U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue, SE

Washington, D.C. 20590

Donald Roe

Planning and Urban Design Director

City of Saint Louis

1520 Market St, Suite 2000

Saint Louis, MO 63103

BASIS FOR PETITION

Petitioner, City of St. Louis, pursuant to the provisions of the Federal Aviation Regulations {14 C.F.R. §

11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for

Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate the DJI

Phantom 3 Advanced, in the National Airspace System (NAS), and for an exemption from the

requirements of:

14 C.F.R §§ 61.113{a) & {b)

14 CFR 45.23{b)

91.7{a), 91.121,

91.151{b),

91.405(a), 91.407{a){1), 91.409{a)(1) & (a){2), and 91

Name and Address of the Petitioner

Donald Roe

Planning and Urban Design Director  

City of Saint Louis

Saint Louis, MO 63103

Office: (314) 657‐3848

Email: roed@stlouis‐mo.gov

Preface:

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory

authority by its terms includes exempting civil aircraft, as the term is defined under §40101 of the Act,

that includes UAS, from the requirement that all civil aircraft must have a current airworthiness

certificate.

The Administrator may grant an exemption from a requirement of a regulation prescribed under

subsection (a) or (b) of this section or any sections 44702‐ 44716 of this title if the Administrator finds

the City of Saint Louis, UAV Petition for Exemption the exemption in the public interest. 49 U.S.C.

§44701(f) See also 49 USC §44711(a); 49 USC §44704; 14

CFR §91.203 (a) (1).

The City of Saint Louis proposes to use one or more Unmanned Aerial Drones (DJI PHANTOM 3

Advanced), for the following uses:

• Inspections of city‐owned rights‐of‐way
• Inspections of city‐owned or city‐funded infrastructure improvement projects

• Bridge inspections

• Assist with damage assessments or situational status reports during emergency response

operations

• Evaluations within the city related to flora & fauna (vegetation & wildlife) issues.

• Historic District / Historic Site photography

• Support to law enforcement and fire departments during response operations.

• Assist with site security during city‐sponsored events (i.e. Summer Concert Series, parades, etc.)

This aircraft has four rotors and four motors in a quadcopter configuration (X4). It is only capable of

vertical takeoff and landings. This UAS weighs less than 55 lbs. including payload, can fly, under normal

conditions at a speed of no more than 30 knots and has the capability to hover, and move in the vertical

and horizontal plane simultaneously. This UAS is equipped with GPS and auto‐return function to the

predetermined safe landing area as well as allowing reading of magnetic interference that can cause loss

off GPS signal. The UAS will operate only in line of sight and will operate only within the limits of public

rights of way or easements. Such operations will be conducted to insure that the UAS will "not create a

hazard to users of the national airspace system or the public." (Reform Act Section 333 (b)).

This exemption application is expressly submitted to fulfill Congress' goal in passing Section 333(a)

through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether

certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before

completion of the rule making required under Section 333 of the Reform Act. In making this

determination, the Secretary is required to determine which types of UASs do not create a hazard to

users of the NAS or the public or pose a threat to national security in light of the following:

• The UAS's size, weight, speed and operational capability;  

• Operation of the UAS in close proximity to airports and populated areas;  

• Operation of the UAS within visual line of sight of the operator;

Reform Act§ 333 (a). Secretary determines that such vehicles "may operate safely in the national

airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the

national airspace system." ld. §333(c).   

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory

authority by its terms includes exempting civil aircraft, as the term is defined under §40101 of the Act,

that includes UAS, from the requirement that all civil aircraft must have a current airworthiness

certificate.

The Administrator may grant an exemption from a requirement of a regulation prescribed under

subsection (a) or (b) of this section or any sections 44702‐44716 of this title if the Administrator finds

the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC §44704; 14

CFR §91.203 (a) (1).

