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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: MICHAEL J. RYANFOR AN EXEMPTION SEEKING 

RELIEF FROM THE REQUIREMENTS OFTITLE 14 OF THE CODE OF FEDERAL REGULATIONSSECTIONS 

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 OPERATIONDJI Inspire 1 and DJI Phantom 3 UNMANNED AIRCRAFT SYSTEMS 

and a BLANKET EXEMPTION FOR UAS OPERATION LESS THAN 55 POUNDS, DAYLIGHT OPERATION, 

VLOS, VFR AND BELOW 200 FEET AGL. 

PURSUANT TO SECTION 333 OFTHE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95) Submitted on JUNE 16, 2015 

MICHAEL J. RYAN 63 Peeksville Road, Locust Grove, GA 30148 

770-402-2848 MJPRYAN@MINDSPRING.COM 
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TABLE OF CONTENTS

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

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

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

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

UNMANNED AIRCRAFT SYSTEMS: DJI PHANTOM 3 (HEREAFTER THE DJI UAS AIRCRAFT) ........5

BASIS FOR PETITION ......................................................................................................................................................6

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

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH MICHAEL J. RYAN SEEKS EXEMPTION. ......7 

THE EXTENT OF RELIEF MICHAEL J. RYAN SEEKS AND THE REASON MICHAEL J. RYAN 

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

THE REASONS WHY GRANTING MICHAEL J. RYAN REQUEST WOULD BE IN THE PUBLIC 

INTEREST; THAT IS, HOW IT WOULD BENEFIT THE PUBLIC AS A WHOLE. ....................................11

THE REASONS WHY THE DJI UAS AIRCRAFT MEET THE CONDITIONS OF THE FAA 

MODERNIZATION AND REFORM ACT OF 2012 (FMRA) SECTION 333.................................................13

THE REASONS WHY GRANTING THIS EXEMPTION WOULD NOT ADVERSELY AFFECT 

SAFETY ..............................................................................................................................................................19

CONCLUSION .................................................................................................................................................................22
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GLOSSARY OF ABBREVIATIONS 

COA Certificate of Authorization 

FAA Federal Aviation Administration 

FAR Federal Aviation Regulation 

GCS Ground Control Station 

GPS Global Positioning System 

LOL Loss of Link 

NAS National Airspace System 

NOTAM Notice to Airman 

PIC Pilot In Command 

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

SO Safety Observer 

SOP Standard Operating Procedures 

UA Unmanned Aircraft 

UAS Unmanned Aircraft System 

VFR Visual Flight Rules 

VLOS Visual Line of Site 

VMC Visual Meteorological Conditions 

VTOL Vertical Takeoff and Landing 

DJI UAV manufacturer

ESC Electronic speed control

FPV First Person View 

LI-PO Lithium Polymer battery

RCV Radio Controlled vehicle 
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SUMMARY

MICHAEL J. RYAN 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 MICHAEL J. 

RYAN to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and 

photography in support of small business, community and charitable activities in and around the State of New York. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

MICHAEL J. RYAN’s primary occupation is a teacher, college professor and media scholar and has considerable experience as a 

UAS hobbyist. From time to time he is asked to support local community, small business, and charitable activities by 

providing commercial aerial photography or videography. In the absence of the exemption, Michael J. Ryan must decline 

to support these interests. The objective of MICHAEL J. RYAN and his aerial operations is to provide high quality 

imaging for a variety of commercial, public, and residential uses that are incidental to his primary occupation, specifically 

targeting:

• Marketing 

• Construction sites before and after 

• Appraisals 

• Motion Picture Filming 

• Aerial acquisitions for inspections of public and private structures. 

• Building Inspection operations 
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BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 3 (Hereafter the DJI UAS Aircraft) MICHAEL J. RYAN seeks an exemption to 

operate DJI Phantom 3 UAS systems for compensation or hire within the NAS. The DJI Phantom 3 is a vertical takeoff and 

landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone 

systems. DJI Phantom 3 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height 

of 11.8 inches, and a maximum speed of approximately 30 knots. The Phantom 3 is equipped with four main rotors; driven by 

Lithium Polymer battery powered electric motors. 

