UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

Petition for Exemption 14 CFR 11.81 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF FLY 

AWAY AERIAL IMAGING LLC FOR AN EXEMPTION SEEKING 

RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF 

FEDERAL REGULATIONS SECTIONS PART 21 SUBPART H, 

91.103(b), 91.105, 91.109, 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 UNMANNED 

AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA 

MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-

95) 

Submitted on August 15th, 2015

Kyle T. Gritzan

8127 Larkspur Ave NW

North Canton, OH 44720  

(330) 826-1198

kyle@flyawayimaging.com
SUMMARY 

Kyle T. Gritzan, the owner of Fly Away Aerial Imaging LLC, seeks 

exemption from the requirements of 14 C.F.R § 91.103(b), 91.105, 91.109, 

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 allow Fly Away Aerial Imaging LLC to operate an 

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

aerial video and photography of real estate, special events, film sets and 

construction sites within the United States. 

BACKGROUND 

Fly Away Aerial Imaging LLC seeks an exemption to operate DJI UAV 

systems for compensation or hire within the National Airspace System. Fly 

Away Aerial Imaging LLC desires to operate DJI PHANTOM 3 unmanned 

aerial systems. These Unmanned Aerial Vehicles are four bladed “quad” 

copters allowing for vertical takeoff and landing. The unit is powered by a 

Lithium Polymer battery which supplies power to four of the engines. It is 

controlled wirelessly through a Ground Control Station allowing it to be 

operated using a remote and an electronic tablet or smart phone system. The 

DJI PHANTOM 3 has a max speed of 29 knots, a maximum gross weight of 

approximately 2 pounds 11 ounces, with dimensions of 16 inches by 16 

inches standing 8 inches tall. The DJI PHANTOM 3 complies with all FCC 

radio frequency regulations. Fly Away Aerial Imaging LLC can provide a 

FCC compliance letter upon request. 

If this petition is granted, DJI PHANTOM 3 systems that will be operated by 

Fly Away Aerial Imaging LLC will be registered in accordance with 49 

U.S.C. 44103, Registration of Aircraft, and 14 C.F.R Part 47, Aircraft 

Registration, and marked in accordance with 14 C.F.R. Part 45, Identification 

and Registration Marking. 
THE SPECIFIC SECTIONS OF 14 C.F.R. FLY AWAY AERIAL 

IMAGING LLC SEEKS EXEMPTION AND THE REASONS WHY 

GRANTING THIS EXEMPTION WOULD NOT ADVERSELY 

AFFECT SAFETY. 

Petitioner, Fly Away Aerial Imaging 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 in the National Airspace 

System (NAS), and for an exemption from the following requirements: 

-14 C.F.R. Part 21, Subpart H 

Based on its size, weight and speed it 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. 

The Reasons Why Granting The Exemption Would Not Adversely 

Affect Safety: 

Fly Away Aerial Imaging LLC believes that safety will not be affected 

without an airworthiness certificate because the process of obtaining an 

airworthiness certificate is geared toward the certification of manned 

aircraft and not small UAVs. Small UAVs, like the DJI PHANTOM 3 

are in a separate category of aircraft, as FMRA Section 333 recognizes. 

-14 C.F.R 91.103 (b) 

Fly Away Aerial Imaging LLC seeks an exemption from the 

requirements of Section 14 C.F.R. 91.103(b) entitled Preflight Action. 

If this petition is granted, Fly Away Aerial Imaging LLC will be 

operating a DJI PHANTOM 3 which does not require a runway. The 

DJI PHANTOM 3 takes off vertically without a runway. Therefore it is 

impossible for the PIC to calculate runway takeoff and landing 

distances. 
Reasons Why An Exemption From The Requirements Of Section 

14 C.F.R. 91.103(b) Would Not Adversely Affect Safety:

Fly Away Aerial Imaging LLC believes that safety will be enhanced 

without the need for a runway. Additionally, the size and weight of the 

DJI PHANTOM 3 is so small, that any takeoff or landing accident 

would cause minimal damage to persons or property when compared to 

manned aircraft takeoff and landing accidents. 

-14 C.F.R 91.105

Fly Away Aerial Imaging LLC seeks an exemption from the 

requirement of Section 14 C.F.R. 91.105, entitled flight crew members 

at stations. Because this is an Unmanned Aerial Vehicle, it is operated 

from the ground. Therefore, the operator has no need to wear seat belts 

while flying. Fly Away Aerial Imaging LLC believes the UAV can be 

safely operated from the Ground Station and still maintain safety of 

flight. 