Relief Overview

Given the small size of the UAS involved and the restricted environment within which they will operate,

the applicant falls within that zone of safety (an equivalent level of safety) in which Congress envisioned

that the FAA allow commercial operations of UASs to commence immediately. Also due to the size of
the UASs and the restricted areas in which the relevant UAS will operate, approval of the application

presents no national security issue.

Given the clear direction in Section 333 of the Reform Act, the authority contained in the Federal

Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations,

and the significant public benefit, including enhanced safety, reduction in environmental impacts,

including reduced emissions associated with allowing UASs for aerial inspections, surveying,

photography and videography, the grant of the requested exemptions is in the public interest.

Accordingly, the applicant respectfully requests that the FAA grant the requested exemption.

Aircraft and Equivalent Level of Safety

The City of St. Louis proposes that the exemption requested herein apply to civil aircraft that have the

characteristics and that operate with the limitations listed herein. These limitations provide for at least

an equivalent or even higher level of safety to operations under the current regulatory structure

because the proposed operations represent a safety enhancement to the already safe aerial inspections,

surveying and photography and videography operations conducted with conventional aircraft.

These limitations and conditions to which the City of St. Louis agrees to be bound when conducting

commercial operations under an FAA issued exemption include

• The UAS will weigh less than 55 lbs;

• Flights will be operated within line of sight of a Pilot‐In Command (PIC) and a Safety Observer

(SO);

• Maximum total flight time for each operational flight will be 30 minutes or less;  

• Flights will be terminated at 25% battery power reserve should that occur prior to the 30 minute

limit;  

• Flights will be operated at an altitude of no more than 200 feet AGL or, not more than 200 feet

above an elevated platform for which filming is planned;

• Minimum crew for each operation will consist of the UAS Pilot and one Visual Observer;

• The UAS will only operate within the defined project area, the boundaries of which will be

determined by the UAS Pilot‐In‐Command (PIC) based on the site‐specific activities and speed of

the UAS required for the operation, and coordinated with the jurisdictional FAA FSDO and local

government officials as applicable;

• A briefing will be conducted in regards to the planned UAS operations prior to each day's

operation. It will be mandatory that all personnel who will be performing duties within the

boundaries of the project be present for this briefing;

• The UAS Pilot and Safety Observer will be able to communicate by voice and/or two way radio

communication system at all times;

• The operations of the UAS will be limited to daylight‐only operations;

• If the UAS loses communications or loses its GPS signal, the UAS will have the capability to

return to a pre‐ determined location within the Project Perimeter and land safely;

• The UAS will have the capability to abort flight in case of unpredicted obstacles or emergencies;

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) Subpart H, entitled

Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness

certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with

the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the

requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The
Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to

exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size,

weight, speed, operational capability, and proximity to airports and populated areas of the particular

UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an

airworthiness certificate, in the restricted environment and under the conditions proposed will be at

least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an

airworthiness certificate without the restrictions and conditions proposed.

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

aircraft and its operation, the City of St. Louis’ operation of DJI Phantom 3 Advanced, 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, the City of Saint Louis 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. The City of Saint Louis submits that the requested relief is

proper since an equivalent level of safety will be ensured. The City of Saint Louis will use experienced

personnel or technicians as needed to perform maintenance, alterations, or preventive maintenance on

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

Monthly Maintenance Log, and DJI Phantom 3 Advanced Instruction Manual). Furthermore, the City of

Saint Louis will document and maintain all maintenance records for the DJI Phantom 3 Advanced UAS.

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

limitations: Pilot in command, is requested by the City of Saint Louis to the extent necessary to allow a

Pilot in Command (PIC) meet or exceed the described requirements of operations set by manufacturer,

and who has demonstrated, that the PIC is able to safely operate the DJI Phantom 3 Advanced UAS in a

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

appropriate distances from people, vessels, vehicles and structures.

The City of Saint Louis seeks relief from Section 9L7(a), entitled Civil aircraft airworthiness, because the

DJI Phantom 3 Advanced UAS does not require an airworthiness certificate in accordance with 14 C.F.R.

