UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

Richard Hunt

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 DJI Phantom 3 UNMANNED 

AIRCRAFT SYSTEM 

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC 

LAW 112-95) 

Submitted on August 26, 2015

Richard Hunt

200 N 11th St; Apt 3E. Brooklyn, NY 11211

TABLE OF CONTENTS 

Page GLOSSARY OF 

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

SUMMARY........................................................................................................

...................4 

INTRODUCTION AND INTERESTS OF 

PETITIONER....................................................4 

BACKGROUND................................................................................................

....................4 
BASIS FOR 

PETITION.........................................................................................................

5 

NAME AND ADDRESS OF 

PETITIONER.............................................................7 

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

HUNT SEEKS EXEMPTION.................................................................8 

THE EXTENT OF RELIEF RICHARD HUNT SEEKS AND THE REASON 

RICHARD HUNT SEEKS THE RELIEF.........................11 

THE REASONS WHY GRANTING RICHARD HUNT’S REQUEST 

WOULD BE IN THE PUBLIC 

INTEREST .........................................................15 

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT 

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

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL 

REGISTER......34 

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS 

AVAILABLE TO SUPPORT RICHARD HUNT ’S REQUEST.........34 

CONCLUSION...................................................................................................

.................35 

APPENDICES........................................................................................37 

AGL

AOI

ATC

ATO

AV

CFR

COA
FAA

FAR

GCS

GPS

LOL

NAS NOTAM PIC Section 333 SO 

SOP UA UAS VFR VLOS VMC VTOL 

GLOSSARY OF ABBREVIATIONS 

Above Ground Level Area of Interest

Air Traffic Control

Air Traffic Organization Aerial Vehicle 

Code of Federal Regulations Certificate of Authorization Federal Aviation 

Administration Federal Aviation Regulation Ground Control Station 

Global Positioning System Loss of Link

National Airspace System Notice to Airman 

Pilot In Command

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

Observer

Standard Operating Procedures

Unmanned Aircraft

Unmanned Aircraft System

Visual Flight Rules

Visual Line of Site

Visual Meteorological Conditions

Vertical Takeoff and Landing 

SUMMARY 

RICHARD HUNT 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 RICHARD HUNT to operate 

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

conducting aerial video and photography of real estate, landmarks, 

landscapes for television and film, and for historical reference. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

RICHARD HUNT provides his clients with photography and videography of 

properties for the purpose of advertising. RICHARD HUNT has many hours 

flying experience. The objective of RICHARD HUNT and his aerial 

operations is to provide high quality imaging for a variety of commercial, 

public, and residential uses, specifically targeting: 

• • • 

Residential Construction Real-estate marketing Television Production 

BACKGROUND 

Unmanned Aircraft Systems: DJI Phantom 3 UASs 

RICHARD HUNT seeks an exemption to operate DJI 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. The 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 42 knots. The DJI Phantom 3UAs is 

equipped with four main rotors; driven by Lithium Polymer battery powered 

electric motors. 

BASIS FOR PETITION 

Petitioner, RICHARD HUNT, 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 a DJI Phantom 3 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, RICHARD HUNT 

operation of the DJI Phantom 3 UAS meets the conditions of FMRA Section 

333 and therefore, will not require an airworthiness certificate in accordance 

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

Accordingly, RICHARD HUNT 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. 

RICHARD HUNT submits that the requested relief is proper since an 

equivalent level of safety will be ensured. RICHARD HUNT will use 

experienced personnel or technicians to perform maintenance, alterations, or 

preventive maintenance on the UAS using the methods, techniques, and 

practices prescribed in the operating documents (i.e., Monthly Maintenance 

Log, and DJI Phantom 3 Instruction Manual). Furthermore, RICHARD 

HUNT will document and maintain all maintenance records for the DJI 

Phantom 3 UAS. 

