UNITED STATES OF AMERICA

 DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

Regulatory Docket No. _______________ 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

IRONSIDES MOTION LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE 

CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL

OPERATION OF DJI PHANTOM 3 AND 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 July 13, 2015 

 

 

IRONSIDES MOTION LLC

www.IronsidesMotion.com

Kevin William Andrews

10657 CHERRYBROOK CIRCLE

 HIGHLANDS RANCH, CO 80126

 303-807-1972

kevin@denversteadicam.com
TABLE OF CONTENTS 

Page 

GLOSSARY OF 

ABBREVIATIONS.................................................................................................................3 

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

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

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

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

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

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH 

IRONSIDES MOTION SEEKS EXEMPTION..........................................................7 

THE EXTENT OF RELIEF AND 

THE REASON SEEKING THE RELIEF.........................9

 

THE REASONS WHY GRANTING REQUEST

WOULD BE IN THE PUBLIC INTEREST .............................................................11

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

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

CONCLUSION.......................................................................................................................19 

 
GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level 

AOI Area of Interest 

ATC Air Traffic Control 

ATO Air Traffic Organization

AV Aerial Vehicle 

CFR Code of Federal Regulations 

COA Certificate of Authorization 

FAA Federal Aviation Administration 

FAR Federal Aviation Regulation 

GCS Ground Control Station 

GPS Global Positioning System 

LOL Loss of Link 

NAS National Airspace System 

NOTAM Notice to Airman 

PIC Pilot In Command 

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

SO Safety Observer 

SOP Standard Operating Procedures 

UA Unmanned Aircraft 

UAS Unmanned Aircraft System 

VFR Visual Flight Rules 

VLOS Visual Line of Site 

VMC Visual Meteorological Conditions 

VTOL Vertical Takeoff and Landing 

DJI UAV manufacturer

ESC Electronic speed control

FPV First Person View 

LI-PO Lithium Polymer battery

RCV Radio Controlled vehicle 
 

SUMMARY

IRONSIDES MOTION LLC seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 

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

operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform 

Act of 2012 (FMRA). This exemption will permit IRONSIDES MOTION LLC to operate an 

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

photography for Marketing, film sets, real estate photography, commercials, special events, wedding 

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

INTRODUCTION AND INTERESTS OF THE PETITIONER

My name is Kevin William Andrews, and I am the owner of IRONSIDES MOTION LLC. As a drone 

operator(pilot) with expertise and knowledge in all aspects of building programing and operating 

multiple types of UAS'S along with camera set up and operation. IRONSIDES MOTION LLC also 

provides clients with the highest quality digital content for use in their commercial, personal, and nonprofit multimedia projects. Kevin Andrews has 15 years of television experience and 20 years of radio 

controlled vehicle experience. 

The objective of IRONSIDES MOTION LLC’s aerial video and photography operations is to provide 

high quality imaging for a variety of commercial, public, and residential uses. Kevin Andrews will also 

provide knowledge of UAS and promote safe UAS operations. 
BACKGROUND 

Unmanned Aircraft Systems: DJI Phantom 3, DJI Inspire 1 UASs

IRONSIDES MOTION LLC seeks an exemption to operate DJI systems for compensation or hire 

within the NAS. The DJI Phantom 3 and DJI Inspire 1 are vertical takeoff and landing (VTOL) 

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

phone systems. The DJI Phantom 3 has a maximum gross weight of approximately 2 pounds 14 

ounces, while having a length of 16 inches width of 16 inches, height of 8 inches, and a maximum 

speed of approximately 29 knots. The DJI Inspire 1 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 42 knots. The DJI Phantom 3 and DJI Inspire 1UAs are equipped with four main rotors; 

driven by Lithium Polymer battery powered electric motors. 

The DJI Phantom 3 and DJI Inspire 1 UAs that will be operated by Kevin Andrews 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 

Markings. 

