

of safety during EDWARD STANZA’S proposed operations. The Administrator has held 

that prior documented flight experience that was obtained in compliance with applicable 

regulations would ensure safe operations, stating as follows: 

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

the purpose of motion picture filming (or similar operations), the PIC must have 

accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of 

total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS 

pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the 

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

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

exemption. For clarification, the FAA considers these minimum hour requirements to 

be inclusive rather than additive; i.e. 5 hours make and model time may be included 

in the 10 hours of multi-rotor time and the 10 hours may be included in the total 25 

hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must 

accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The 

FAA finds that at a minimum, the flight-hour requirements in Exemption No. 11062 are 

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

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

experience that was obtained in compliance with applicable regulations would satisfy this 

requirement. Training, proficiency, and experience building flights can also be conducted 

under the grant of exemption to accomplish the required flight time. During training, 

proficiency, and experience-building flights the PIC is required to operate the UA with 

appropriate distances in accordance with 14 C.F.R 91.119. 

Exemption No. 11138 at page 15. 

Accordingly, EDWARD STANZA will ensure safe operations by not allowing any PIC 

to operate the DJI Phantom 3, DJI Inspire 1 UAS unless that PIC has demonstrated, by 

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

operate the DJI Phantom 3, DJI Inspire 1 UAS in a manner consistent with the exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from 

people, vessels, vehicles and structures. 

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

Would Not Adversely Affect Safety. 

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

because prior to every flight, EDWARD STANZA will ensure that the DJI Phantom 3, DJI 

Inspire 1 UAS is in an airworthy condition based upon the UAS’s compliance with its 

operating documents and as stated in the conditions and limitations herein. 

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

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

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

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

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, DJI Inspire 1 UA 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 EDWARD STANZA’S operation of the DJI Phantom 3, 

DJI Inspire 1 UA 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 onboard the aircraft. Prior to each flight, a zero altitude initiation point is 

automatically established by the UASs at ground level. 

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

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

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

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

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

Would Not Adversely Affect Safety. 

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

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

Phantom 3, DJI Inspire 1 UAS; (2) the limitations on the proposed flight operations; and (3) 

the location of the proposed flight operations. Accordingly, EDWARD STANZA will ensure 

that it will safely operate the battery powered DJI Phantom 3, DJI Inspire 1 UA 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, DJI 

Inspire 1 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, DJI Inspire 1 

UAS provide audible and visual warnings to the PIC at the GCS when the UAs experiences 

low battery voltage, the first warning occurring at approximately 33% remaining battery 

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

level, the DJI Phantom 3, DJI Inspire 1 UAS 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). 
22 | Page

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, EDWARD STANZA 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 EDWARD STANZA 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., Monthly Maintenance Log, and DJI 

Phantom 3, DJI Inspire 1 Instruction Manual). Furthermore, EDWARD STANZA will 

document and maintain all maintenance records for the DJI Phantom 3, DJI Inspire 1 UAS. 

Since the DJI Phantom 3, DJI Inspire 1 UAS will be inspected as prescribed by the 

operating documents, EDWARD STANZA 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, DJI Inspire 1 User Manual is attached hereto as Exhibit B; a copy of the DJI 

Phantom 3, DJI Inspire 1 UAS Maintenance LOG is attached hereto as Exhibit C. 

Likewise, the exemption sought will not adversely affect safety because EDWARD STANZA

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, DJI Inspire 1 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 

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 EDWARD STANZA’s proposed operating limitations, the operating 

documents, and the technical aspects of the DJI Phantom 3, DJI Inspire 1 UAS, EDWARD 

STANZA 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, EDWARD STANZA requests 

that the FAA prescribe special conditions for the intended operation of the DJI Phantom 3, 

DJI Inspire 1 UAS, which contain such safety standards that the Administrator finds 
23 | Page

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, DJI Inspire 1 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 subchapter do not contain 

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

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

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

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

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

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

See 14 C.F.R. § 21.16. 

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

may prescribe special conditions for Edward Stanza’s intended operation of the DJI 

Phantom 3, DJI Inspire 1 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 Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 

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

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

From Which EDWARD STANZA Seeks Exemption: 

EDWARD STANZA 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 EDWARD STANZA Seeks: 

This exemption will permit EDWARD STANZA to commercially operate an Unmanned 

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

certain areas of the United States. 
24 | Page

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

STANZA’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, EDWARD STANZA’S request for exemption may be 

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

above. 

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

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

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

certification. 

As discussed in detail above, EDWARD STANZA will operate the DJI Phantom 3, DJI 

Inspire 1 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. 

CONCLUSION 

As set forth herein, EDWARD STANZA 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 3, DJI Inspire 1 UAS 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 EDWARD STANZA to safely, 

efficiently, and economically operate the DJI Phantom 3, DJI Inspire 1 UAS commercially 

within the NAS. 