Part 21, Subpart H. As such, the City of Saint Louis submits that he will ensure that the DJI Phantom 3

Advanced UAS is in an airworthy condition, prior to every flight, by determining that the UASs are in

compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Advanced

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

The City of Saint Louis also seeks an exemption from the requirements of Section 91.121, entitled

Altimeter Settings, as the DJI Phantom 3 Advanced will not have a typical barometric altimeter onboard.

However, altitude information of the DJI Phantom 3 Advanced 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

the City of Saint Louis’ operation of the DJI Phantom 3 Advanced UAS within visual line of sight, at or

below 200 feet AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, the City of St. Louis seeks an exemption from the requirements of Section 91.151(b),

entitled Fuel requirements for flight in VFR conditions.  All flights of the DJI Phantom 3 Advanced will be

conducted 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 30 minutes to the first

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

Extent and Reasoning Why the City of St. Louis Seeks Relief from the Above Sections

1. Section 61.113(a) & (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 meet all requirements

as described in the DJI Phantom 3 Advanced owner's manual 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 City of Saint Louis, UAV Petition for Exemption 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, the City of St. Louis submits that an equivalent level of safety will be

maintained because no PIC will be allowed to operate the DJI Phantom 3 Advanced UAS unless that PIC

has demonstrated that the PIC is able to safely operate either the DJI Phantom 3 Advanced 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, the City of St. Louis submits that all flights of the DJI Phantom 3 Advanced UAS, conducted by

the PIC pursuant to the grant of this Petition: (1) will be incidental to the City of St. Louis’ business; and

(2) will not carry passengers or property for compensation or hire.

In addition, due to the vertical dimensions of the City of Saint Louis boundaries penetrating both Class B

airspace of Lambert International Airport (KSTL) and Class D airspace of Saint Louis Downtown Airport

(KCPS), all flights of the DJI Phantom 3 Advanced UAS will be approved and conducted under the

supervision of a FAA Certified Flight Instructor.  All operators will be trained in the avoidance of this

airspace.  

2. 91.7(a). Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent

required to allow the City of St. Louis to determine that the DJI Phantom 3 Advanced UASs are in

airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating

documents (i.e., the City of St. Louis Operations Manual, Monthly Maintenance Log, and DJI Phantom 3

Advanced Instruction Manual).  The City of St. Louis seeks the requested relief because the DJI Phantom

3 Advanced UAS does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21,

Subpart H. Therefore, the City of St. Louis will ensure that the DJI Phantom 3 Advanced UAS are in

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

Maintenance Log, and DJI Phantom 3 Advanced 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. 91.121. Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight

operations of the DJI Phantom 3 Advanced 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), the

City of St. Louis seeks the requested relief because the DJI Phantom 3 Advanced UA 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 Advanced UA

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. 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 Advanced UA

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

total duration of 25 minutes to the first point of intended landing and, assuming normal cruising speed,

to fly after that for at least 5 minutes. The City of St. Louis seeks the requested relief because without an

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

Advanced UA will severely constrain the practicality of any aerial video or still photo flight operations

that the City of St. Louis proposes to conduct pursuant to this Petition.

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

Phantom 3 Advanced operating documents, and the City of St. Louis’ proposed operating limitations,

ensure that the City of St. Louis will safely operate the battery powered DJI Phantom 3 Advanced 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 25 minutes to the first point of intended landing and,

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

14 CFR 45.23(b) Marking of the Aircraft. Applicable codes of Federal Regulation require aircraft to be

marked according to certain specifications. UAV Field Services UASs are, by definition, unmanned. They

therefore do not have a cabin, cockpit or pilot station on which to mark certain words or phrases.