BASIS FOR PETITION 

Petitioner, Kevin William Andrews (IRONSIDES MOTION LLC), pursuant to the provisions of the 

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

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

Administrator to commercially operate the DJI Phantom 3, DJI Inspire 1 UASs 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 of DJI Phantom 3 and DJI Inspire 1 UASs 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, IRONSIDES MOTION LLC requests relief from Sections 91.405(a), 91.407(a)(1), 

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

that only apply to aircraft with an airworthiness certificate. 

IRONSIDES MOTION LLC submits that the requested relief is proper since an equivalent level of 

safety will be ensured. IRONSIDES MOTION LLC 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 and DJI Inspire 1 Instruction Manual). Furthermore, IRONSIDES MOTION LLC will 

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

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and 
limitations: Pilot in command, is requested by IRONSIDES MOTION LLC to the extent necessary to 

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

medical certificate, and who has demonstrated, by meeting minimum flight- hour and currency

requirements, that the PIC is able to safely operate the DJI Phantom 3 and DJI Inspire 1 UASs in a 

manner consistent with this exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles and structures. 

IRONSIDES MOTION LLC seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, 

because the DJI Phantom 3 and DJI Inspire 1 UASs do not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. As such, IRONSIDES MOTION LLC submits that they

will ensure that the DJI Phantom 3 and DJI Inspire 1UASs are in an airworthy condition, prior to every

flight, by determining 

that the UASs are in compliance with the operating documents (i.e., Monthly Maintenance Log, and 

DJI Phantom 3 and DJI Inspire 1 Instruction Manual), and that the aircraft are in a condition for safe 

flight. 

IRONSIDES MOTION LLC also seeks an exemption from the requirements of Section 91.121, entitled 

Altimeter Settings, as the DJI Phantom 3 and DJI Inspire 1 UAs will not have a typical barometric 

altimeter onboard. However, altitude information of the DJI Phantom 3 and DJI Inspire 1UAs 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 IRONSIDES MOTION LLC’s operation of the DJI Phantom 

3and DJI Inspire 1 UASs within visual line of sight, at or below 500 feet AGL, will ensure a level of 

safety equivalent to Section 91.121. 

Additionally, IRONSIDES MOTION LLC seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. IRONSIDES MOTION LLC 

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

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

enough battery power to fly for a total duration of approximately 15.5 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, IRONSIDES MOTION LLC provides the following information 

in support of its petition for exemption: 

A. Name And Address Of The Petitioner.

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

Kevin William Andrews

IRONSIDES MOTION LLC

10657 Cherrybrook Circle

Highlands Ranch CO 80126

(303)-807-1972

 Email: kevin@denversteadicam.com
B. The Specific Sections Of 14 C.F.R. From Which IRONSIDES MOTION LLC Seeks Exemption.

1IRONSIDES MOTION LLC Seeks Exemption From The Requirements Of Section 61.113(a) And 

(b).

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

3

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

5 (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. 

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

business or employment if— 

7The flight is only incidental to that business or employment; and

8(2) The aircraft does not carry passengers or property for compensation or hire. 

9

102. IRONSIDES MOTION LLC Seeks Exemption From The Requirements Of Section 91.7(a). 

11Section 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.

12

13 3. IRONSIDES MOTION LLC 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-- 

1Below 18,000 feet MSL, to--

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

the aircraft; 

3(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 

4(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. IRONSIDES MOTION LLC 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. 

5IRONSIDES MOTION LLC Seeks Exemption From The Requirement Of Section 91.405(a).

6
7 Section 91.405, entitled Maintenance required, subsection (a), states the following: Each owner or 

operator of an aircraft— 

8(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[.] 

9

6. IRONSIDES MOTION LLC Seeks Exemption From The Requirements Of Section 

91.407(a)(1

6 Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or 

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

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

rebuilding, or alteration unless-- (1) It has been approved for return to service by a person authorized 

under § 43.7 of this chapter[.] 

8

97. IRONSIDES MOTION LLC Seeks Exemption From The Requirements Of Sections 

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

10Section 91.409, entitled Inspections, subsection (a), states the following: 

11(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 -- 

12(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 

13(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this 

chapter. 

14

15 8. IRONSIDES MOTION LLC Seeks Exemption From The Requirements Of Sections 91.417(a) 

And 91.417(b). 

16Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following: 

17(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: 

18Records 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--

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

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

21(iii) The signature, and certificate number of the person approving the aircraft for return to service.

22Records containing the following information:

23(i) The total time in service of the airframe, each engine, each propeller, and each rotor. 

24(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and appliance. 

25 (iii) The time since last overhaul of all items installed on the aircraft which are required to be 

overhauled on a specified time basis. 

26 (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. 

27 (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. 

28 (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. 

29
30(b) The owner or operator shall retain the following records for the periods prescribed: 

31(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. 

32(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. 

33(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. 

34

35 C. The Extent Of Relief IRONSIDES MOTION LLC Seeks And The Reason IRONSIDES 

MOTION LLC Seeks The Relief. 

361. Extent Of Relief IRONSIDES MOTION LLC Seeks And The Reason IRONSIDES MOTION 

LLC Seeks Relief From Section 61.113(a) And (b). 

37Relief 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, IRONSIDES MOTION LLC submits that an equivalent 

level of safety will be maintained because no PIC will be allowed to operate the DJI Phantom 3 UAS 

or DJI Inspire 1 UAS unless that PIC has met certain flight-hour and currency requirements, 

demonstrating that the PIC is able to safely operate either the DJI Phantom 3 or 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, IRONSIDES MOTION LLC submits that all flights of the DJI Phantom 3 and 

DJI Inspire 1 UASs, conducted by the PIC pursuant to the grant of this Petition: (1) will be 

incidental to IRONSIDES MOTION LLC’s business; and (2) will not carry passengers or 

property for compensation or hire. 

2Extent Of Relief IRONSIDES MOTION LLC Seeks And The Reason IRONSIDES MOTION LLC 

Seeks Relief From Section 91.7(a).

3

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the 

extent required to allow IRONSIDES MOTION LLC to determine that the DJI Phantom 3 and 

DJI Inspire 1 UASs are in airworthy condition prior to every flight by ensuring that the UAS is in 

compliance with the operating documents (i.e., IRONSIDES MOTION LLC Aerial Operations 

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

IRONSIDES MOTION LLC seeks the requested relief because the DJI Phantom 3 and 

DJI Inspire 1 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, 

Subpart H. Therefore, IRONSIDES MOTION LLC will ensure that the DJI Phantom 3 and DJI 

Inspire 1 UASs are in airworthy condition based upon its compliance with the operating 

documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 and DJI Inspire 1 Instruction 

Manual) prior to every flight, and further, determine that the aircraft are in condition for safe 

flight, as stated in the conditions and limitations below.
3. Extent Of Relief IRONSIDES MOTION LLC Seeks And The Reason IRONSIDES 

MOTION LLC Seeks Relief From Section 91.121. 

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

operations of the DJI Phantom 3 and DJI Inspire 1 UASs, 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), IRONSIDES MOTION LLC seeks the requested relief 

because the DJI Phantom 3 and DJI Inspire 1 UA’s altimeter may be set on the ground to zero 

feet AGL, rather than the local barometric pressure or field altitude, before each flight. 

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

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

below. As more fully set forth herein, an equivalent level of safety will be maintained since the 

DJI Phantom 3 and DJI Inspire 1 UAs 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 d

isplay of the GCS. 

4. Extent Of Relief IRONSIDES MOTION LLC Seeks And The Reason IRONSIDES 

MOTION LLC 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 and DJI

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

flight rules (VFR), for a total duration of 15.5 minutes to the first point of intended landing and, 

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

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

the flight time duration of the battery powered DJI Phantom 3 and DJI Inspire 1 UAs will 

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

IRONSIDES MOTION LLC proposes to conduct pursuant to this Petition.

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

DJI Inspire 1 UASs, the DJI Phantom 3 and DJI Inspire 1 operating documents, and 

IRONSIDES MOTION LLC proposed operating limitations, ensure that IRONSIDES MOTION LLC 

will safely operate the battery powered DJI Phantom 3 and DJI Inspire 1 UAs during daylight hours 

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

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

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

55.Extent Of Relief IRONSIDES MOTION LLC Seeks And The Reason IRONSIDES MOTION 

LLC Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & 

(b).