Reasons Why An Exemption From The Requirements Of Section 

14 C.F.R. 91.105 Would Not Adversely Affect Safety:

Fly Away Aerial Imaging LLC believes that UAVs are much safer 

because the PIC is safely on the ground. Any inflight turbulence does 

not affect the safety of the PIC. In the event of a crash, the PIC risks 

significantly less physical damage from the DJI PHANTOM 3 than he 

or she would inside a manned aircraft during a crash. For these reasons, 

Fly Away Aerial Imaging LLC believes that safety is actually improved 

by operating a UAV instead of a manned aircraft. 
-14 C.F.R 91.109

Fly Away Aerial Imaging LLC seeks an exemption from the 

requirement of Section 14 C.F.R. 91.105, entitled Flight Instruction; 

Simulated instrument flight and certain flight tests. Fly Away Aerial 

Imaging LLC believes that all forms of flight instruction given on the 

UAV can safely be given using a dual operator ground station. Using 

two remotes, the instructor has the ability to override the student if 

needed, ensuring the instructor has full control over the UAV at all 

times while given flight instruction. Without this exemption, it would 

be impossible for Fly Away Aerial Imaging LLC to give any type of 

UAV flight instruction. 

Reasons Why An Exemption From The Requirements Of Section 

14 C.F.R. 91.105 Would Not Adversely Affect Safety:

Fly Away Aerial Imaging LLC believes that the same level of safety 

will be maintained during flight instruction because the instructor has 

full control at all times while giving flight lessons. In the event that the 

student begins the lose control, the instructor can take over, exactly like 

it is done in manned aircraft. 

-14 C.F.R 91.121

Fly Away Aerial Imaging LLC also seeks an exemption from the 

requirements of Section 14 C.F.R. 91.121, entitled Altimeter Settings, 

as the DJI PHANTOM 3 does not have a barometric altimeter. The DJI 

PHANTOM 3 altimeter may be set on the ground to zero feet AGL, 

rather than the local barometric pressure or field altitude, before each 

flight. Altitude information is provided to the Pilot in Command via the 

telemetry data link. This information is displayed to the Pilot in 

Command via the ground station tablet interface. This altitude 

information, combined with visual line of sight will ensure a level of 

safety equivalent to that of Section 14 C.F. R. 91.121. 
Reasons Why An Exemption From The Requirements Of Section 

14 C.F.R. 91.105 Would Not Adversely Affect Safety:

Fly Away Aerial Imaging LLC believes that safety will still be 

maintained because the PIC still has altitude information available to 

him or her at all times during the flight. This, combined with attitude 

and ground speed information keeps the PIC aware of the UAV and its 

surroundings. 

-14 C.F.R 91.151(b)

Fly Away Aerial Imaging LLC seeks an exemption from the 

requirements of Section 14 C.F.R. 91.151(b), entitled Fuel 

requirements for flight in VFR conditions. Fly Away Aerial Imaging 

LLC believes that the standard Lithium Polymer batteries that power 

the DJI PHANTOM 3. will be adequate for the short flights needed for 

this operation. The DJI PHANTOM 3 has enough battery power to fly 

for a total duration of approximately 13 minutes with an additional 5 

minutes of reserve power for additional flying at normal speed. Fly 

Away Aerial Imaging LLC seeks the requested relief because without 

an exemption from Section 91.151(b), it would not be possible to fly a 

DJI PHANTOM 3. This would severely constrain the practicality of 

any aerial video or still photo flight operations that Fly Away Aerial 

Imaging LLC proposes to conduct pursuant to this Petition. 

Furthermore, safety will be ensured as the DJI PHANTOM 3 UAV 

provide audible and visual warnings to the PIC at the ground station 

when the UAV 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+ UAV will descend and land 

automatically. 
Reasons Why An Exemption From The Requirements Of Section 

14 C.F.R. 91.105 Would Not Adversely Affect Safety:

Fly Away Aerial Imaging LLC believes that safety will still be 

maintained because the DJI PHANTOM 3 would always be flown 

within line of sight. This ensures that a landing can immediately be 

made within seconds or minutes. Additionally, the ability to takeoff or 

land vertically allows the DJI PHANTOM 3 to land on virtually any 

flat surface. This ensures that the DJI PHANTOM 3 will have plenty of 

battery reserves allowing it to always be able to safely land after a 

flight. 

-14 C.F.R 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), 91.417(a) & 

(b).

Fly Away Aerial Imaging LLC requests relief from these sections as 

these sections set forth requirements for maintenance that only apply to 

aircraft with an airworthiness certificate. Fly Away Aerial Imaging 

LLC requests relief from these Sections because the DJI Phantom 3 

does not require airworthiness certificates as set forth in the conditions 

of FMRA Section 333. 

A maintenance logbook will be developed to record all maintenance, 

alterations or repairs made on the UAV. Prior to any revenue flight, the 

PIC will be required to determine the DJI PHANTOM 3 UAV in a 

manner consistent with this exemption. 