Further, two inch lettering is difficult to place on such small aircraft. CITY OF SAINT LOUIS petition for

exemption by placing the "N "number on its fuselage as required by 14 CFR 45.29 (f) so that the pilot,

technician, spotter and others working with the UAV will see the markings. The FAA has previously

issued exemptions to this regulation through‐ Exemption No 10167 and 10700

5. 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, City of Saint Louis requests relief from these Sections because the DJI Phantom 3 Advanced

UAS do not require airworthiness certificates. As set forth more fully below, the DJI Phantom 3

Advanced UAS meet the conditions of FMRA Section 333 for operation without an airworthiness

certificate. Accordingly the City of Saint Louis 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 City of St. Louis aerial Operations Manual, Monthly

Maintenance Log, and DJI Phantom 3 Advanced Instruction Manual). Furthermore, the City of St. Louis

will document and maintain all maintenance records for the DJI Phantom 3 Advanced UAS.
The reasons for granting this request are entirely beneficial to the public and community as a whole.

Granting the present Petition will further the public interest by allowing the City of St. Louis to safely,

efficiently, and economically perform aerial video and photographic surveys and inspections of

construction sites, rights of way, utility easements, and other sites within the City of Saint Louis,

Missouri.

This exemption application is expressly submitted to fulfill Congress' goal in passing Section 333{a)

through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether

certain unmanned aircraft systems may operate safely in the national airspace system {NAS) before

completion of the rule making required under Section 332 of the Reform Act. In making this

determination, the Secretary is required to determine which types of UAS do not create a hazard to

users of the NAS or the public or pose a threat to national security in light of the following:

• The UAS's size, weight, speed and operational capability;

• Operation of the UAS in close proximity to airports and populated areas; and

• Operation of the UAS within visual line of sight of the operator.

Reform Act § 333 (a).  Lastly, the Secretary determines that such vehicles 11may operate safely in the

national airspace system, the Secretary shall establish requirements for the safe operation of such

aircraft in the national airspace system." ld. §333{c).

Given the small size of the UAS involved and the restricted sterile environment within which they will

operate, the applicant falls squarely within that zone of safety (an equivalent level of safety) in which

Congress envisioned that the FAA must, by exemption, allow commercial operations of UASs to

commence immediately. Also due to the size of the UASs and the restricted areas in which the relevant

UAS will operate, approval of the application presents no national security issue. Given the clear

direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as

amended; the strong equivalent level of safety surrounding the proposed operations, and the significant

public benefit, including enhanced safety, reduction in environmental impacts, including reduced

emissions associated with allowing UASs for video and photographic operations, the grant of the

requested is in the public interest. Accordingly, the applicant respectfully requests that the FAA grant

the requested exemption.

Reasons Beneficial to the Public

1. The Public Will Benefit from Decreased Congestion of the NAS.

The DJI Phantom 3 Advanced 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 3 Advanced 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 Advanced UA does

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 Advanced UAS.

Conducting aerial acquisitions with the DJI Phantom 3 Advanced 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 3 Advanced 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 3 Advanced 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 3 Advanced UAS to perform aerial observation, 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 Advanced UAS (weighing approximately 2

pounds 11 ounces, at their maximum gross weights with length of 16 inches, widths of 16 inches, 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, surveys and inspections, operations with the DJI Phantom 3

Advanced UAS will benefit the economy. In addition to being safe and efficient, the DJI Phantom 3

Advanced UAS are also provides an economical alternative to using manned aircraft to conduct similar

aerial operations. As such, operation of the DJI Phantom 3 Advanced UAS will allow the City of Saint

Louis, to provide quality services to the residents and businesses of the City and the Region at minimum

costs. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency {"EPA")

regulatory actions phasing out leaded aviation fuels, agencies must adopt new and alternative

technology in continue to provide required services at reasonable costs. Operating the battery powered

DJI Phantom 3 Advanced UAS is one such technology that not only allows agencies and companies

greater operational flexibility compared to manned aircraft, but provides such flexibility without the

high operational cost of a traditional manned aircraft.

By operating the DJI Phantom 3 Advanced UAS, the City of Saint Louis can maintain and hopefully

improve our ability to operate and maintain critical infrastructure and at the same time collect

important data for further development of system‐wide modeling of water, wastewater, stormwater,  

historic preservation, and roadway systems as well as provide accurate and current data related to

environmental issues such as ground cover, vegetation & wildlife habitats.