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

Private pilot privileges and limitations: Pilot in command, is requested by 

RICHARD HUNT 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 UAS in a manner consistent with this exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures. 
RICHARD HUNT seeks relief from Section 91.7(a), entitled Civil aircraft 

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

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As 

such, RICHARD HUNT 

submits that he will ensure that the DJI Phantom 3 UAS is in airworthy 

condition, prior to every flight, by determining that the UAS are in 

compliance with the operating documents (i.e., Monthly Maintenance Log, 

and DJI Phantom 3 Instruction Manual), and that the aircraft are in a 

condition for safe flight. 

RICHARD HUNT also seeks an exemption from the requirements of Section 

91.121, entitled Altimeter Settings, as the DJI Phantom 3 UAS will not have a 

typical barometric altimeter onboard. However, altitude information of the 

DJI Phantom 3 UAS will be provided to the PIC via Global Positioning 

System (GPS) equipment and radio communications telemetry data link, 

which downlinks from the UA to the GCS for active monitoring of the flight 

path. This altitude information, combined with RICHARD HUNT’s operation 

of the DJI Phantom 3 UAS within visual line of sight, at or below 400 feet 

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

Additionally, RICHARD HUNT seeks an exemption from the requirements 

of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. 

RICHARD HUNT submits that safety will not be affected by operation of the 

DJI Phantom 3 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 14.5 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, RICHARD HUNT 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: RICHARD 

HUNT
200 N 11th St; Apt 3E

Brooklyn, NY 11211 

516-982-2833; richard.hunt2@gmail.com

B. The Specific Sections Of 14 C.F.R. From Which RICHARD HUNT 

Seeks Exemption. 

1. RICHARD HUNT Seeks Exemption From The Requirements Of 

Section 61.113(a) And (b). 

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

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

(a) No person who holds a private pilot certificate may act as a pilot in 

command (PIC) of an aircraft that is carrying passengers or property for 

compensation or hire; nor may that person, for compensation or hire, act as 

PIC of an aircraft. 

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

connection with any business or employment if— 

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

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

hire. 

2. RICHARD HUNT Seeks Exemption From The Requirements Of 

Section 91.7(a). 

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the 

following: (a) No person may operate a civil aircraft unless it is in an 

airworthy condition. 

3. RICHARD HUNT Seeks Exemption From The Requirements Of 

Section 91.121. 

Section 91.121, entitled Altimeter settings, subsection (a), states the 

following, in part: 
(a) Each person operating an aircraft shall maintain the cruising altitude or 

flight level of that aircraft, as the case may be, by reference to an altimeter 

that is set, when operating-- 

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

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

within 100 nautical miles of the aircraft; 

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

this section, the current reported altimeter setting of an appropriate available 

station; or 

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

departure airport or an appropriate altimeter setting available before 

departure. 

4. RICHARD HUNT Seeks Exemption From The Requirements Of 

Section 91.151(b). 

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

subsection 

(b), states the following: 

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

(considering wind and forecast weather conditions) there is enough fuel to fly 

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

fly after that for at least 20 minutes. 

5. RICHARD HUNT Seeks Exemption From The Requirement Of 

Section 91.405(a). 

Section 91.405, entitled Maintenance required, subsection (a), states the 

following: Each owner or operator of an aircraft— 

(a) Shall have that aircraft inspected as prescribed in subpart E of this part 

and shall between required inspections, except as provided in paragraph (c) 
of this section, have discrepancies repaired as prescribed in part 43 of this 

chapter[.] 

6. RICHARD HUNT Seeks Exemption From The Requirements Of 

Section 91.407(a)(1) 

Section 91.407, entitled Operation after maintenance, preventive 

maintenance, rebuilding, or alteration, subsection (a)(1), states the following: 

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

preventive maintenance, rebuilding, or alteration unless-- 

(1) It has been approved for return to service by a person authorized under § 

43.7 of this chapter[.] 

7. RICHARD HUNT Seeks Exemption From The Requirements Of 

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

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

(a) Except as provided in paragraph (c) of this section, no person may operate 

an aircraft unless, within the preceding 12 calendar months, it has had -- 

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

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

chapter; or 

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

accordance with part 21 of this chapter. 