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

apply to aircraft with an airworthiness certificate, IRONSIDES MOTION LLC requests relief 

from these Sections because the DJI Phantom 3 and DJI Inspire 1 UASs do not require airworthiness 

certificates. As set forth more fully below, the DJI Phantom 3 and DJI Inspire 1 UASs meet the 

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

Accordingly IRONSIDES MOTION LLC 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., IRONSIDES MOTION LLC Aerial 
Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 and DJI Inspire 1 

Instruction Manual). Furthermore, IRONSIDES MOTION LLC will document and maintain all 

maintenance records for the DJI Phantom 3 and DJI Inspire 1 UASs. 

DThe Reasons Why Granting IRONSIDES MOTION LLC Request Would Be In The Public 

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

DI

Granting the present Petition will further the public interest by allowing IRONSIDES 

MOTION LLC to safely, efficiently, and economically perform aerial video and photography of 

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

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

of the NAS, reduce pollution, crashes and accidents caused by pilot error and provide 

significant benefits to the economy. Notably, the benefits of IRONSIDES MOTION LLC 

proposed operation of the DJI Phantom 3 and DJI Inspire 1 UASs will be realized without 

implicating any privacy issues.

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

The DJI Phantom 3 and DJI Inspire 1 UAs 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 Phantom 3 or 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 and DJI Inspire 1 UAs do not require an airport to takeoff or land. Likewise, a 

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

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

arrival, and landing phases of flight operations. 

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

and DJI Inspire 1 UASs. 

Conducting aerial acquisitions with the DJI Phantom 3 and DJI Inspire 1 UASs, 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 and DJI Inspire 1 UASs produce 

no air pollution, and is the most viable environmentally conscious alternative to the cabin class, 

six cylinder internal combustion engine aircraft that are typically utilized for aerial video and 

photography, while burning approximately 20-30 gallons per hour of leaded aviation fuel. The 

DJI Phantom 3 and DJI Inspire 1 UAs, 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 and DJI Inspire 1 UASs 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 

Phantom 3 and DJI Inspire 1 UAs (weighing approximately 2 pounds 14 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).

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

3 and DJI Inspire 1 UASs Will Benefit The Economy. 

In addition to being safe and efficient, the DJI Phantom 3 and DJI Inspire 1 UASs are 

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

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

companies, like IRONSIDES MOTION LLC, to remain competitive and contribute to growth 

of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental 

Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and 

operated companies must adopt new and alternative technology in order to remain competitive. 

Operating the battery powered DJI Phantom 3 and 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 and DJI Inspire 1 UASs, companies such as 

IRONSIDES MOTION LLC, 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 and DJI Inspire 1 UASs, 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. 

4There Are No Privacy Issues.

5

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

decades, IRONSIDES MOTION LLC proposed operation of the DJI Phantom 3 and DJI Inspire 

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

UASs will be operated only in compliance with operating documents (i.e., IRONSIDES 

MOTION LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 and DJI

Inspire 1 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. 

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 IRONSIDES MOTION LLC Seeks Exemption. 

1Reasons Why The DJI Phantom 3 and DJI Inspire 1 UAs Meet The Conditions Of The FAA

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

2

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

the unmanned aircraft and its operation, IRONSIDES MOTION LLC operation of the DJI 
Phantom 3 and DJI Inspire 1 UASs meet the conditions of FMRA Section 333, and will not 

require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Section 333 

provides authority for a UAS to operate without airworthiness certification and sets forth 

requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or 

otherwise pose a threat to national security. Specifically, FMRA Section 333 states the 

following, in part: 

(a) In General.--Notwithstanding any other requirement of this subtitle, and not later 

than 180 days after the date of enactment of this Act, the Secretary of Transportation shall 

determine if certain unmanned aircraft systems may operate safely in the national airspace 

system before completion of the plan and rulemaking required by section 332 of this Act or the 

guidance required by section 334 of this Act.