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

Modernization and Reform Act of 2012, Section 333, EDWARD STANZA 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 EDWARD STANZA to operate the 

DJI Phantom 3, DJI Inspire 1 UAS commercially for the purpose of conducting aerial video 

and photography over certain areas of the United States. Dated: September 11, 2015 

Respectfully submitted, 

EDWARD STANZA

_________________________ 

Edward Stanza

1954 Argyle Ave. #D

Los Angeles, CA 90068

Tel: (409) 599-9846

edwardstanza@yahoo.com
25 | Page

Appendices: 

A – DJI Phantom 3 Specifications Data Sheet 

B – DJI Inspire 1 Specifications Data Sheet 

C – DJI Phantom 3 Manufacturer’s User Manual 

D – DJI Inspire 1 Manufacturer’s User Manual 

E – Monthly Maintenance Log 

APPENDIX – A 

DJI Phantom 3 TECHNICAL SPECIFICATIONS 

EDWARD STANZA only utilizes safe and reliable UASs. DJI is an industry leader in small 

UAS production. DJI UASs are loaded with ground breaking software enabling the user to 

set parameters which will not allow flight into controlled airspace. Parameters can also be 

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

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

location information to the PIC via the linked monitor (smart phone/tablet devices) 

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 

Camera 

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

Lens FOV 94° 20 mm (35 mm format equivalent) f/2.8, focus at ∞ 

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

Shutter Speed 8s -1/8000s 

Image Max Size 4000 x 3000 

Still Photography Modes 

•Single Shot 

•Burst Shooting: 3/5/7 shots 

•Auto Exposure Bracketing (AEB): 3/5 

•Bracketed Frames at 0.7EV Bias 
26 | Page

•Time-lapse 

Video Recording Modes 

Phantom 3 Professional 

•UHD: 4096x2160p 24/25, 3840x2160p 24/25/30 

•FHD: 1920x1080p 24/25/30/48/50/60 

•HD: 1280x720p 24/25/30/48/50/60 

Phantom 3 Advanced 

•FHD: 1920x1080p 24/25/30/48/50/60 

•HD: 1280x720p 24/25/30/48/50/60 

Supported SD Card Types 

Micro SD Max capacity: 64 GB. Class 10 or UHS-1 rating required 

Max Bitrate of Video Storage 

Phantom 3 Professional 60 Mbps 

Phantom 3 Advanced 40 Mbps 

Supported File Formats 

•FAT32/exFAT 

•Photo: JPEG, DNG 

•Video: MP4, MOV (MPEG-4 AVC/H.264) 

Operating Temperature 0°C to 40°C 

Gimbal 

Controllable Range Pitch -90° to +30° 

Stabilization 3-axis (pitch, roll, yaw) 

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 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 

Mobile Device Holder 

For tablet or phone 

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

Transmitter Power (EIRP) 

•FCC: 20 dBm 
27 | Page

•CE: 16 dBm 

Working Voltage 1.2 A @7.4 V 

Battery Charger 

Voltage 17.4 V 

Rated Power 

Phantom 3 Professional 

•100 W

Phantom 3 Advanced 

•57 W

Intelligent Flight Battery 

Capacity 4480 mAh 

Voltage 15.2 V 

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

App / Live View

Mobile App DJI Pilot 

EIRP 100mW

Live View Working Frequency 2.4GHz ISM 

Live View Quality 720P @ 30fps (depending on conditions and mobile device) 

Latency 220ms (depending on conditions and mobile device) 

Required Operating Systems 

•iOS 8.0 or later 

•Android 4.1.2 or later 

Recommended Devices 

•iOS: iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air Wi-Fi + Cellular, iPad mini 2, 

iPad mini 2 Wi-Fi + Cellular, iPad Air 2, iPad Air 2 Wi-Fi + Cellular, iPad mini 3, and iPad 

mini 3 Wi-Fi + Cellular. This app is optimized for iPhone 5s, iPhone 6, and iPhone 6 Plus 

•Android: Samsung S5, Note 3, Sony Xperia Z3, Google Nexus 7 II, Google Nexus 9, Mi 3, 

Nubia Z7 mini 

APPENDIX – B 

DJI Inspire 1 TECHNICAL SPECIFICATIONS 

EDWARD STANZA only utilizes safe and reliable UASs. DJI is an industry leader in small 

UAS production. DJI UASs are loaded with ground breaking software enabling the user to 

set parameters which will not allow flight into controlled airspace. Parameters can also be 

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

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

location information to the PIC via the linked monitor (smart phone/tablet devices) 
28 | Page

Aircraft 

Model T600 

Weight (Battery Included) 2935 g 

Hovering Accuracy (GPS mode) Vertical: 0.5 m 

Horizontal: 2.5 m

Max Angular Velocity Pitch: 300°/s 

Yaw: 150°/s 

Max Tilt Angle 35° 

Max Ascent Speed 5 m/s 

Max Descent Speed 4 m/s 

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

Max Flight Altitude 4500 m 

Max Wind Speed Resistance 10 m/s 

Max Flight Time Approximately 18 minutes 

Motor Model DJI 3510 

Propeller Model DJI 1345 

Indoor Hovering Enabled by default 

Operating Temperature Range -10° to 40° C 

Diagonal Distance 559 to 581 mm 

Dimensions 438x451x301 mm 

Gimbal 

Model ZENMUSE X3 

Output Power (with camera) Static: 9 W 

In Motion: 11 W

Operating Current Station: 750 mA 

Motion: 900 mA 

Angular Vibration Range ±0.03° 

Mounting Detachable 

Controllable Range Pitch: -90° to +30° 

Pan: ±320° 

Mechanical Range Pitch: -125° to +45° 

Pan: ±330° 

Max Controllable Speed Pitch: 120°/s 

Pan: 180°/s 

Camera 

Name X3 

Model FC350 

Total Pixels 12.76M 

Effective Pixels 12.4M 

Image Max Size 4000x3000 

ISO Range 100-3200 (video) 