4. There Are No Privacy Issues. Similar to the manned aerial acquisition flight operations that have been

conducted for decades, the City of St. Louis’ proposed operation of the DJI Phantom 3 Advanced UAS

will not implicate any privacy issues. Specifically, the DJI Phantom 3 Advanced UAS will be operated only

in compliance with operating documents (i.e., The City of St. Louis Aerial Operations Manual, Monthly

Maintenance Log, and DJI Phantom 3 Advanced Instruction Manual) which requires property owner

involvement as well as local law enforcement notification, and in accordance with the Federal Aviation

Regulations, including the maximum altitude limitations as per the requirements of 14 C.F.R. § 91.119.

The Reasons Why Granting the Exemption Would Not Adversely Affect Safety
Reasons Why The DJI Phantom 3 Advanced UA Meet The Conditions Of The FAA Modernization and

Reform Act of 2012 (FMRA) Section 333:

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

unmanned aircraft and its operation, City of Saint Louis operation of the DJI Phantom 3

Advanced 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. In seeking this exemption, the City of

St. Louis submits that the DJI

2. Phantom 3 Advanced UAS can operate safely in the NAS pursuant to FMRA Section 333, as

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

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

a. The Specifications OfThe DJI Phantom 3 Advanced UAS Demonstrate Its Safe

Characteristics. The DJI Phantom 3 Advanced UAS do not create a hazard to users of the

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

weight, speed, and operational capability.

i. Technical Specifications of the DJI Phantom 3 Advanced UAS.  The technical

specifications of the DJI Phantom 3 Advanced UAS are set forth by the DJI

Phantom 3 Advanced Specifications and Data Sheet attached.

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

Enable The UAS To Remain Within A Defined Operational Area. The DJI Phantom

3 Advanced 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 3 Advanced UAS are included in the User Manuals.

iii. The DJI Phantom 3 Advanced UASs are designed for automatic return to home

point or hover in the event of loss of the Control Link or navigation. When the

Control Link is lost, the DJI Phantom 3 Advanced UA will remain stationary, in

flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 3 Advanced

UA 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 Advanced

UA is set forth in the DJI Phantom 3 Advanced User Manual.

iv. The DJI Phantom 3 Advanced GCS and Its Operation. A complete description of

the operation and specifications of the DJI Phantom 3 Advanced GCS and flight

control software is provided in the DJI Phantom 3 Advanced User Manual.

3. Flights Of DJI Phantom 3 Advanced UAS Will Be Conducted Pursuant To Specific Operating

Limitations. In seeking this exemption, the City of St. Louis proposes to commercially operate DJI

Phantom 3 Advanced UAS for the special purpose of conducting aerial video and photography

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

a. 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 Advanced Unmanned Aircraft Systems. Proposed

operations of any other aircraft will require a new petition or a petition to amend this

grant.

b. UAS operations under this exemption will be limited to conducting operations for the

purpose of aerial video and photography.
c. The UA may not be flown at an indicated airspeed exceeding 20 knots.  City of Saint

Louis, UAV Petition for Exemption

d. The UA must be operated at an altitude of no more than 200 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.

e. 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.

f. The use of first person view camera to satisfy the visual line of site by the PIC or safety

observer (SO) is not permitted.

g. 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.

h. 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.

i. 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.

j. 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.

k. 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.

l. 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.
m. The operator must follow the UAS manufacturer's aircraft/component, maintenance,

overhaul, replacement, inspection, and life limit requirements.

n. 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.

o. Each UASs operated under this exemption must comply with all manufacturer Safety

Bulletins.

p. The authorized person must make an entry in the aircraft record of the corrective action

taken against discrepancies discovered between inspections.

q. The PIC must meet or exceed all requirements as set forth by manufacturer in order to

justifiably operate the DJI Phantom 3 Advanced or hold an equivalent pilot license

approved by the FAA.

r. 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.

s. 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.

t. 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.

u. 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.

v. 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.