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

subsection (a), the Secretary shall determine, at a minimum--

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

weight, speed, operational capability, proximity to airports and populated areas, and operation 

within visual line of sight do not create a hazard to users of the national airspace system or the 

public or pose a threat to national security; and 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, IRONSIDES MOTION LLC submits that the DJI Phantom 3 

and DJI Inspire 1 UASs can operate safely in the NAS pursuant to FMRA Section 333, as 

demonstrated by: (a) the characteristics of the DJI Phantom 3 and DJI Inspire 1 UASs; (b) the 

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

a. The Specifications Of The DJI Phantom 3 and DJI Inspire 1 UASs Demonstrate 

Its Safe Characteristics. 

The DJI Phantom 3 and DJI Inspire 1 UASs do not create a hazard to users of the NAS or the 

public, or otherwise pose a threat to national security considering its size, weight, speed, and 

operational capability. 

i. Technical Specifications Of The DJI Phantom 3 and DJI Inspire 1 UASs. 

The technical specifications of the DJI Phantom 3 and DJI Inspire 1 UASs are set forth by the 

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

and B. 

ii. The DJI Phantom 3 and DJI Inspire 1 UASs Autonomous Flight And Navigation 

Modes Enable The UASs To Remain Within A Defined Operational Area. 

The DJI Phantom 3 and DJI Inspire 1 UASs 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 and DJI Inspire 1 UASs is provided at pages 25-35 of the DJI Phantom 3 and 

pages 12-16 and 45-50 of the DJI Inspire 

1 User Manuals, attached hereto as Exhibit C and D. 

iii. The DJI Phantom 3 and DJI Inspire 1 UASs Are Designed For Automatic 

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

Navigation. 

When the Control Link is lost, the DJI Phantom 3 and DJI Inspire 1 UAs will remain stationary, 

in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 3 and DJI Inspire 1 UAs 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 Phantom 3 UAS are set 

forth at pages 27 through 29 and for the DJI Inspire 1 at pages 13 through 15 of the DJI 

Phantom 3 and DJI Inspire 1 User Manuals, attached hereto as Exhibit C and D.

ivThe DJI Phantom 3 and DJI Inspire 1 GCS And Its Operation.

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

DJI Inspire 1 GCS and flight control software is provided at pages 32 through 43 of the DJI 

Phantom 3 User Manual and pages 40 through 47 of the DJI Inspire 1 User Manual. DJI 

Phantom 3 and DJI Inspire 1 User Manuals are attached hereto as Exhibits C and D.

b. Flight Operations Of DJI Phantom 3 and DJI Inspire 1 UASs Are Limited To 

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

IRONSIDES MOTION LLC will only utilize certificated pilots who possess a current and valid 

airman medical certificate to act as a pilot in command (PIC) of the DJI Phantom 3 and DJI 

Inspire 1 UASs. Additionally, a safety observer will assist all pilots during flight time. 

c. Flights Of DJI Phantom 3 and DJI Inspire 1 UASs Will Be Conducted Pursuant 

To Specific Operating Limitations. 

In seeking this exemption, IRONSIDES MOTION LLC proposes to commercially operate DJI 

Phantom 3 and DJI Inspire 1 UASs 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 and 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 500 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. 

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 f

or 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.

 17. The PIC must possess at least a private pilot certificate and at least a current thirdclass 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 experience-building flights, all 

persons not essential for flight 

operations are considered nonparticipants, and the PIC must operate the UA with appropriate 

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

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. 
All operations must be conducted under visual meteorological conditions (VMC). If flight at 

night is required, a special request will be made at the FAA office closest to proposed area of 

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

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

denoted on a current FAA-published aeronautical chart unless a letter of agreement with that 

airport’s management is obtained, and the operation is conducted in accordance with a NOTAM 

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

be made available to the Administrator upon request. 

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

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

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

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 (N- Number) 

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

practicable. 

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

control of the 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 

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. 

IRONSIDES MOTION LLC submits that the equivalent level of safety established by Section 

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

Phantom 3 and DJI Inspire 1 UASs 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 

or 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.