8. RICHARD HUNT Seeks Exemption From The Requirements Of 

Sections 91.417(a) And 91.417(b). 

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

the following: 

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

each registered owner or operator shall keep the following records for the 

periods specified in paragraph (b) of this section: 
(1) Records of the maintenance, preventive maintenance, and alteration and 

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

inspections, as appropriate, for each aircraft (including the airframe) and each 

engine, propeller, rotor, and appliance of an aircraft. The records must 

include-- 

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

work performed; and 

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

(iii) The signature, and certificate number of the person approving the aircraft 

for return to service. 

(2) Records containing the following information: 

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

each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, propeller, 

rotor, and appliance. 

(iii) The time since last overhaul of all items installed on the aircraft which 

are required to be overhauled on a specified time basis. 

(iv) The current inspection status of the aircraft, including the time since the 

last inspection required by the inspection program under which the aircraft 

and its appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and safety 

directives including, for each, the method of compliance, the AD or safety 

directive number and revision date. If the AD or safety directive involves 

recurring action, the time and date when the next action is required. 

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each 

major alteration to the airframe and currently installed engines, rotors, 

propellers, and appliances. 
(b) The owner or operator shall retain the following records for the periods 

prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall be retained 

until the work is repeated or superseded by other work or for 1 year after the 

work is performed. 

(2) The records specified in paragraph (a)(2) of this section shall be retained 

and transferred with the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under § 43.11 

of this chapter shall be retained until the defects are repaired and the aircraft 

is approved for return to service. 

C. The Extent Of Relief RICHARD HUNT Seeks And The Reason 

RICHARD HUNT Seeks The Relief. 

1. Extent Of Relief RICHARD HUNT Seeks And The Reason RICHARD 

HUNT 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, RICHARD HUNT submits that an equivalent 

level of safety will be maintained because no PIC will be allowed to operate 

the DJI Phantom 3 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 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, RICHARD HUNT submits that all flights of theDJI Phantom 3 

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

incidental to MICHAEL 

GEOFFREY HACKETT’s business; and (2) will not carry passengers or 

property for compensation or hire. 

2. Extent Of Relief RICHARD HUNT Seeks And The Reason RICHARD 

HUNT 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 RICHARD HUNT to determine that the DJI 

Phantom 2 and DJI Phantom 3 UASs are in airworthy condition prior to 

every flight by ensuring that the UAS is in compliance with the operating 

documents (i.e., the RICHARD HUNT Aerial Operations Manual, Monthly 

Maintenance Log, and DJI Phantom 3 Instruction Manual). 

RICHARD HUNT seeks the requested relief because the DJI Phantom 2 and 

DJI Phantom 3 UASs do not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. Therefore, RICHARD HUNT 

will ensure that the DJI Phantom 3 UAS are in airworthy condition based 

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

Maintenance Log, and DJI Phantom 3 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 RICHARD HUNT Seeks And The Reason RICHARD 

HUNT 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 UAS, which utilize a barometric 

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

link to downlink altitude information from the UA to the PIC at the ground 

control station (GCS). Since the FAA requires that any altitude information 
concerning UAS operations be reported to air traffic control (ATC) in feet 

above ground level (AGL), RICHARD HUNT seeks the requested relief 

because the DJI Phantom 3 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 UAS is 

equipped with a barometric pressure sensor and GPS equipment, which 

automatically ensures that a ground level pressure setting will be established 

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

on the heads-up display of the GCS. 

4. Extent Of Relief RICHARD HUNT Seeks And The Reason RICHARD 

HUNT 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 UAS during daylight hours in visual meteorological 

conditions (VMC), under visual flight rules (VFR), for a total duration of 

14.5 minutes to the first point of intended landing and, assuming normal 

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

seeks the requested relief because without an exemption from Section 

91.151(b), the flight time duration of the battery powered DJI Phantom 3 

UAs will severely constrain the practicality of any aerial video or still photo 

flight operations that RICHARD HUNT proposes to conduct pursuant to this 

Petition. 