100-1600 (photo) 

Electronic Shutter Speed 8s - 1/8000s 
29 | Page

FOV (Field of View) 94° 

CMOS Sony EXMOR 1/2.3” 

Lens 20mm (35mm format equivalent)f/2.8 focus at ∞ 

9 Elements in 9 groups 

Anti-distortion 

Still Photography Modes 

Single shoot 

Burst shooting: 3/5/7 frames 

Auto Exposure Bracketing (AEB): 3/5 bracketed frames at 0.7EV Bias 

Time-lapse 

Video Recording Modes 

UHD (4K): 4096x2160p24/25, 3840x2160p24/25/30 

FHD: 1920x1080p24/25/30/48/50/60 

HD: 1280x720p24/25/30/48/50/60 

Max Bitrate of Video Storage 60 Mbps 

Supported File Formats 

FAT32/exFAT 

Photo: JPEG, DNG 

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

Supported SD Card Types 

Micro SD 

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

Operating Temperature Range 0° to 40° C 

Remote Controller 

Name C1 

Operating Frequency 5.725~5.825 GHz 

2.400~2.483 GHz 

Transmitting Distance (outdoor and unobstructed) 2 km 

EIRP 10dBm@900m, 13dBm@5.8G, 20dBm@2.4G 

Video Output Port USB, mini-HDMI 

Power Supply Built-in battery 

Charging DJI charger 

Dual User Capability Host-and-Slave connection 

Mobile Device Holder Tablet or Phone 

Max Mobile Device Width 170mm 

Output Power 9 W

Operating Temperature Range -10° to 40° C 

Storage Temperature Range Less than 3 months: -20° to 45° C 

More than 3 months: 22° to 28° C 

Charging Temperature Range 0-40° C 

Battery 6000 mAh LiPo 2S 

Charger 

Model A14-100P1A 

Voltage 26.3 V 

Rated Power 100 W
30 | Page

Battery (Standard) 

Name Intelligent Flight Battery 

Model TB47 

Capacity 4500 mAh 

Voltage 22.2 V 

Battery Type LiPo 6S High voltage battery 

Energy 99.9 Wh 

Net Weight 570 g 

Operating Temperature Range -10° to 40° C 

Storage Temperature Range Less than 3 months: -20° to 45° C 

More than 3 months: 22° C to 28° C 

Charging Temperature Range 0° to 40° C 

Max Charging Power 180 W

Battery (Optional) 

Name Intelligent Flight Battery 

Model TB48 

Capacity 5700 mAh 

Voltage 22.8 V 

Battery Type LiPo 6S 

Energy 129.96 Wh 

Net Weight 670 g 

Operating Temperature Range -10° to 40° C 

Storage Temperature Range Less than 3 months: -20 to 45° C 

More than 3 months: 22° to 28° C 

Charging Temperature Range 0° to 40° C 

Max Charging Power 180 W

Vision Positioning 

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

Altitude Range 5-500 cm 

Operating Environment Brightly lit (lux > 15) patterned surfaces 

Operating Range 0-250 cm 

App / Live View

Mobile App DJI Pilot 

EIRP 100mW

Live View Working Frequency 2.4GHz ISM 

Live View Quality 720P @ 30fps (depending on conditions and mobile device) 

Latency 220ms (depending on conditions and mobile device) 

Required Operating Systems 

•iOS 8.0 or later 

•Android 4.1.2 or later 

MONTH:__________YEAR:__________UAS #DATE (ISSUE DISCOVERED)DATE (ISSUE 

CORRECTED)ISSUE DESCRIPTION & MAINTENANCE CONDUCTEDMAINTENANCE PERFORMED 

BY: (PRINT & SIGN)SOFTWAREUPUPDATESAIRFRAMEENGINESCAMERALANDING 

GEARVIBRATIONDAMPENINGOTHER:UAS MONTHLY MAINTENANCE LOG
31 | Page

Recommended Devices 

•iOS: iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air Wi-Fi + Cellular, iPad mini 2, 

iPad mini 2 Wi-Fi + Cellular, iPad Air 2, iPad Air 2 Wi-Fi + Cellular, iPad mini 3, and iPad 

mini 3 Wi-Fi + Cellular. This app is optimized for iPhone 5s, iPhone 6, and iPhone 6 Plus 

•Android: Samsung S5, Note 3, Sony Xperia Z3, Google Nexus 7 II, Google Nexus 9, Mi 3, 

Nubia Z7 mini 

APPENDIX – C 

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

APPENDIX – D 

http://www.dji.com/product/inspire-1/download 

APPENDIX – E