Fly Away Aerial Imaging LLC will use trained technicians to perform 

maintenance, alterations, or preventive maintenance on the UAVs using 

the methods, techniques, and practices prescribed in the UAV operating 

documents (Monthly Maintenance Log, and DJI PHANTOM 3 

Instruction Manual). Furthermore, Fly Away Aerial Imaging LLC will 

document and maintain all maintenance records for the DJI 

PHANTOM 3. 
Fly Away Aerial Imaging LLC submits that it will ensure that the DJI 

PHANTOM 3 UAV are in an airworthy condition, prior to every flight, 

by determining that the UAVs are in compliance with the operating 

documents (Maintenance Log, and DJI PHANTOM 3 Instruction 

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

Reasons Why An Exemption From The Requirements Of Section 

14 C.F.R. 91.105 Would Not Adversely Affect Safety:

Fly Away Aerial Imaging will carefully and meticulously operate the 

DJI PHANTOM 3 in accordance with the manufacturer’s operating 

manual. The exemption sought will not adversely affect safety because 

Fly Away Aerial Imaging LLC will use trained technicians to perform 

maintenance, alterations or preventive maintenance on the UAV using 

the methods, techniques, and practices prescribed by the operating 

documents. Fly Away Aerial Imaging LLC believes that safety will not 

be affected because the procedures established above ensure the the DJI 

PHANTOM 3 will always be maintained and operated in a structured, 

organized and consistent manner. Using the procedures above ensures 

that each flight is taken with the utmost care. 
The Reasons Why Granting Fly Away Aerial Imaging LLC’s Request 

Would Be In The Public Interest AND How It Would Benefit The Public 

As A Whole. 

Reason #1. Expanding the availability of affordable aerial photos for industry

Granting this petition will further the public interest by expanding the 

availability of economically affordable aerial cinematography and 

photography. Historically, the public has used aerial photos for a variety of 

reasons. These aerial photos and videos have been obtained using manned 

aircraft, costing hundreds and thousands of dollars per hour to operate. 

Granting this petition will increase the quality of aerial photography services, 

while at the same time decreasing the price. This service will allow for the 

following: 

 enhanced and dynamic real estate marketing, benefiting property 

owners and real estate agents 

 crop surveying for the agricultural industry (field drainage monitoring, 

crop insurance documentation, pesticide monitoring, etc), which will 

lead to increased farming efficiency benefiting both farmers and 

consumers 

 insurance claim documentation for insurance companies such as hail 

damage, crop damage, bridge collapses, flooding, etc., which will 

benefit the insurance companies and consumers of insurance products 

 construction progress for residential, commercial, and industrial 

construction companies. 

 wetland and water drainage mitigation for public works departments, 

which will enhance the ability of civil engineers to plan for water 

drainage mitigation 

 power line and pipeline utility inspection services for utility companies 

-many more potential applications exist 

The increased efficiency and lower cost of operating a UAV for aerial 

applications will benefit the economy as a whole by allowing scarce 

resources, such as aircraft fuel, to be used in other areas of the economy. This 

will ensure that the United States remains competitive on the global market 

for aerial applications and ensure that more jobs stay located within the 

United States. 
Reason #2. Reduced Levels of Air and Noise Pollution

Using the DJI PHANTOM 3 UAV, to conduct aerial operations instead of 

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

and noise pollution. Small UAVs are much more energy efficient than 

traditional manned aircraft. By using battery power and electric motors, the 

DJI PHANTOM 3 UAV produces no air pollution, and is much more 

environmentally friendly that the traditional four to six-cylinder internal

combustion aircraft engines that are typically utilized for aerial video and 

photography. These manned aircraft burn approximately 10-25 gallons per 

hour of leaded aviation fuel. The DJI PHANTOM 3 UAV also eliminates a 

lot of noise pollution. The small propeller blades and electric motors produce 

only a fraction of the noise level that traditional fixed-wing aircraft or 

helicopters produce. 

Reason #3 Increased Public Safety

The public will benefit from the safety and efficiency of the DJI PHANTOM 

3 UAV. The DJI PHANTOM 3, weighing only 2 pounds 11 ounces, poses a 

very small threat to people and property on the ground in the event of a crash. 

The damage a 2 pound UAV can do is very small compared to the damage 

that a 4000lb aircraft with hundreds of gallons of fuel onboard. In other 

words, it has less physical potential for collateral damage to life and property 

compared to manned aircraft. 

Reason #4. Reduced Congestion of the National Airspace System

Granting this request also benefits the public as a whole by reducing the 

congestion of manned aircraft, leading to decreased congestion of the NAS. 

By reducing the number of manned aircraft operating in the NAS, it will 

relieve the air traffic control system of unnecessary aircraft traffic. Because 

the DJI PHANTOM 3 UAV does not need a runway or airport to operate, it 

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. This will allow the air traffic control system to focus their 

resources more on the needs of other types of manned flights. 
How Fly Away Aerial Imaging LLC plans to operate the UAV if this 

petition is granted. 