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

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

RICHARD HUNT’s proposed operating limitations, ensure that RICHARD 

HUNT will safely operate the battery powered DJI Phantom 3 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 14.5 
minutes to the first point of intended landing and, assuming normal cruising 

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

5. Extent Of Relief RICHARD HUNT Seeks And The Reason RICHARD 

HUNT 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, RICHARD 

HUNT requests relief from these Sections because the DJI Phantom 3 UAS 

does not require airworthiness certificates. As set forth more fully below, the 

DJI Phantom 3 UAS meets the conditions of FMRA Section 333 for 

operation without an airworthiness certificate. Accordingly, RICHARD 

HUNT 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 RICHARD 

HUNT Aerial Operations Manual, Monthly Maintenance Log, and DJI 

Phantom 3 Instruction Manual). Furthermore, RICHARD HUNT will 

document and maintain all maintenance records for the and DJI Phantom 3 

UAS. 

D. The Reasons Why Granting RICHARD HUNT 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 

RICHARD HUNT to safely, efficiently, and economically perform aerial 

video and photography of real estate, and landscapes over certain areas of the 

United States. 

Additionally, use of theDJI Phantom 3 UAS will decrease congestion of the 

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

Notably, the benefits of RICHARD HUNT’s proposed operation of the DJI 

Phantom 3 UAS will be realized without implicating any privacy issues. 

1. The Public Will Benefit From Decreased Congestion Of The NAS. 
The DJI Phantom 3 UAS is a battery powered and serve as a safe, efficient, 

and economical alternative to the manned aircraft traditionally utilized to 

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

perform aerial acquisitions, an exemption allowing the use of the DJI 

Phantom 3 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 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 UAS. 

Conducting aerial acquisitions with the DJI Phantom 3 UAS, instead of 

manned aircraft, will greatly benefit the public by drastically reducing the 

levels of air and noise pollution generated during traditional aerial video and 

still photography flight operations. By using battery power and electric 

motors, DJI Phantom 3 UAS produces no air pollution, and is the most viable 

environmentally conscious alternative to the cabin class, six cylinder internal 

combustion engine aircraft that are typically utilized for aerial video and 

photography, while burning approximately 20-30 gallons per hour of leaded 

aviation fuel. 

By using the DJI Phantom 3 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 UAS 

(weighing approximately 6 pounds 7.5 ounces, at their maximum gross 

weights with length of 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 UAS Will Benefit The Economy. 

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

economical alternative to using manned aircraft to conduct similar aerial 

operations. As such, operation of the DJI Phantom 3 UAS will allow United 

States based companies, like RICHARD HUNT, 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 UAS is one such 

technology that not only allows companies greater operational flexibility 

compared to manned aircraft, but provides such flexibility without the high 

operational cost of a traditional manned aircraft. 

By operating the DJI Phantom 2 and DJI Phantom 3 UASs, companies such 

as RICHARD HUNT, 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 UAS, provides a stable workforce that increases consumer spending; 

improves local, state, and federal tax revenues; and allows companies to 

invest in research and development in order to remain competitive both in the 

United States and abroad. 

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 RICHARD 

HUNT Seeks Exemption. 
1. Reasons Why The DJI Phantom 3 UAS 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, RICHARD HUNT’s 

DJI Phantom 3 UAS meet the conditions of FMRA Section 333, and will not 

require an airworthiness certificate in accordance with 14 C.F.R. Part 21, 

Subpart H. 

Section 333 provides authority for a UAS to operate without airworthiness 

certification and sets forth requirements for considering whether a UAS will 

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

to national security. Specifically, FMRA Section 333 states the following, in 

part: 

(a) In General.--Notwithstanding any other requirement of this subtitle, and 

not later than 180 days after the date of enactment of this Act, the Secretary 

of Transportation shall determine if certain unmanned aircraft systems may 

operate safely in the national 

airspace system before completion of the plan and rulemaking required by 

section 332 of this Act or the guidance required by section 334 of this Act. 