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

accordance with the operating documents.

x. 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.

y. 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.
z. The UA must remain clear and yield the right of way to all manned aviation operations

and activities at all times.

aa. The UAS may not be operated by the PIC from any moving device or vehicle.

bb. All operations shall be conducted over publicly owned or controlled property. Any

operation over privately owned property would require 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.

cc. After receiving a grant of exemption, operations outside of these parameters will

require a separate COA specific to the airspace required for their operation.

dd. 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

The City of Saint Louis affirms all information listed above to be true and binding upon the FAA’s findings

of exemption regarding commercial operations of listed UAS, until further notice of laws or regulations

decided by the government/FAA . Thank you for your consideration.

Donald Roe

Planning and Urban Design Director  

City of St. Louis, Missouri
Appendix
Addendu

UAS Deta

Aircraft

m

ails

Weight

1280 g

Diagona

590 mm

Max As

5 m/s

Max De

3 m/s

(Including Ba

al Size (Includ

m

scent Speed

escent Speed

attery And Pr

ding Propelle

ropellers)

rs)
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

Camera Sensor

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

Lens

FOV 94° 20 mm (35 mm format equivalent) f/2.8, focus at ∞ 

ISO Range

100‐3200 (video) 100‐1600 (photo)

Shutter Speed

8s ‐1/8000s

Image Max Size

4000 x 3000

Still Photography Modes

Single Shot

Burst Shooting: 3/5/7 shots

Auto Exposure Bracketing (AEB): 3/5

Bracketed Frames at 0.7EV Bias

Time‐lapse

Video Recording Modes

Phantom 3 Professional

UHD: 4096x2160p 24/25, 3840x2160p 24/25/30

FHD: 1920x1080p 24/25/30/48/50/60

HD: 1280x720p 24/25/30/48/50/60

Phantom 3 Advanced

FHD: 1920x1080p 24/25/30/48/50/60

HD: 1280x720p 24/25/30/48/50/60

Supported SD Card Types

Micro SD

Max capacity: 64 GB. Class 10 or UHS‐1 rating required

Max Bitrate Of Video Storage

60 Mbps

Supported File Formats

FAT32/exFAT

Photo: JPEG, DNG

Video: MP4, MOV (MPEG‐4 AVC/H.264)

Operating Temperature

0°C to 40°C

Gimbal Controllable Range

Pitch ‐90° to +30°
Stabilization

3‐axis (pitch, roll, yaw)

Vision

Positioning

Max Velocity

Less than 8 m/s (when 2 m above ground)

Altitude Range

30 cm‐300 cm

Operating Range

30 cm‐300 cm

Operating Environment

Surface with clear pattern and adequate lighting (Lux > 15)

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

Phantom 3 Advanced

57 W

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

App / Live

View

Mobile App

DJI Pilot

EIRP

100mW

Live View Working Frequency

2.4GHz ISM

Live View Quality

720P @ 30fps (depending on conditions and mobile device)

Latency

220ms (depending on conditions and mobile device)

Required Operating Systems

iOS 8.0 or later

Android 4.1.2 or later

Recommended Devices

iOS: iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air Wi‐Fi + Cellular, iPad mini 2,

iPad mini 2 Wi‐Fi + Cellular, iPad Air 2, iPad Air 2 Wi‐Fi + Cellular, iPad mini 3, and iPad

mini 3 Wi‐Fi + Cellular. This app is optimized for iPhone 5s, iPhone 6, and iPhone 6 Plus

Android: Samsung S5, Note 3, Sony Xperia Z3, Google Nexus 7 II, Google Nexus 9, Mi 3,

Nubia Z7 mini

*Support for additional Android devices available as testing and development continues

  

Phantom 3 Advanced:

Part Number: CP.PT.000160

GTIN: 00784672983280