If this petition is granted flights of DJI PHANTOM 3 UAV will be conducted

according specific operating limitations 

1. 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. 

2. The UAV must be operated at an altitude of no more than 200 AGL.

3. The UAV 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. 

4. 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.

5. 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. 

6. The operating documents and the grant of exemption must be 

accessible during UAV 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. 
7. Prior to each flight the PIC must inspect the UAV to ensure that it is in 

a condition for safe flight. If the inspection reveals a condition that 

affects the safe operation of the UAV, the aircraft is prohibited from 

operating until the necessary maintenance has been performed and the 

UAV 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. 

8. Any UAV that has undergone maintenance or alterations that affect the 

UAV 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. 

9. 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. 

10. 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 UAV to service. 

11. Each UAV operated under this exemption must comply with all 

manufacturer Safety Bulletins. 

12. UAV 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. 

13. The UAV may not operate within 5 nautical miles of an airport 

reference point as denoted on a current FAA-published aeronautical 

chart, or within the lateral limits of class B, C or D airspace as denoted 

on a current FAA-published aeronautical chart. 
14. 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. 

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

emergencies in accordance with the operating documents. 

16. 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. 

17. 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. 

18. The UAV must remain clear and yield the right of way to all manned 

aviation operations and activities at all times. 

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

vehicle. 

20. 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 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 UAV, 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). 

21. 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. 
Flight safety will be maintained because the PIC operating the DJI 

PHANTOM 3 is already a ATP pilot and has demonstrated that the PIC is 

able to safely operate the DJI PHANTOM 3 UAV in a manner consistent 

with safe operation, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and 

structures. 

Fly Away Aerial Imaging LLC will not allow any PIC to operate the DJI 

PHANTOM 3 unless that PIC has demonstrated to the PIC that he or she is 

able to safely operate the DJI PHANTOM 3 UAV in a manner consistent 

with this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and 

structures. 
Technical Specifications Of The DJI PHANTOM 3 UAV. 

Fly Away Aerial Imaging desires to operate a DJI PHANTOM 3. This 

Unmanned Aerial Vehicle is a four bladed “quad” copter allowing for vertical 

takeoff and landing. The unit is powered by a Lithium Polymer battery which 

supplies power to four of the engines. It is controlled wirelessly through a 

Ground Control Station allowing it to be operated using a remote and an 

electronic tablet or smart phone systems. The DJI PHANTOM 3 has max 

speed of 29 knots, a maximum gross weight of approximately 2 pounds 11 

ounces, with dimensions of 16 inches by 16 inches standing 8 inches tall. The 

DJI PHANTOM 3 complies with all FCC radio frequency regulations. Fly 

Away Aerial Imaging LLC can provide a FCC compliance letter upon 

request. The DJI PHANTOM 3 UAV Autonomous Flight And Navigation 

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

The DJI PHANTOM 3 UAV 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 UAV is provided at pages 25-

35 of the DJI PHANTOM 3 User Manual (see attachment) The DJI 

PHANTOM 3 UAV 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 UAV will remain stationary, in 

flight, for 3 seconds or more. If, after 3 seconds, the DJI PHANTOM 3 UAV 

does not reacquire control link data from the GCS, the UAV will assume that 

the Control Link is lost and the UAV 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 

UAV are set forth at pages 27 through 29 of the DJI PHANTOM 3 User 

Manual (see attachment) A complete description of the operation and 

specifications of the DJI PHANTOM 3 GCS and flight control software is 

provided at pages 32 through 43 of the DJI PHANTOM 3 User Manual. 

Considering the size, weight, speed and operation capability, Fly Away 

Aerial Imaging LLC believes the DJI PHANTOM 3 UAV does not create a 

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

national security. For further technical information concerning the DJI 

PHANTOM 3, see the attached operator’s manual 
CONCLUSION 

Fly Away Aerial Imaging 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 UAV 

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 Fly Away Aerial 

Imaging LLC to safely, efficiently, and economically operate the DJI 

PHANTOM 3 commercially within the NAS. 

In accordance with the Federal Aviation Regulations and the FAA 

Modernization and Reform Act of 2012, Section 333, Fly Away Aerial 

Imaging LLC respectfully requests that the Administrator grant this Petition 

for an exemption from the requirements of 14 C.F.R Sections 91.103(b), 

91.105, 91.109, 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 the DJI PHANTOM 3 UAV 

commercially for the purpose of conducting aerial video and photography 

over certain areas of the United States. 

Dated: August 15th, 2015 

Respectfully submitted, 

Kyle Gritzan

Kyle Gritzan

8127 Larkspur Ave NW North Canton, OH 44720

(330) 826-1198

kyle@flyawayimaging.com