The DJI Phantom 3 will be operated by MICHAEL J. RYAN and 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, MICHAEL J. RYAN, 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 UAS Aircraft 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, 

MICHAEL J. RYAN operation DJI UAS Aircraft 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, MICHAEL J. RYAN 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. 

MICHAEL J. RYAN submits that the requested relief is proper since an equivalent level of safety will be ensured. MICHAEL J. 

RYAN 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. 

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is 

requested by MICHAEL J. RYAN to the extent necessary to allow a Pilot in Command (PIC) with significant experience in the 

field of UAV’s, and who has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to 

safely operate the DJI UAS Aircraft in a manner consistent with this exemption, including evasive and emergency maneuvers and 

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

MICHAEL J. RYAN seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the DJI UAS Aircraft do not

require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, MICHAEL J. RYAN submits that he 

will ensure the DJI 

UAS Aircraft are in an airworthy condition, prior to every flight, by determining that the UASs are in compliance with the 

operating documents and that the aircraft are in a condition for safe flight. 

MICHAEL J. RYAN also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings, DJI UAS 

aircraft will not have a typical barometric altimeter onboard. However, altitude information of the DJI UAS Aircraft 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 active monitoring of the flight path. This altitude information, combined with MICHAEL J. 

RYAN operation of the DJI UAS Aircraft within visual line of sight, at or below 400 feet AGL, will ensure a level of safety 

equivalent to Section 91.121. 

Additionally, MICHAEL J. RYAN seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for 

flight in VFR conditions. MICHAEL J. RYAN submits that safety will not be affected by operation of the DJI UAS Aircraft 

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

after that for at least 5minutes. 

In accordance with 14 C.F.R. § 11.81, MICHAEL J. RYAN provides the following information in support of its petition for 

exemption: 

Name And Address Of The Petitioner.

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

MICHAEL J. RYAN 63 Peeksville Road., Locust Grove, GA 30148 770-402-2848 (Mobile) mjpryan@mindspring.com
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The Specific Sections Of 14 C.F.R. From Which MICHAEL J. RYAN Seeks Exemption

MICHAEL J. RYAN 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: 

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.A private pilot may, for 

compensation or hire, act as PIC of an aircraft in connection with any business or employment if—

The flight is only incidental to that business or employment; andThe aircraft does not carry passengers or property for 

compensation or hire. 

MICHAEL J. RYAN 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. 

MICHAEL J. RYAN Seeks Exemption From The Requirements Of Section 91.121. 

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

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—Below 18,000 feet MSL, to--

The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft;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 

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. 

MICHAEL J. RYAN 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. 

MICHAEL J. RYAN 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—

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[.] 
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MICHAEL J. RYAN 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: 

No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration 

unless-- It has been approved for return to service by a person authorized under § 43.7 of this chapter[.] 

MICHAEL J. RYAN 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: 

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 -- 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 An inspection for the issuance of an airworthiness 

certificate in accordance with part 21 of this chapter. 

MICHAEL J. RYAN Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b). 

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

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: 

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--

• A description (or reference to data acceptable to the Administrator) of the work performed; and 

• The date of completion of the work performed; and 

• The signature and certificate number of the person approving the aircraft for return to service. 

• Records containing the following information: 

• The total time in service of the airframe, each engine, each propeller, and each rotor. 

• The current status of life-limited parts of each airframe, engine, propeller, rotor, and appliance. 

• The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a 

specified time basis. 

• 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. 

• 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. 

• 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. The owner or operator shall retain the following records for 

the periods prescribed: 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. 

• 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.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. 
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The Extent of Relief MICHAEL J. RYAN Seeks and The Reason MICHAEL J. RYAN Seeks the Relief.

Extent of Relief MICHAEL J. RYAN Seeks and The Reason MICHAEL J. RYAN 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, MICHAEL J. RYAN submits that an equivalent level of safety will be maintained because no PIC 

will be allowed to operate the DJI Inspire 1,DJI Phantom 2 UAS or DJI Phantom 3 UAS unless that PIC has met certain flighthour and currency requirements, demonstrating that the PIC is able to safely operate either the DJI Inspire 1, DJI Phantom 2 or DJI 

Phantom 3 UAS in a manner consistent with the operations specifications as described in this exemption, including evasive and 

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

Further, MICHAEL J. RYAN submits that all flights of DJI UAS aircraft, conducted by the PIC pursuant to the grant of this 

Petition: (1) will be incidental to MICHAEL J. RYAN business; and (2) will not carry passengers or property for compensation or 

hire. 