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

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

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

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

areas, and operation within visual line of sight do not create a hazard to 

users of the national airspace system or the public or pose a threat to 

national security; and 

(2) whether a certificate of waiver, certificate of authorization, or 

airworthiness certification under section 44704 of title 49, United States 

Code, is required for the operation of unmanned aircraft systems identified 

under paragraph (1). 
(c) Requirements for Safe Operation.--If the Secretary determines under this 

section that certain unmanned aircraft systems may operate safely in the 

national airspace system, the Secretary shall establish requirements for the 

safe operation of such aircraft systems in the national airspace system. 

In seeking this exemption, RICHARD HUNT submits that the DJI Phantom 3 

UAS can operate safely in the NAS pursuant to FMRA Section 333, as 

demonstrated by: (a) the characteristics of the DJI Phantom 3 UAS; (b) the 

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

a. The Specifications Of The DJI Phantom 3 UAS Demonstrate Its Safe 

Characteristics. 

The DJI Phantom 3 UASs does not create a hazard to users of the NAS or the 

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

weight, speed, and operational capability. 

i. Technical Specifications Of The DJI Phantom 3 UAS. 

The technical specifications of the DJI Phantom 3 UAS is set forth by the DJI 

Phantom 3 User Manual, attached hereto as Appendix A. 

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

Enable The UAS To Remain Within A Defined Operational Area. 

The DJI Phantom 3 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 UAS is provided at pages 12-16 

and 45-50 of the DJI Phantom 3 User Manuals, attached hereto as Appendix 

B. 

iii. The DJI Phantom 3 UAS 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 UAS will remain 

stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI 

Phantom 3 UAS does not reacquire control link data from the GCS, the UAS 

will assume that the Control Link is lost and the UAS will return to the home 
position (i.e., failsafe mode) via GPS, and will descend to the takeoff position 

and shutdown. 

A complete description of the Failsafe Functions of the DJI Phantom 3 at 

pages 13 through 15 of the DJI Phantom 3 User Manuals, attached hereto as 

Appendix B. 

iv. The DJI Phantom 3 GCS And Its Operation. 

A complete description of the operation and specifications of the DJI 

Phantom 3 GCS and flight control software is provided at pages 40 through 

47 of the DJI Phantom 3 User Manual. DJI Phantom 3 User Manuals are 

attached hereto as Appendix A. 

b. Flight Operations Of DJI Phantom 3 UAS Is Limited To The Line Of 

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

RICHARD HUNT will be the only person to act as a pilot in command (PIC) 

of the DJI Phantom 3 UAS. Additionally, a safety observer will assist in 

flights. 

c. Flights Of The DJI Phantom 3 UAS Will Be Conducted Pursuant To 

Specific Operating Limitations. 

In seeking this exemption, RICHARD HUNT proposes to commercially 

operate the DJI Phantom 3 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 

Unmanned Aircraft Systems. Proposed operations of any other aircraft will 

require a new petition or a petition to amend this grant. 

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

operations for the purpose of aerial video and photography. 

3. The UAS may not be flown at an indicated airspeed exceeding 20 knots. 
4. The UA must be operated at an altitude of no more than 400 feet above 

ground level (AGL), as indicated by the procedures specified in the operating 

documents unless a special request is made and approved by ATC. All 

altitudes reported to ATC must be in feet AGL. 

5. The 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 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. 
17. The PIC must possess at least a private pilot certificate and at least a 

current third- class medical certificate. 

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

operator’s qualification criteria and demonstrates the ability to safely operate 

the UAS in a manner consistent with how the UAS will be operated under the 

exemption, including evasive and emergency maneuvers and maintaining 

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

qualification flight hours must be logged in a manner consistent with 14 

C.F.R. § 61.51(b). Flights for 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 pre- determined location within the planned operating area and land or be 

recovered in accordance with the operating documents. 

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

emergencies in accordance with the operating documents. 

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

and forecast weather conditions) there is enough power to fly at normal 

cruising speed to the intended landing point and land the 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. 
RICHARD HUNT 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 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 UAS in a manner consistent with the 

exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles and structures. 

