FROM: 

Mara Virabov

Coastal Luxury Films

30101 Town Center Drive Suite #206

Laguna Niguel, CA 92677

Tel: 310-995-2475

Email: CoastalLuxuryFilms@gmail.com

TO: 

DOCKET OPERATIONS 

ROOM W12-140 OF THE WEST BUILDING 

GROUND FLOOR

1200 NEW JERSEY AVENUE, SE.

WASHINGTON, DC, 20590

Regulatory Docket No. _______________

PETITION FOR EXEMPTION OF:

Coastal Luxury Films 

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

PART 21, SUBPART H AND SECTIONS §§ 61.113(a) & (b), 91.109, 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 2 VISION + AND DJI PHANTOM 3 PROFESSIONAL 

UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Submitted on April 23, 2015

Coastal Luxury Films Petition for Exemption Section 333 FAA 1
TABLE OF CONTENTS

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 COASTAL LUXURY FILMS

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

THE EXTENT OF RELIEF COASTAL LUXURY FILMS SEEKS AND THE

REASON COASTAL LUXURY FILMS SEEKS THE RELIEF...........................................11

THE REASONS WHY GRANTING COASTAL LUXURY FILMS’ 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.........................33

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS

CONCLUSION.........................................................................................................................33

Coastal Luxury Films Petition for Exemption Section 333 FAA 2
GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

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

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing

Coastal Luxury Films Petition for Exemption Section 333 FAA 3
SUMMARY

Coastal Luxury Films (Mara Virabov) seeks exemption from the requirements of 14 C.F.R §§

61.113(a) & (b), 91.109, 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

Coastal Luxury FIlms to operate an Unmanned Aircraft System (UAS) for the commercial

purpose of conducting aerial video and photography of Real Estate Properties (for homeowners, 

realtors, home builders, home contractors and / or home inspectors for real estate marketing and 

inspection of home exteriors) as well as filming of special events, film sets, scripted and 

unscripted television sets and landscape over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

Coastal Luxury Films is a production company based in California specializing in real estate 

videography, photography, music video production, special event production with plans to extend 

into film and television production. The principals of Coastal Luxury Films (parent company 

CBH Pictures LLC) have been in the video and entertainment production business for over ten 

years; have produced over 300 music videos and commercials, several reality television shows, 

award shows, concerts and special events. Coastal Luxury Films’ objective is to conduct aerial 

photography and videography in order to provide high quality digital imaging and video content 

to its clients, in particular to homeowners, real estate agents, realtors, home builders, home 

contractors, and/or home inspectors for real estate marketing and inspections of home exteriors 

utilizing DJI S Phantom 2 Vision + and/or DJI Phantom 3 UAS. More specifically, Coastal 

Luxury Films aerial video and photography operations will serve in the following areas:

• Aerial photography of houses / residential and commercial buildings

• Aerial videography of houses / residential and commercial buildings

• Aerial event photography

• Aerial event filming

• Aerial Film & Television production

• Aerial location scouting and safety inspection

• Increase public knowledge of UAS and promote safe UAS operations.

Coastal Luxury Films Petition for Exemption Section 333 FAA 4
The proposed aerial filming will be conducted over private property with controlled access in the 

NAS and with the knowledge and permit of the private property’s owner.

Unmanned Aircraft Systems: DJI Phantom 2 Vision+, Phantom 3 Professional UAS

Coastal Luxury Films seeks an exemption to operate DJI systems DRONES for compensation

or hire within the NAS. The DJI Phantom 2 Vision+, Phantom 3 Professional are vertical takeoff 

and landing (VTOL) Unmanned Aircrafts (UAS) with a Ground Control Station (GCS) utilizing

electronic tablet or smart phone systems. The DJI Phantom 2 Vision+, Phantom 3 Professional 

have a maximum gross weight of approximately 2 pounds 11 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 Phantom 2 Vision+, Phantom 3 Professional UAS are equipped with four main rotors; 

driven by Lithium Polymer battery powered electric motors.