Extent of Relief MICHAEL J. RYAN Seeks and The Reason MICHAEL J. RYAN 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 MICHAEL J. RYAN to 

determine that the DJI UAS Aircraft are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with 

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

Aircraft Instruction Manual). 

MICHAEL J. RYAN seeks the requested relief because the DJI UAS Aircraft do not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. Therefore, MICHAEL J. RYAN will ensure that the DJI UAS Aircraft are in 

airworthy condition based upon its compliance with the operating documents (i.e., Monthly 

Maintenance Log, and DJI UAS Aircraft Instruction Manual) prior to every flight, and further, determine that the aircraft are in 

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

Extent of Relief MICHAEL J. RYAN Seeks and The Reason MICHAEL J. RYAN Seeks Relief from Section 91.121. 

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the DJI UAS Aircraft, 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), MICHAEL E OLSEN seeks 

the requested relief because the DJI UAS Aircraft 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 UAS Aircraft 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. 
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Extent of Relief MICHAEL J. RYAN Seeks and The Reason MICHAEL J. RYAN 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 UAS Aircraft during daylight hours in visual meteorological conditions (VMC), under visual 

flight rules (VFR), for a total duration of 15 minutes to the first point of intended landing and, assuming normal cruising speed, to 

fly after that for at least 5 minutes. MICHAEL J. RYAN seeks the requested relief because without an exemption from Section 

91.151(b), the flight time duration of the battery powered DJI UAS Aircraft will severely constrain the practicality of any aerial 

video or still photo flight operations that MICHAEL J. RYAN proposes to conduct pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the DJI UAS Aircraft operating documents, and MICHAEL J. 

RYAN proposed operating limitations, ensure that MICHAEL J. RYAN will safely operate the battery powered DJI UAS Aircraft 

during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to

fly for a total duration of 15 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for 

at least 5 minutes. 

Extent of Relief MICHAEL J. RYAN Seeks and The Reason MICHAEL J. RYAN 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, MICHAEL J. RYAN requests relief from these 

Sections because the DJI UAS Aircraft do not require airworthiness certificates. As set forth more fully below, DJI UAS Aircraft 

meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. 

Accordingly, MICHAEL J. RYAN will use trained technicians to perform maintenance, alterations, or preventive maintenance on 

the UASs using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the MICHAEL J. RYAN 

Aerial Operations Manual, Monthly Maintenance Log, and DJI UAS Aircraft Instruction Manual). Furthermore, MICHAEL J. 

RYAN will document and maintain all maintenance records for the DJI UAS Aircraft. 
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The Reasons Why Granting MICHAEL J. RYAN 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 MICHAEL J. RYAN 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 UAS Aircraft will decrease congestion of the NAS, reduce pollution, and provide significant benefits 

to the economy. Notably, the benefits of MICHAEL J. RYAN proposed operation of the DJI UAS Aircraft will be realized without 

implicating any privacy issues.

The Public Will Benefit from Decreased Congestion of The NAS. 

DJI UAS Aircraft 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 a DJI UAS Aircraft 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 UAS Aircraft 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. 

The Public Will Benefit from The Safety and Efficiency of The DJI UAS Aircraft 

Conducting aerial acquisitions with the DJI UAS Aircraft, 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 UAS Aircraft 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 UAS aircraft, 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 UAS Aircraft 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 DJI UAS Aircraft(weighing 

approximately 2 pounds 11 ounces and 6 pounds 7.5 ounces respectively, at their maximum gross weights with lengths of 16 

inches and 17.3 inches respectively, widths of 16 inches and 17.7 inches respectively, and with no fuel on board), has less physical 

potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that 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). 

Performing Aerial Video and Photography Operations with The DJI UAS Aircraft Will Benefit the Economy. 