Considering RICHARD HUNT’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 UAS, RICHARD HUNT 

submits that the additional manned airmanship experience of a commercially 

certificated pilot would not correlate to the airmanship skills necessary for 

RICHARD HUNT’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). 

RICHARD HUNT will not allow any PIC to operate the DJI Phantom 3 UAS 

unless that PIC has demonstrated, by meeting minimum flight-hour 

requirements or the DJI Phantom 3 UAS training and currency requirements, 

that the PIC is able to safely operate the DJI Phantom 3 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 RICHARD HUNT’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, RICHARD HUNT will ensure safe operations by not allowing 

any PIC to operate the DJI Phantom 3 UAS unless that PIC has 

demonstrated, by meeting minimum flight-hour and currency requirements, 

that the PIC is able to safely operate the DJI Phantom 2 or DJI Phantom 3 

UAS in a manner consistent with the exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures. 

3. Reasons Why An Exemption From The Requirements Of Section 

91.7(a) Would Not Adversely Affect Safety. 

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

maintained because prior to every flight, RICHARD HUNT will ensure that 

the DJI Phantom 3 UAS is in an airworthy condition based upon the UAS’s 

compliance with its operating documents and as stated in the conditions and 

limitations herein. 

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

specific to UAS, in circumstances similar, in all material respects, to those 

presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 

11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 

11157, 11158, 11159, 11160, 11161). 

4. Reasons Why An Exemption From The Requirements Of Section 

91.121 Would Not Adversely Affect Safety. 

The equivalent level of safety established by Section 91.121 will be 

maintained because the altitude information of the DJI Phantom 3 UAS 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 RICHARD HUNT’s operation of the DJI Phantom 3 UAS within visual 

line of sight, at or below 400 feet AGL, will ensure a level of safety 

equivalent to Section 91.121. The altitude information will be generated by 

GPS equipment installed onboard the aircraft. Prior to each flight, a zero 

altitude initiation point is automatically established by the UASs at ground 

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

in circumstances similar, in all material respects, to those presented herein 

(e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 

11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 

11160, 11161). 

5. Reasons Why An Exemption From The Requirements Of Section 

91.151(b) Would Not Adversely Affect Safety. 

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

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

specifications of the DJI Phantom 3 UAS; (2) the limitations on the proposed 

flight operations; and (3) the location of the proposed flight operations. 

Accordingly, RICHARD HUNT will ensure that it will safely operate the 

battery powered DJI Phantom 3 UAS during daylight hours in VFR 

conditions, with enough battery power to fly for a total duration of 13.5 

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

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

Here, as in Exemption No. 11109, the technical specifications of the DJI 

Phantom 3 UAS; the limitations on the proposed flight operations; and the 

location of the proposed operations, will 

ensure an equivalent level of safety established by 14 C.F.R. Section 

91.151(b). Furthermore, safety will be ensured as the DJI Phantom 3 UAS 

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

experiences low battery voltage, the first warning occurring at approximately 

33% remaining battery power, and again at approximately 10% remaining 

battery power. At the critically low battery level, tDJI Phantom 3 UAS will 

descend and land automatically. 

Significantly, previous exemptions granted by the FAA concerning Section 

91.151 establish that safety is not adversely affected when the technical 

characteristics and operating limitations of the UAS are considered. Relief 

has been granted for manned aircraft to operate at less than the minimums 

prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 

10650. Moreover, the FAA has previously granted relief from Section 91.151 
specific to UAS, in circumstances similar, in all material respects, to those 

presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 

11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 

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

6. Reasons Why An Exemption From The Requirements Of Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would 

Not Adversely Affect Safety. 

In seeking this exemption, RICHARD HUNT 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 RICHARD HUNT 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 RICHARD HUNT Aerial 

Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 

Instruction Manual). Furthermore, RICHARD HUNT will document and 

maintain all maintenance records for theDJI Phantom 3 UAS. 

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

operating documents, RICHARD HUNT will maintain the equivalent level of 

safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A 

copy of the DJI Phantom 3 User Manuals are attached hereto as Appendix A; 

a copy of the DJI Phantom 3 UAS Maintenance LOG is attached hereto as 

Appendix B. 