The DJI Phantom 2 Vision+, Phantom 3 Professional UAS that will be operated by Coastal 

Luxury Films (trained professional), will be registered in accordance with 49 U.S.C. 44103, 

Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in 

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

BASIS FOR PETITION

Petitioner, Coastal Luxury Films, 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 2 Vision+, Phantom 3 UAS 

in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R

§§ 61.113(a) & (b), 91.109, 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

Coastal Luxury Films Petition for Exemption Section 333 FAA 5
with the unmanned aircraft and its operation, Coastal Luxury Films operation of DJI Phantom 2 

Vision+, Phantom 3 Professional 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, Coastal Luxury Films 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.

Coastal Luxury Films submits that the requested relief is proper since an equivalent

level of safety will be ensured. Coastal Luxury Films 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 2 Vision+, Phantom 3 Professional Instruction 

Manual). Furthermore, Coastal Luxury Films will document and maintain all maintenance 

records for the DJI Phantom 2 Vision+ and Phantom 3 Professional UAS.

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

privileges and limitations: Pilot In Command, is requested by Coastal Luxury Films to the

extent necessary to allow a Pilot in Command (PIC) holding a Supplemental Pilot Certificate, 

and who has demonstrated, by meeting minimum flight- hour and currency requirements, that the 

PIC is able to safely operate the DJI Phantom 2 Vision+, Phantom 3 Professional UAS in a 

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

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

Coastal Luxury Films seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, 

because the DJI Phantom 2 Vision+, Phantom 3 Professional UAS do not require an 

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

Luxury Films submits that it will ensure that the DJI Phantom 2 Vision+, Phantom 3 Professional 

UAS 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 2 

Vision+, Phantom 3 Professional Instruction Manual), and that the aircraft are in a condition for 

safe flight. Coastal Luxury Films also seeks an exemption from the requirements of Section

Coastal Luxury Films Petition for Exemption Section 333 FAA 6
91.121, entitled Altimeter Settings, as the DJI Phantom 2 Vision+, Phantom 3 Professional UAS 

will not have a typical barometric altimeter onboard. However, altitude information of the DJI 

Phantom 2Vision+, DJI Phantom 3 Professional UA 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 Coastal Luxury Films’ operation of the DJI Phantom 2 Vision+, 

Phantom 3 Professional UAS within visual line of sight, at or below 200 feet AGL, will ensure a 

level of safety equivalent to Section 91.121.

Additionally, Coastal Luxury Films seeks an exemption from the requirements of

Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. Coastal Luxury Films 

submits that safety will not be affected by operation of the DJI Phantom 2 Vision+, Phantom 3 

Professional UA during daylight hours in visual meteorological conditions (VMC) under visual 

flight rules (VFR), with enough battery power to fly for a total duration of approximately 13.5

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

after that for at least 4.5 minutes.

In accordance with 14 C.F.R. § 11.81, Coastal Luxury Films 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:

 Mara Virabov

 Coastal Luxury Films

 (parent company CBH Pictures LLC)

 30101 Town Center Drive Suite 206

 Laguna Niguel, CA 92677

 Tel: 310-995-2485

 Email: coastalluxuryfilms@gmail.com

Coastal Luxury Films Petition for Exemption Section 333 FAA 7
B. The Specific Sections Of 14 C.F.R. From Which Coastal Luxury Films Seeks

Exemption.

 1. Coastal Luxury Films 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. Coastal Luxury Films 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. Coastal Luxury Films 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.

Coastal Luxury Films Petition for Exemption Section 333 FAA 8
 4. Coastal Luxury Films 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. Coastal Luxury Films 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. Coastal Luxury Films 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. Coastal Luxury Films 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

Coastal Luxury Films Petition for Exemption Section 333 FAA 9
 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. Coastal Luxury Films 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

Coastal Luxury Films Petition for Exemption Section 333 FAA 10
 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 Coastal Luxury Films Seeks And The Reason Coastal Luxury Films Seeks 

The Relief.

 1. Extent Of Relief Coastal Luxury Films Seeks And The Reason Coastal Luxury 

 Films 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 Supplemental Pilot Certifiacte, 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 

Coastal Luxury Films Petition for Exemption Section 333 FAA 11
 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, Coastal Luxury Films submits that an equivalent 

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

 DJI Phantom 2 Vision+, Phantom 3 Professional UAS UA unless that PIC has met 

 certain flight-hour and currency requirements, demonstrating that the PIC is able 

 to safely operate either the DJI Phantom 2 Vision+, Phantom 3 Professional 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, 

 Coastal Luxury Films submits that all flights of the DJI Phantom 2 Vision+, 

 Phantom 3 Professional UAS, conducted by the PIC pursuant to the grant of this 

 Petition: (1) will be incidental to Coastal Luxury Films business; and (2) will not 

 carry passengers or property for compensation or hire.