In addition to being safe and efficient, the DJI UAS Aircraft are also an economical alternative to using manned aircraft to conduct 

similar aerial operations. As such, operation of the DJI UAS Aircraft will allow United States based companies, like MICHAEL E 

OLSEN, 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 UAS Aircraft 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. 
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By operating the DJI UAS aircraft, petitioners such as MICHAEL J. RYAN 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 UAS Aircraft, provides a stable workforce 

that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and 

development in order to remain competitive both in the United States and abroad. 

There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for decades, MICHAEL J. RYAN proposed 

operation of the DJI UAS Aircraft will not implicate any privacy issues. Specifically, the DJI UAS Aircraft will be operated only 

in compliance with operating documents (i.e., the MICHAEL J. RYAN Aerial Operations Manual, Monthly Maintenance Log, and 

DJI UAS Aircraft Instruction Manual) which requires property owner involvement as well as local law enforcement notification, 

and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119. 
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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 MICHAEL J. RYAN Seeks Exemption. 

Reasons Why The DJI UAS Aircraft 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, 

MICHAEL J. RYAN operation of the DJI UAS Aircraft 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: 

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. 

Assessment of Unmanned Aircraft Systems. --In making the determination under subsection (Secretary shall determine, at a 

minimum—

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 

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). 

Requirements for Safe Operation. —

If the Secretary determines under this section that certain u)nmanned 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, MICHAEL J. RYAN submits that the DJI UAS Aircraft can operate safely in the NAS pursuant to 

FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI UAS aircraft; (b) the pilot certification requirement; and 

(c) the specific operating limitations. 

The Specifications of The DJI UAS Aircraft Demonstrate Its Safe Characteristics. 

The DJI UAS Aircraft 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. 

Technical Specifications of DJI UAS Aircraft. 

The technical specifications of the DJI UAS Aircraft are set forth by the DJI UAS aircraft User Manual, attached hereto as 

Appendix A. 

The DJI UAS Aircraft Autonomous Flight and Navigation Modes Enable The UASs to Remain Within a Defined Operational Area. 

The DJI UAS Aircraft may be operated in both manual and fully autonomous flight 16 modes. A complete description of the flight 

and navigational modes of the DJI UAS Aircraft provided in the User Manual, attached hereto as Appendix A. 

The DJI UAS Aircraft Are Designed for Automatic Return to Home Point or Hover in The Event of Loss of the Control Link or 

Navigation. 
14

When the Control Link is lost, the DJI UAS Aircraft will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the 

DJI UAS Aircraft do 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 UAS aircraft are described in the User Manual, attached hereto as 

Appendix A.

DJI UAS Aircraft GCS Operation. 

Phantom 3 GCS and flight control software is provided in the User Manual for the DJI UAS aircraft attached hereto as Appendix 

A. 

Flight Operations of DJI UAS Aircraft are Limited to The Line of Sight of a Certificated Pilot in Command with A Safety 

Observer. 

MICHAEL J. RYAN will be the only person to act as a pilot in command (PIC) of DJI UAS Aircraft. 

Flights of DJI UAS Aircraft Will Be Conducted Pursuant to Specific Operating Limitations. 

In seeking this exemption, MICHAEL J. RYAN proposes to commercially operate DJI UAS Aircraft 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 UAS AIRCRAFT. 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 45 knots. 17 

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL), as indicated by the 

procedures specified in the operating documents unless a special request is made and approved by ATC. All altitudes 

reported to ATC must be in feet AGL. 

5. The UAs must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to 

use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA-issued airman 

medical certificate. 

6. 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. T 

9. he operating documents and the grant of exemption must be accessible during UAS operations and made available to the 
15

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 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 UASs 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. 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 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. 

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

18. § 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. 

19. The UAV may not operate within 5 nautical miles of an airport reference point 19 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 
16

must be made available to the Administrator upon request. 

20. The UAV 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. 

21. If the UAV 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. 

22. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating 

documents. 

23. 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 UAV with 25% battery power remaining. 

24. 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. 

25. 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. 

26. Before conducting operations, the radio frequency spectrum used for operation and control of the UAV must comply with 

the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 

27. 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. 