Likewise, the exemption sought will not adversely affect safety because 

RICHARD HUNT will use trained technicians to perform maintenance, 

alterations or preventive maintenance on the UAS using the methods, 

techniques, and practices prescribed by the operating documents. 

Furthermore, the exemption sought would maintain an equivalent level of 

safety established by Sections 91.407, 91.417(a) and 91.417(b), because all 

maintenance of the DJI Phantom 3 UAS will 
be performed by trained technicians. Maintenance will be documented and 

maintained utilizing the monthly maintenance log. 

Significantly, previous exemptions granted by the FAA concerning Sections 

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

that safety is not adversely affected when the technical characteristics and 

operating limitations of the UAS are considered. 

In consideration of RICHARD HUNT’s proposed operating limitations, the 

operating documents, and the technical aspects of the DJI Phantom 3 UAS, 

RICHARD HUNT submits that safety will not be adversely affected by 

granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)

(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted 

relief specific to UAS in circumstances similar, in all material respects, to 

those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 

11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 

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

7. The FAA May Prescribe Any Other Conditions For Safe Operation. 

In accordance with Section 333 of the FAA Modernization and Reform Act of 

2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, RICHARD 

HUNT requests that the FAA prescribe special conditions for the intended 

operation of the DJI Phantom 3 UAS, which contain such safety standards 

that the Administrator finds necessary to establish a level of safety equivalent 

to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 

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

91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will 

permit safe operation of the UAS for the limited purpose of conducting aerial 

video and photography over certain areas of the United States for 

compensation or hire. FMRA Section 333 sets forth the requirements for 

considering whether a UAS will create a hazard to users of the NAS or the 

public, or otherwise pose a threat to national security; and further, provides 

the authority for such UAS to operate without airworthiness certification in 

accordance with any requirements that must be established for the safe 

operation of the UAS in the NAS. 
Likewise, the Administrator may prescribe special conditions pursuant to 14 

C.F.R. 

§ 21.16, for operation of the DJI Phantom 3 UAS, since the airworthiness 

regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety 

standards, due to the novel or unusual design features of the aircraft. Section 

21.16, entitled Special Conditions, states the following: 

If the FAA finds that the airworthiness regulations of this subchapter do not 

contain adequate or appropriate safety standards for an aircraft, aircraft 

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

aircraft, aircraft engine or propeller, he prescribes special conditions and 

amendments thereto for the product. The special conditions are issued in 

accordance with Part 11 of this chapter and contain such safety standards for 

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

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

See 14 C.F.R. § 21.16. 

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

FAA may prescribe special conditions for RICHARD HUNT’s intended 

operation of the DJI Phantom 3 UAS, which contain such safety standards 

that the Administrator finds necessary to establish a level of safety equivalent 

to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 

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

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

• A Summary That Can Be Published In The Federal Register, stating: 

The Rules From Which RICHARD HUNT Seeks Exemption: 

RICHARD HUNT 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 RICHARD HUNT 

Seeks: 
This exemption will permit RICHARD HUNT 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 RICHARD HUNT’s Request. 

This Petition is made pursuant to the FAA Modernization and Reform Act of 

2012 

(FMRA) Section 333, which directs the Secretary of Transportation to 

determine if certain UAS may operate safely in the NAS. As such, 

RICHARD HUNT’s request for exemption may be granted pursuant to the 

authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above. 

FMRA Section 333 sets forth the requirements for considering whether a 

UAS will create a hazard to users of the NAS or the public, or otherwise pose 

a threat to national security; and further, provides the authority for such UAS 

to operate without airworthiness certification. 

As discussed in detail above, RICHARD HUNT will operate the DJI 

Phantom 3 UAS safely in the NAS, without creating a hazard to users of the 

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

CONCLUSION 

As set forth herein, RICHARD HUNT 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 UAS 

commercially, without an airworthiness certificate, for the limited purpose of 

conducting aerial video and photography. 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 RICHARD HUNT to safely, efficiently, and 

economically operate the DJI Phantom 3 UAS commercially within the NAS. 

WHEREFORE, in accordance with the Federal Aviation Regulations and the 

FAA Modernization and Reform Act of 2012, Section 333, RICHARD 
HUNT 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 RICHARD HUNT to operate the DJI 

Phantom 3 UAS commercially for the purpose of conducting aerial video and 

photography. Dated: June 12, 2015 

Respectfully submitted, 

RICHARD HUNT 

38 West Park Place New Orleans, La. 70124 504 628 8996 

Appendices: 

A – DJI Phantom 3 Specifications Data Sheet 

APPENDIX – A 

DJI Phantom 3 TECHNICAL SPECIFICATIONS 

RICHARD HUNT only utilizes safe and reliable UAS. 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) 

2.2.1 Aircraft 

 . 2.2.1.1 Model – Phantom 3 

 . 2.2.1.2 Weight (Battery Included) – 1280 grams 
 . 2.2.1.3 Hovering Accuracy (GPS Mode) – Vertical: +/- 10cm; 

Horizontal: +/-1m 

 . 2.2.1.4 Max Angular Velocity –Yaw: 2000/s 

 . 2.2.1.5 Max Tilt Angle - 350 

 . 2.2.1.6 Max Ascent Speed – 5m/s 

 . 2.2.1.7 Max Descent Speed – 3m/s 

 . 2.2.1.8 Max Speed – 16m/s (ATTI mode, no wind – NOT 

RECOMMENDED) 

 . 2.2.1.9 Max Flight Altitude – 6000m 

2.2.1.10 Max Flight Time – Approximately 23 minutes 2.2.1.12 Motor Model 

– DJI 3510

2.2.1.13 Propeller Model – DJI 1345 

2.2.1.14 Operating Temperature Range – 140F to 1040F (-100C to 400C) 

2.2.1.15 Dimensions – 17 1⁄4” x 17 3⁄4” x 12” 

2.2.2 Gimbal 

 . 2.2.2.1 Model – ZENMUSE X3 

 . 2.2.2.2 Output Power (with camera) – Static: 9W; In Motion: 11W 
 . 2.2.2.3 Operating Current – Static: 750mA; In Motion: 900mA 

 . 2.2.2.4 Angular Vibration Range - ±0.030 

 . 2.2.2.5 Mounting – Detachable 

 . 2.2.2.6 Controllable Range – Pitch: -900 to +300; Pan: ±3200 

 . 2.2.2.7 Mechanical Range – Pitch: -1250 to 450; Pan: ±3300 

 . 2.2.2.8 Max Controllable Speed – Pitch: 1200/s; Pan: 1800/s 

2.2.3 Camera 

 . 2.2.3.1 Name – Sony EXMOR 

 . 2.2.3.2 Model – 12.4M Pixel 

 . 2.2.3.3 Total Pixels – 12.4M 

 . 2.2.3.4 Effective Pixels – 12.76M 

 . 2.2.3.5 Image Max Size – 4000x3000 

 . 2.2.3.6 ISO Range – 100-3200 

 . 2.2.3.7 Field of View - 940 
 . 2.2.3.8 CMOS – Sony EXMOR 1/2.3” 

 . 2.2.3.9 HD Video Recording – UHD(4K): 4096x2160p24/25, 

3840x2160p24/25/30; FHD: 1920x1080p24/25/30/48/50/60; HD: 

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

2.2.3.10 Operating Temperature Range - 320F - 1040F (00C - 400C) 

2.2.4 Transmitter

2.2.4.1 Name – C1 

2.2.4.2 Operating Frequency – 5.728-5.850GHz; 2.400-2.483GHz 2.2.4.3 

Communicating Distance (unobstructed) – 2000m 

2.2.4.4 Output Power – 9W

2.2.4.5 Operating Temperature Range - 140F to 1040F (-100C to 400C) 

2.2.4.6 Battery – 600mAh LiPo 2S