 Considering IRONSIDES MOTION LLC’s 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 Phantom 3 or DJI Inspire 1 UAS, 

IRONSIDES MOTION LLC submits that the additional manned airmanship experience of a 

commercially certificated pilot would not correlate to the airmanship skills necessary for IRONSIDES 

MOTION LLC’s specific proposed flight operations. 

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

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

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 

11153, 11156, 11158, 11159, 11160, 11161). BLAKE J COPPINGER will not allow any PIC to 

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

minimum flight-hour requirements or the DJI Phantom 3 or DJI Inspire 1 UAS training and 

currency requirements, that the PIC is able to safely operate the DJI Phantom 3 or 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 that was obtained in compliance with applicable regulations will ensure an 

equivalent level of safety during IRONSIDES MOTION LLC’s proposed operations. The 

Administrator has held that prior documented flight experience that was obtained in compliance 

with applicable regulations would ensure safe operations, stating as follows: 

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

motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner 
consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 

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

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

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

FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make 

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

in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must 

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

that at a minimum, the flight hour requirements in Exemption No. 11062 are appropriate to practice and 

build proficiency in the skills necessary to safely conduct the petitioner’s proposed operations. The 

FAA also finds that prior documented flight experience that was obtained in compliance with 

applicable regulations would satisfy this requirement. Training, proficiency, and experience-building 

flights can also be conducted under the grant of exemption to accomplish the required flight time. 

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

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

Exemption No. 11138 at page 15. 

Accordingly, IRONSIDES MOTION LLC will ensure safe operations by not allowing any PIC 

to operate the DJI Phantom 3 or 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 or 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. 

 

CONCLUSION

IRONSIDES MOTION LLC seeks an exemption pursuant to 14 C.F.R. § 11.61 and 

Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will 

permit safe operation of the DJI Phantom 3 and DJI Inspire 1 UASs 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 IRONSIDES MOTION LLC to safely, 

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

within the NAS. WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA
Modernization and Reform Act of 2012, Section 333, IRONSIDES MOTION LLC respectfully

requests that the Administrator grant this Petition for an exemption from the requirements of 14 

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

(1) & (a)(2), and 91.417(a) & (b), and permit Leading Edge to operate the DJI Phantom 3 and 

DJI Inspire 1 UASs commercially for the purpose of conducting aerial video and photography 

over certain areas of the United States. Dated: May 22, 2015 

 Submitted by 

 Kevin William Andrews

IRONSIDES MOTION LLC 

 

APPENDIX – A

DJI PHANTOM 3 TECHNICAL SPECIFICATIONS 

IRONSIDES MOTION LLC 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) 

1.1DJI Phantom 3

1.2 1.1.1 Aircraft 

 1.1.1.1 Supported Battery – DJI 6000AH LiPo Battery

1.1.1.2 Weight (Battery & Propellers Included) – 2lbs 11.810oz (1242g)

1.1.1.3 Hover Accuracy (Ready to Fly) – Vertical: .8m; Horizontal: 2.5m 

1.1.1.4 Max Yaw Angular Velocity - 200/s 

1.1.1.5 Max Tilt Angel - 35 1.1.1.6 Max Ascent Speed – 6m/s

1.1.1.7 Max Descent Speed – 2m/s 

1.1.1.8 Max Flight Speed – 15m/s (NOT RECOMMENDED) 

1.1.2 Gimbal 

1.1.2.1 Working Current – Static: 750mA; Dynamic: 900mA

1.1.2.2 Control Accuracy - ±0.03 

1.1.2.3 Controllable Range – Pitch: -90 - 0 

1.1.2.4 Maximum Angular Speed – Pitch: 90/s 

1.1.3 Camera 

1.1.3.1 Operating Temperature Range - 32F - 104F (0C - 40C) 

1.1.3.2 Sensor Size – 1/2.3” 

1.1.3.3 Effective Pixels – 14M 

1.1.3.4 Resolution – 4384x3288 

4.1.3.5 HD Video Recording – 1080p30 & 720p

4.1.3.6 Recording Field of View - 110/85 

APPENDIX – B

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS 

IRONSIDES MOTION LLC 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) 

All specifications can be found in the attached user manual or at 

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