28. The UAV must remain clear and yield the right of way to all manned aviation operations and activities at all times. 

29. The UAV may not be operated by the PIC from any moving device or vehicle. 

30. 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: 

31. Barriers or structures are present that sufficiently protect nonparticipating persons from the UAV 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; 

32. 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; 

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

per § 91.119(a). 
17

34. 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. 

35. 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. 

36. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB 

Web site: www.ntsb.gov. 
18

Reasons Why an Exemption from The Requirements of Section 61.113(a) And (b) Would Not Adversely Affect Safety.

MICHAEL J. RYAN 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 UAS Aircraft unless that PIC has demonstrated, by meeting minimum flighthour and currency requirements, that the PIC is able to safely operate the DJI UAS Aircraft in a manner consistent with the 

exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and

structures. 

Considering MICHAEL J. RYAN proposed area of operations, and the operating limitations set forth-above; the parallel nature of 

private pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062); and the 

airmanship skills necessary to safely operate the DJI UAS aircraft, MICHAEL J. RYAN submits that the training, preparation, 

practice, and experience of the Petitioner is sufficient to meet the requirements of the proposed use. 

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). 

MICHAEL J. RYAN will not allow any PIC to operate the DJI UAS Aircraft unless the PIC has demonstrated, by meeting 

minimum flight-hour requirements or the DJI UAS Aircraft training and currency requirements, that the PIC is able to safely 

operate the DJI UAS Aircraft 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 MICHAEL J. RYAN 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 UAS with appropriate distances in accordance with 14 C.F.R 91.119. 

Exemption No. 11138 at page 15. 

Accordingly, MICHAEL J. RYAN will ensure safe operations by not allowing any PIC to operate DJI UAS Aircraft unless that 

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

UAS Aircraft in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. 
19

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, MICHAEL J. RYAN 

will ensure that DJI UAS Aircraft is in an airworthy condition based upon the UAS’s compliance with its operating documents and 

as stated in the conditions and limitations herein. 

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

respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 

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

Reasons 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 UAS 

Aircraft 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 MICHAEL J. 

RYAN operation of the DJI UAS Aircraft 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 23 circumstances similar, in all material respects, 

to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 

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

Reasons Why an Exemption from The Requirements of Section 91.151(b) Would Not Adversely 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 UAS Aircraft; (2) the limitations on the proposed flight operations; and (3) the location of 

the proposed flight operations. Accordingly, MICHAEL J. RYAN will ensure that it will safely operate the battery powered DJI 

UAS Aircraft during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 15 minutes to the 

first point of intended landing and, assuming normal cruising speed, to fly after that for at least 5 minutes. 

Here, as in Exemption No. 11109, the technical specifications of the DJI UAS Aircraft UASs; 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 UAS Aircraft 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 Vision+ and 

DJI Phantom 3 UASs 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). 

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, MICHAEL J. RYAN 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 MICHAEL J. RYAN will use trained technicians to perform maintenance, alterations, or preventive 

maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., the MICHAEL

J. RYAN Aerial Operations Manual, Monthly Maintenance Log, and DJI UAS Aircraft Instruction Manual). 

Furthermore, MICHAEL J. RYAN will document and maintain all maintenance records for the DJI UAS Aircraft UASs. 
20

Since the DJI UAS Aircraft will be inspected as prescribed by the operating documents, MICHAEL J. RYAN 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 UAS Aircraft User 

Manual is attached hereto as Appendix A; a copy of the DJI UAS Aircraft Maintenance LOG is attached hereto as Appendix B.

Likewise, the exemption sought will not adversely affect safety because MICHAEL J. RYAN 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 UAS Aircraft 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 MICHAEL J. RYAN proposed operating limitations, the operating documents, and the technical aspects of the

DJI UAS Aircraft, MICHAEL J. RYAN 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). 

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, MICHAEL J. RYAN 

requests that the FAA prescribe special conditions for the intended operation of the DJI UAS Aircraft UASs, which contain such 

safety standards t hat the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. 

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

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAs for the 

limited purpose of conducting aerial video and photography over certain areas of the United States for compensation or hire. 