 Coastal Luxury Films believes that though UAS are not traditional aircrafts, a 

 PIC operating the UA must have knowledge of Airman rules, basic Airspace and 

 comply with all the rules proposed by the FAA. However, considering the fact

 that a UA is almost like a toy, weighing less than a skinny person, the PIC may be 

 except from obtaining a Private Pilot Certificate, a Sports Certificate, a 

 Recreational Certificate considering these certificates require flight hours of 

 several thousand tons weighing aircrafts. The operation of UAS by Coastal 

 Luxury Films is strictly for entertainment / informational purposes, thus the 

 operators of the UAS have a career and / or freelance employment as a Camera 

 Operator and Cinematographer and will be not be entertaining a career as a pilot. 

 Lastly, Coastal Luxury Films PICs will operate the UAS no higher than 200 feet, 

 consequently causing no danger do any other aircraft in the NAS. However, 

 Coastal Luxury Films Proposes PIC Certification as a Supplemental 

 pilot and a minimum requirement of successfully completed private pilot ground 

 school. Additionally, supplemental pilots without a current FAA private pilot 

Coastal Luxury Films Petition for Exemption Section 333 FAA 12
 certificate must have successfully passed the private pilot, commercial pilot, or 

 airline transport pilot knowledge test within the past 24 calendar months.

 2. Extent Of Relief Coastal Luxury Films Seeks And The Reason Coastal Luxury 

 Films 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 Coastal Luxury Films to determine that the DJI 

 Phantom 2 Vision+, Phantom 3 UAS are in airworthy condition prior to every 

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

 (i.e., the Coastal Luxury Films Aerial Operations Manual, Monthly Maintenance 

 Log, and DJI Phantom 2 Vision+, Phantom 3 Professional Instruction Manual).

 Coastal Luxury Films seeks the requested relief because the DJI Phantom 2 

 Vision+ UAS do not require an airworthiness certificate in accordance with 14 

 C.F.R. Part 21, Subpart H. Therefore, Coastal Luxury Films will ensure that the 

 DJI Phantom 2 Vision+ UAS are in airworthy condition based upon its 

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

 DJI Phantom 2 Vision+, Phantom 3 Professional 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 Coastal Luxury Films Seeks And The Reason Coastal Luxury 

 Films 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 2 Vision+, Phantom 3 Professional 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), Coastal Luxury Films seeks the 

 requested relief because the DJI Phantom 2 Vision+ UA’s altimeter may be set on 

 the ground to zero feet AGL, rather than the local barometric pressure or field 

Coastal Luxury Films Petition for Exemption Section 333 FAA 13
 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 2 Vision+, Phantom 3 Professional 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 display of the GCS.

 

 4. Extent Of Relief Coastal Luxury Films Seeks And The Reason Coastal Luxury 

 Films 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 2 Vision+, Phantom 3 Professional UAS during daylight 

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

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

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

 Luxury Films seeks the requested relief because without an exemption

 from Section 91.151(b), the flight time duration of the battery powered DJI 

 Phantom 2 Vision+, Phantom 3 UA will severely constrain the practicality of any 

 aerial video or still photo flight operations that Coastal Luxury Films proposes to 

 conduct pursuant to this Petition.

 Significantly, as set forth below, the technical specifications of the DJI Phantom 2

 Vision+ UAS, the DJI Phantom 2 Vision+, Phantom 3 Professional operating 

 documents, and Coastal Luxury Films proposed operating limitations, ensure that 

 Coastal Luxury Films will safely operate the battery powered DJI Phantom 2 

 Vision+, Phantom 3 Professional 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.

Coastal Luxury Films Petition for Exemption Section 333 FAA 14
! ! 5. Extent Of Relief Coastal Luxury Films Seeks And The Reason Coastal Luxury 

 Films Seeks Relief From Section 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, Coastal Luxury Films 

 requests relief from these Sections because the DJI Phantom 2 Vision +, Phantom 

 3 Professional UAS do not require airworthiness certificates. As set forth more 

 fully below, the DJI Phantom 2 Vision+, Phantom 3 Professional UAS meet the 

 conditions of FMRA Section 333 for operation without an airworthiness 

 certificate. Accordingly, Coastal Luxury Films will use trained technicians to 

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

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

 documents (i.e., the Coastal Luxury Films Aerial Operations Manual, Monthly 

 Maintenance Log, and DJI Phantom 2 Vision+, Phantom 3 Professional 

 Instruction Manual). Furthermore, Coastal Luxury Films will document and 

 maintain all maintenance records for the DJI Phantom 2 Vision+, Phantom 3 

 UAS.

D. The Reasons Why Granting Coastal Luxury Films 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 Coastal Luxury 

 Films to safely, efficiently, and economically perform aerial video and photography

 of real estate, special events, film sets, and landscape over certain areas of the United 

 States.

 Additionally, use of the DJI Phantom 2 Vision+, Phantom 3 Professional UAS will 

 decrease congestion of the NAS, reduce pollution, and provide significant benefits to the 

 economy. Notably, the benefits of Coastal Luxury Films’ proposed operation of the DJI 

 Phantom 2 Vision, Phantom 3+ UAS will be realized without implicating any privacy 

 issues.

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

Coastal Luxury Films Petition for Exemption Section 333 FAA 15
 The DJI Phantom 2 Vision+, Phantom 3 Professional UA 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 2 Vision+, 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 2 Vision+, Phantom 3 Professional UA 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 2 Vision+, Phantom 3 UAS.

 Conducting aerial acquisitions with the DJI Phantom 2 Vision+, Phantom 3 

 Professional UAS, instead of manned aircraft, will greatly benefit the public by 

 drastically reducing the levels of air and noise pollution generated during 

 traditional aerial video and still photography flight operations. By using battery 

 power and electric motors, the DJI Phantom 2 Vision+, Phantom 3 Professional 

 UAS 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 2 

 Vision+, Phantom 3 Professional UA, while reducing the carbon footprint of 

 aerial acquisitions, also eliminates noise pollution, as the UAS are propelled by 

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

 using the DJI Phantom 2 Vision+, Phantom 3 Professional UAS to 

 perform aerial acquisitions, the substantial risk to life and property in the air and 

Coastal Luxury Films Petition for Exemption Section 333 FAA 16
 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 2 

 Vision+, Phantom 3 UAS (weighing approximately 2 pounds 11 ounces and 6 

 pounds 7.5 ounces respectively, at their maximum gross weights with lengths of 

 16 inches and 17.3 inches respectively, widths of 16 inches and 17.7 inches 

 respectively, and with no fuel on board), has less physical potential for collateral 

 damage to life and property on the ground, and in the air, compared to the manned 

 aircraft that typically conduct similar operations (weighing approximately 6,000 

 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel 

 capacity of 180 gallons).

 3. Performing Aerial Video and Photography Operations With The DJI

 Phantom 2 Vision+, Phantom 3 UAS Will Benefit The Economy.

 In addition to being safe and efficient, the DJI Phantom 2 Vision+, Phantom 3 

 Professional is also an economical alternative to using manned aircraft to conduct 

 similar aerial operations. As such, operation of the DJI Phantom 2 Vision+, 

 Phantom 3 Professional UAS will allow United States based companies, like 

 Coastal Luxury Films, 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 2 

 Vision+, Phantom 3 Professional 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 Vision+, Phantom 3 Professional UAS, 

 companies such as Coastal Luxury Films, 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 

Coastal Luxury Films Petition for Exemption Section 333 FAA 17
 performance of U.S. companies, through commercial use of the DJI Phantom 2 

 Vision +, Phantom 3 Professional UAS, provides a stable workforce that increases 

 consumer spending; improves local, state, and federal tax revenues; and allows 

 companies to invest in research and development in order to remain competitive 

 both in the United States and abroad.

 4. There Are No Privacy Issues.

 Similar to the manned aerial acquisition flight operations that have been 

 conducted for decades, Coastal Luxury Films proposed operation of the DJI 

 Phantom 2 Vision+, Phantom 3 UAS will not implicate any privacy issues. 

 Specifically, the DJI Phantom 2 Vision+, Phantom 3 Professional UAS will be 

 operated only in compliance with operating documents (i.e., the Coastal Luxury 

 Films Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 

 Vision+, Phantom 3 Professional 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 Coastal Luxury Films Seeks Exemption.

1. Reasons Why The DJI Phantom 2 Vision+, Phantom 3 Professional 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, Coastal Luxury Films operation of the DJI

Phantom 2 Vision+, 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.

Coastal Luxury Films Petition for Exemption Section 333 FAA 18
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 rule-making 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, Coastal Luxury Films submits that the DJI Phantom 2

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

 demonstrated by: (a) the characteristics of the DJI Phantom 2 Vision+, Phantom 3 

 Professional UAS; 

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

 a. The Specifications Of The DJI Phantom 2 Vision+, Phantom 3 Professional 

 UAS Demonstrate Its Safe Characteristics.

Coastal Luxury Films Petition for Exemption Section 333 FAA 19
 The DJI Phantom 2 Vision+, Phantom 3 Professional UAS does not create a 

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

 security considering its size, weight, speed, and operational capability.

 

 i. Technical Specifications Of The DJI Phantom 2 Vision+, Phantom 3 

 Professional UAS.

 The technical specifications of the DJI Phantom 2 Vision+, Phantom 3 

 Professional UAS is set forth by the DJI Phantom 2 Vision+, Phantom 3 

 Professional Specifications and Data Sheet, attached hereto as Exhibit A.

 

 ii. The DJI Phantom 2 Vision+, Phantom 3 Professional UAS Autonomous 

 Flight And Navigation Modes Enable The UAS To Remain Within A 

 Defined Operational Area. The DJI Phantom 2 Vision+, Phantom 3 

 Professional UAS may be operated in both manual and fully autonomous 

 flight modes. A complete description of the flight and navigational modes 

 of the DJI Phantom 2 Vision+, Phantom 3 UAS is provided at pages 25-35 

 of the DJI Phantom 2 Vision+, User Manual, attached hereto as 

 Exhibit B & D (Phantom 3 User Manual will be available after May 15, 

 2015; however, is very similar to DJI Phantom 2 Vision+ User Manual).

 

 iii. The DJI Phantom 2 Vision+, Phantom 3 Professional 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 2 Vision+ UA will remains stationary, in flight, for 3 

 seconds or more. If, after 3 seconds, the DJI Phantom 2 Vision+, Phantom 

 3 Professional UA does not reacquire control link data from the GCS, the 

 UA will assume that the Control Link is lost and the UA 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 2 Vision+, Phantom 3 UAS are set forth at 

Coastal Luxury Films Petition for Exemption Section 333 FAA 20
 pages 27 through 29 of the DJI Phantom 2 Vision+, (Phantom 

 3) Professional User Manual, attached hereto as B & D.

 iv. The DJI Phantom 2 Vision+, Phantom 3 Professional GCS And Its 

 Operation.

 A complete description of the operation and specifications of the DJI 

 Phantom 2 Vision+, Phantom 3 GCS and flight control software is 

 provided at pages 32 through 43 of the DJI Phantom 2 Vision+, (Phantom 

 3) Professional User Manual. DJI Phantom 2 Vision+ User Manual is 

 attached hereto as Exhibit B & D.

 

 b. Flight Operations Of DJI Phantom 2 Vision+, Phantom 3 Professional 

 UAS Are Limited To The Line Of Sight Of A Certificated Pilot in Command 

 With A Safety Observer.

 Coastal Luxury Films 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 2 Vision, Phantom 3 + UAS. Additionally, a safety observer will assist 

 all pilots during flight time.

 c. Flights Of DJI Phantom 2 Vision+, Phantom 3 Professional UAS Will Be 

 Conducted Pursuant To Specific Operating Limitations.

 In seeking this exemption, proposes to commercially operate DJI Phantom 2

 Vision+ UAS for the special purpose of conducting aerial video and photography 

 over certain areas of United States, pursuant to the following specific operating 

 limitations:

 1. Operations authorized by this grant of exemption will be limited to the following

 aircraft described in the operating documents, rotorcraft UASs weighing less

 than 55 pounds maximum gross weight: DJI Phantom 2 Vision+, Phantom 3 Professional 

 Unmanned Aircraft System. Proposed operations of any other aircraft will require a new

 petition or a petition to amend this grant.

Coastal Luxury Films Petition for Exemption Section 333 FAA 21
 2. UAS operations under this exemption will be limited to conducting operations

 for the purpose of aerial video and photography for homeowners, Realtors, home 

 builders, contractors, home inspectors for use in real estate marketing and real estate 

 inspections. Additionally, aerial video and photography may be conducted on occasional 

 basis for film and television sets, special events and landscape photography as deemed 

 necessary.

 3. The UAS may not be flown at an indicated airspeed exceeding 29 knots (15 m/s).

 4. The UAS must be operated at an altitude of no more than 200 (500 per the User 

 Manual) 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.

Coastal Luxury Films Petition for Exemption Section 333 FAA 22
 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

Coastal Luxury Films Petition for Exemption Section 333 FAA 23
 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 UAS operated under this exemption must comply with all manufacturer

 Safety Bulletins.

 16. The authorized person must make an entry in the aircraft record of the

 corrective action taken against discrepancies discovered between inspections.

 17. The PIC must possess at least a Suplemental Pilot certificate and at least a current

 third- class medical certificate. Supplemental pilots must have, at a minimum, 

 successfully completed private pilot ground school. Additionally, supplemental pilots 

 without a current FAA private pilot certificate must have successfully passed the private 

 pilot, commercial pilot, or airline transport pilot knowledge test within the past 24 

 calendar months.

 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

Coastal Luxury Films Petition for Exemption Section 333 FAA 24
 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

Coastal Luxury Films Petition for Exemption Section 333 FAA 25
 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.

Coastal Luxury Films Petition for Exemption Section 333 FAA 26
 29. The UAS 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.

Coastal Luxury Films Petition for Exemption Section 333 FAA 27
2. Reasons Why An Exemption From The Requirements Of Section 61.113(a)

And (b) Would Not Adversely Affect Safety.

Coastal Luxury Films 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 2 Vision

+, Phantom 3 Professional UAS unless that PIC has demonstrated, by meeting minimum flighthour and currency requirements, that the PIC is able to safely operate the DJI Phantom 2 Vision

+, Phantom 3 Professional UAS in a manner consistent with the exemption, including evasive 

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

and structures.

Considering Coastal Luxury Films 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 2 Vision+, Phantom 3 Professional UAS, Coastal Luxury 

Films submits that the additional manned airmanship experience of a commercially certificated 

pilot would not correlate to the airmanship skills necessary for Coastal Luxury Films 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).

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, Coastal Luxury Films will ensure that the DJI Phantom 2

Vision+ 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.

Coastal Luxury Films Petition for Exemption Section 333 FAA 28
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 2, Vision, Phantom 3 + UA will be provided 

to the PIC via GPS equipment and a radio communications telemetry data link, which downlinks

from the UA to the GCS for active monitoring of the flight path and altitude. This altitude

information, combined with Coastal Luxury Films’ operation of the DJI Phantom 2

Vision+, Phantom 3 UAS within visual line of sight, at or below 500 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 2 Vision+, Phantom 3 UAS; (2) the limitations on the proposed flight operations; and 

(3) the location of the proposed flight operations. Accordingly, Coastal Luxury Films will ensure 

that it will safely operate the battery powered DJI Phantom 2 Vision+, Phantom 3 Professional 

UA during daylight hours in VFR conditions, with enough battery power to fly for a total 

duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising 

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

Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 2

Coastal Luxury Films Petition for Exemption Section 333 FAA 29
Vision+, 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 2 Vision+, Phantom 3 

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

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

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

battery level, the DJI Phantom Vision+, 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, Coastal Luxury Films 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 Coastal Luxury FIlms will use trained technicians to perform maintenance,

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

practices prescribed in the operating documents (i.e., the Coastal Luxury Films Aerial Operations

Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+, Phantom 3 Professional 

Instruction Manual). Furthermore, Coastal Luxury Films will document and maintain all 

maintenance records for the DJI Phantom 2 Vision+, Phantom 3 Professional UAS.

Since the DJI Phantom 2 Vision+, Phantom 3 Professional UAS will be inspected as prescribed 

by the operating documents, Coastal Luxury Films will maintain the equivalent level of safety

Coastal Luxury Films Petition for Exemption Section 333 FAA 30
established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI

Phantom 2 Vision+ User Manual is attached hereto as Exhibit B & D; a copy of the DJI Phantom 

2 Vision+, Phantom 3 UAS Maintenance LOG is attached hereto as Exhibit C.

Likewise, the exemption sought will not adversely affect safety because Coastal Luxury Films 

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 2 Vision+, Phantom 3 Professional 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 Coastal Luxury Films proposed operating limitations, the

operating documents, and the technical aspects of the DJI Phantom 2 Vision +, Phantom 3 

Professional UAS, Coastal Luxury Films 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, Coastal Luxury Films requests

that the FAA prescribe special conditions for the intended operation of the DJI Phantom 2

Vision+, 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

Coastal Luxury Films Petition for Exemption Section 333 FAA 31
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 2 Vision+, Phantom 3 Professional 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 Coastal Luxury Films’ intended operation of the DJI

Phantom 2 Vision+, 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).

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

From Which Coastal Luxury Films Seeks Exemption:

Coastal Luxury Films 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).

Coastal Luxury Films Petition for Exemption Section 333 FAA 32
A Brief Description Of The Nature Of The Exemption Coastal Luxury FIlms Seeks:

This exemption will permit Coastal Luxury Films to commercially operate an

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

photography over certain areas of the United States.

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

Luxury Films 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, Coastal Luxury Films 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, Coastal Luxury Films will operate the DJI Phantom 2

Vision +, Phantom 3 Professional 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, Coastal Luxury Films 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 2 Vision+, Phantom 3 Professional UAS 

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

video and photography over certain areas of the United States. By granting this Petition, the FAA

Administrator will be fulfilling the Congressional mandate of the FAA Modernization and

Reform Act of 2012, while also advancing the interests of the public, by allowing Coastal 

Luxury Films to safely, efficiently, and economically operate the DJI Phantom 2, Phantom 3 

Vision+ UAS commercially within the NAS.

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

Coastal Luxury Films Petition for Exemption Section 333 FAA 33
Modernization and Reform Act of 2012, Section 333, Coastal Luxury Films 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 Coastal Luxury Films to operate the DJI

Phantom 2 Vision +, Phantom 3 Professional UAS commercially for the purpose of conducting 

aerial video and photography of Real Estate Properties (for homeowners, realtors, home 

builders, home contractors and / or home inspectors for real estate marketing and inspection of 

home exteriors) as well as filming of special events, film sets, scripted and unscripted television 

sets and landscape over certain areas of the United States. 

Dated: April 23, 2015

Respectfully submitted by,

Mara Virabov

_________________________

Mara Virabov

Coastal Luxury Films

(CBH Pictures LLC)

30101 Town Center Drive Suite #206

Laguna Niguel, CA 92677

Tel: 310-995-2475

Email: CoastalLuxuryFilms@gmail.com

Coastal Luxury Films Petition for Exemption Section 333 FAA 34
Appendixes:

A – DJI Phantom 2 Vision+ Specifications Data Sheet

B – DJI Phantom 2 Vision+ Manufacturer’s User Manual

C – DJI Phantom 3 Professional Specifications Data Sheet

D – DJI Phantom 3 Manufacturer’s User Manual

E – Monthly Maintenance Log

APPENDIX – A

DJI PHANTOM 2 VISION+ TECHNICAL SPECIFICATIONS

Coastal Luxury Films 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)

1.1 DJI Phantom 2 Vision+

 1.1.1 Aircraft

 1.1.1.1 Supported Battery – DJI 5200mAH 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 - 2000/s

 1.1.1.5 Max Tilt Angel - 350

 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 - ±0.030

 1.1.2.3 Controllable Range – Pitch: -900 - 00

 1.1.2.4 Maximum Angular Speed – Pitch: 900/s

 1.1.3 Camera

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

 1.1.3.2 Sensor Size – 1/2.3”

 1.1.3.3 Effective Pixels – 14M

Coastal Luxury Films Petition for Exemption Section 333 FAA 35
 1.1.3.4 Resolution – 4384x3288

 4.1.3.5 HD Video Recording – 1080p30 & 720p

 4.1.3.6 Recording Field of View - 1100/850

 1.1.4 Transmitter

 1.1.4.1 Operating Frequency – 5.728GHz – 5.85GHz

 1.1.4.2 Communication Distance (unobstructed) – FCC Compliance: 800m

 1.1.4.3 Receiver Sensitivity (1%PER) - -93dBm

 1.1.4.4 Transmitter Power – FCC Compliance: 100mW

 1.1.4.5 Working Voltage – 120mA@3.7V

 1.1.5 Range Extender

 1.1.5.1 Operating Frequency – 2412-2462MHz

 1.1.5.2 Communication Distance (unobstructed) – 500-700m

 1.1.5.3 Transmitter Power – 20dBm

 1.1.5.4 Power Consumption – 2W

Coastal Luxury Films Petition for Exemption Section 333 FAA 36
APPENDIX – B

DJI Phantom 2 Vision+ Manufacturer’s User Manual

(uploaded in a separate attachment, a 72-page document)

Coastal Luxury Films Petition for Exemption Section 333 FAA 37
APPENDIX – C

DJI PHANTOM 3 TECHNICAL SPECIFICATIONS

AIRCRAFT

Weight (Including Battery And Propellers) 1280 g

Diagonal Size (Including Propellers) 590 mm

Max Ascent Speed 5 m/s

Max Descent Speed 3 m/s

Hover Accuracy

• Vertical: +/- 10cm

• Horizontal: +/- 1m

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

Max Altitude Above Sea Level 6000 m

Operating Temperature 0°C to 40°C

Gps Mode GPS/GLONASS

GIMBAL

Controllable Range Pitch -90° to +30°

Stabilization 3-axis (pitch, roll, yaw)

Coastal Luxury Films Petition for Exemption Section 333 FAA 38
REMOTE CONTROLLER

Operating Frequency 2.400 GHz-2.483 GHz

Max Distance 2000m (outdoors and unobstructed)

Video Output Port USB

Operating Temperature 0°C- 40°C

Battery 6000 mAh LiPo 2S

Mobile Device Holder For tablet or phone

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

Transmitter Power (Eirp)

• FCC: 20 dBm

• CE: 16 dBm

Working Voltage 1.2 A @7.4 V

BATTERY CHARGER

Voltage 17.4 V

Rated Power Phantom 3 Professional 100 W

Coastal Luxury Films Petition for Exemption Section 333 FAA 39
INTELLIGENT FLIGHT BATTERY

Capacity 4480 mAh

Voltage 15.2 V

Battery Type LiPo 4S

Energy 68 Wh

Net Weight 365 g

Max Flight Time Approximately 23 minutes

Operating Temperature -10°C to 40°C

Max Charging Power 100 W

Coastal Luxury Films Petition for Exemption Section 333 FAA 40
APPENDIX – D

DJI Phantom 3 Professional Manufacturer’s User Manual

(DJI Phantom 3 Professional Manual will be available after May 15, 2015. Coastal Luxury Films 

ordered DJI Phantom 3 Professional UA and will expect shipping after May 15, 2015 along with 

the User Manual. The User Manual of DJI Phantom 3 Professional is very similar to the User 

Manual of DJI Phantom 2 Vision +, with several minor changes, in particular of the quality of 

the camera attached to the device. For more information please refer to attachment (Appendix -

B) which provides the complete manual of DJI Phantom 2 Vision + UA.)

Coastal Luxury Films Petition for Exemption Section 333 FAA 41
APPENDIX – E

MONTHLY MAINTENANCE LOG

month:_________year:________

UAS 

#___________

Date Issue 

Discovered

Date Issue 

Addressed

Issue Description & 

Maintenance Conducted

Maintenance 

Performed By:

Print & Sign

Software Updates

Airframe

Engines

Propellers

Camera Gimbal

Landing Gear

Vibration 

Dampening

Other:

Mara Virabov

Coastal Luxury Films

 (CBH Pictures LLC)

30101 Town Center Drive Suite #206

Laguna Niguel, CA 92677

Tel: 310-995-2475

Email: CoastalLuxuryFilms@gmail.com

Coastal Luxury Films Petition for Exemption Section 333 FAA 42