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the 

public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without 

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

NAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of the DJI UAS Aircraft 

UASs, 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 Leading 

Edge’s intended operation of the DJI UAS Aircraft, 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). 
21

A Summary That Can Be Published in The Federal Register, stating: The Rules from Which MICHAEL J. RYAN Seeks 

Exemption: 

MICHAEL J. RYAN 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 MICHAEL J. RYAN Seeks: 

This exemption will permit MICHAEL J. RYAN to commercially operate an Unmanned Aircraft System (UAS) for the purpose of 

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

Any Additional Information, Views, Or Arguments Available to Support MICHAEL J. RYAN 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, MICHAEL J. RYAN 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, MICHAEL J. RYAN will operate DJI UAS aircraft safely in the NAS, without creating a hazard to 

users of the NAS, or the public, or otherwise pose a threat to national security. 
22

CONCLUSION

As set forth herein, MICHAEL J. RYAN 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 UAS Aircraft 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 MICHAEL J. RYAN to safely, efficiently, 

and economically operate the DJI UAS Aircraft commercially within the NAS. 

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, 

Section 333, MICHAEL J. RYAN 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 Leading Edge to operate the DJI UAS Aircraft commercially for the purpose of conducting aerial 

video and photography over certain areas of the United States. 

Dated: June 16, 2015 

Attachments to this submission: 

DJI Phantom 3 Manual 

Very respectfully, 

Michael J. Ryan 63 Peeksville Road, Locust Grove, Georgia, 30248

770-402-2848

mjpryan@mindspring.com
23

APPENDIX – A

DJI PHANTOM 3 TECHNICAL SPECIFICATIONS 

MICHAEL J. RYAN 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. Further, DJI software provides real-time altitude and location 

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

Specifications 

Aircraft 

Weight (Battery & Propellers 

Included) 1280 g 

Max. Ascent Speed 5 m/s 

Max. Descent Speed 3 m/s 

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

Max. Flight Altitude 6000 m 

Max. Flight Time Approximately 23 minutes 

Operating Temperature 0°C to 40°C 

GPS Mode GPS/GLONASS 

Gimbal 

Controllable Range Pitch: - 90° to + 30° 

Vision Positioning 

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

Altitude Range 30 cm-300 cm 

Operating Range 30 cm-300 cm 

Operating Environment Brightly lit (lux > 15) patterned surfaces 

Camera 

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

Lens FOV 94° 20mm(35mm format equivalent ) f/2.8 

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

Electronic Shutter Speed 8s -1/8000s 

Image Max. Size 4000 x 3000 
24

Still Photography Modes 

Single shotBurst shooting: 3/5/7 

framesAuto Exposure Bracketing (AEB): 

3/5 Bracketed frames at 0.7EV Bias 

Time-lapse 

Supported SD Card Types Micro SDMax. capacity: 64 GB. Class 10 or UHS-1 rating required 

Video Recording Modes FHD:1920x1080p 24/25/30/48/50/60 HD:1280x720p 24/25/30/48/50/60 

Max. Bitrate Of Video 

Storage 40 Mbps 

Supported File Formats FAT32/exFATPhoto: JPEG, DNGVideo: MP4/MOV (MPEG-4 AVC/H.264) 

Operating Temperature 

Range 0°C to 40°C 

© 2015 DJI. All Rights Reserved. 53 

Remote Controller 

Operating Frequency 2.400 GHz-2.483 GHz 

Transmitting Distance 2000 m (Outdoor And 

Unobstructed) 

Video Output Port USB 

Operating Temperature 

Range 0°C- 40°C 

Battery 6000 mAh LiPo 2S 

Mobile Device Holder Tablets and smartphones 

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

Working Voltage 1.2 A @7.4 V 

Charger 

Voltage 17.4 V 

Rated Power 57 W 

Intelligent Flight Battery ( PH3-4480 mAh-15.2 V ) 

Capacity 4480 mAh 

Voltage 15.2 V 

Battery Type LiPo 4S 

Energy 68 Wh 

Net Weight 365 g 

Operating Temperature -10°C- 40°C 
25

Max. Charging Power 100 W 

All specifications can be found in the attached user manual or at http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Advanced_User_Manual_v1.2_en.pdf
26

Appendix B

DJI PHANTOM 3 ADVANCED MAINTENANCE LOG

Screenshot below: