October 23 , 2015

Attn: U. S. Department of T

ransportation Docket Operations We st Building Ground Floor , Room w12 -140 1200 New Jersey

Av e, SE Wa shington, DC 20590

B r andon Selfors EMBOSS , LL C.

R EQUEST A

N EXEMPTION FROM THE REQUI R EMENTS OF TI TLE 14 OF THE CODE OF FEDERAL REGULA

TI ONS SECTI ONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMER C I AL OPERA TI ON OF DJ I I nspire 1 UNMANNED AI R C RAFT SYSTEMS PURSUANT TO SECTION 3 33 OF THE FA

A MODERNIZA TI ON AND REFORM ACT OF 2012 (PUB LIC LA W 1 12-95)

Brandon Owner / President EMBOSS , LL C 1 0 3 60 72nd Street North Suite 811 Lar g o , Florida 33777

727-768-6115 b randon@embosswebworks.com

1TA BLE OF CONTENTS
Page

GLOSSAR

Y OF ABBREVIA

TI ONS....................................................................................3

SUMMAR

Y.

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

IN TRODUCTION AND INTERESTS OF PETITIONER....................................................4

BACKGROUND....................................................................................................................4

BASI S FOR PETITION.........................................................................................................5

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

THE SPECI FI C SECTIONS OF 14 C.F .R. FROM WHI CH EMBOSS , LLC SEEKS EXEMPTION

... ... ... ... ...... .........................................................7

THE EXTENT OF RELIEF EMBOSS , LL C SEEKS AND THE R EASON EMBOSS SEEKS THE RELIEF..........................................................................10

THE REASONS WHY GR ANTING EMBOSS , LLC’S REQUEST WOUL D BE IN THE PUBLIC INTEREST .........................................................................12

THE REASONS WHY

GRAN TI

NG THE EXEMPTI ON TO EMBOSS , LLC WOULD NOT A DVERSEL Y A

FFECT SAFETY

.... .......................... ........14

SUMMAR

Y THA T CAN BE PUBLISHED IN THE FEDERAL REGI STER.....................25

ANY A DDIT IONA L IN FORMA TI ON, VI EWS, OR ARGUMENTS AVA ILABLE TO SUPPO RT EMBOSS , LLC................................... ...............................................25

CONCL USION................................................................................................................... ...25

APPENDI CES.......................................................................................... 26 -27

2GLOSSAR Y OF ABBREVIA

TI ONS

AGL Above Ground Level AOI Area of Interest AT C Air T raf fic Control AT O Air T raf fic Organization AV Aerial Ve hicle CFR Code of Federal Regulations COA Certificate of Aut horization FA A Federal Av iation Administration FA R Federal Av iation Regulation GCS Ground Control Station GPS Global Positioning S ys tem LO L L oss of Link NAS National Airspace Sy stem NOT AM Notice to Airman PI C Pilot I n Command Section 333 F AA Modernization and Reform Act of 2012 (FMRA) SO Safet y Observer SOP S tandard Operating Procedures UA Unmanned Aircraft UAS Unmanned Aircraft Sy stem VFR Vi sual Flight Rules VLOS Vi sual L ine of Site VMC Vi sual Meteorological Conditions VTOL Ve rtical T akeof f and L anding

3**SUMMAR Y** 

Emboss , LL C h ereafter refe rred to as Emboss seeks exemption from the requirements of 14 C.F. R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft Sy stem (DJ I Inspire 1 ) pursuant to Section 333 of the F AA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Emboss to operate an Unmanned Aircraft Sy stem (UAS) for the commercial purpose of conducting aerial video and photograph y of construction sites, residential and commercial rea l estate, economic development corporations for cities, civil landscapes and events over certain areas of the United States.

**INTRODUCTION AND INTERESTS OF**  **T HE PETITIONER** 

Emboss has been in b u siness since 2008. Emboss provides their cli ents with exp erti se and knowledge in video and multimedia mark eting, advertising, and public relations using advanced technol ogies and solutions. Emboss has worked on several productions over the past ye ars in all ty pes of locations with a p erfect client and emplo yee safet y recor d. The ob jective of Emboss and our Unmanned Aircraft Sy stem (DJ I I n spire 1 ) aerial operations is to provide an af fordable, h igh -q uality production sy stem for

a variet y of governmental, commercial, public, and residential uses, specifically targeting • Real

- estate marketing • Construction sites before and after • Economic development • Civic landmarks • Golf courses • Special event and sports coverage • Film making

Our staf f has safel y flown small RC electric quadcopters recrea tionally for approxi mately

1 year without incident. **BACKGROUND**

Unmanned Aircraft Sy stems: DJI Inspire 1 , UAS

Emboss seeks an exemption to operate DJ I Inspire 1 system for compensation or hire within the NAS. The DJ I I n spire 1 is vertical takeof f and landing (VT OL) Unman ned Aircraft (UA) with a Ground C o n trol Station (GCS) utilizing electronic tab let or smart phone s ys tems. The DJ I In spire 1 h as a maximum gross weight of approximately 6.5 lbs while having a diagonal dimension of 581 mm , a maximum speed of approximately 2 2 m/s an d a maximum fly ing height of 4500 m . The DJ I I n spir e 1 is equipped with four main roto rs; driven b y Li th iu m Po ly mer battery powered electric motors.4

The DJ I I nspire 1 that wil l be operated b y Emboss will be registered in acco rdance with 49 U.S.C. 44103, Registration of Air cr aft, as well as 14 C.F .R Part 47, Aircraft Registration, an d marked in accordance with 14 C.F. R

. Part 45, I dentif ication and Registr ation Marking.

**BASIS FOR PETITION**

Petit ioner
, Emboss , pursuant to the provisio ns of th e Federal Av iation Regulations (14 C.F .R. § 1 1.61) and the F AA Mo d ernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Un man n ed Aircraft Sy stems, hereby petitions the Ad ministrator to commer cially op er ate the DJ I Inspire 1 , UAS in th e National Airspace S ys tem (NAS), and for an exemp tion f ro m th e requiremen ts of 14 C.F. R §§ 61.1 13(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).

I n consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its o p eration, Emboss o peration of DJ I Inspire 1 UAS meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F. R

. Pa r t 2 1 , Sub p art H.

Ac cordingly
, Emboss requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a )(1) & ( a)(2), and 9 1.417(a) & (b), as these sections set forth requirements for maintenance that only appl y to aircraft with an airworthiness certificate.

Emboss submits that the requested relief is proper since an equivalent level of safety will b e ensured. Emboss will use experienced perso n nel or technicians to perfor m maintenan ce, alterations, or preventive maintenance on the UAS using the methods, tec hniques, and practices prescribed in the operating d o cuments (i.e., Monthly Maintenance Lo g, and DJI Inspire 1 Instruction Manual). Fur th ermore, Emboss will document and maintain all maintenance records for th e DJ I Inspire 1 UAS.

R elief from certain requi rements of Section 61.1 13(a) and (b), entitled Private pilot privileges and lim itations: Pilot in command, is requested b y Emboss to the extent necessary to allow a Pilot in C o mmand (PI C) holding a private pilot or higher level certificate, as well as an a irman medical certificate, and who has demonstrated, by meeting minimum flight hour and currency requirements, that the PI C is able to safely operate the DJ I P h antom UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people,

v essels, vehicles and structures.

Emboss seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the DJI In spir e 1 UAS d o n o t require an airworthiness certificate in accordance w ith 14 C.F .R. Part 21, Subpart H. As such, Embo ss Photography /V ideo submits that they will ensure that the DJI Inspire 1 UAS is in an airworth y condition, prio r to every flight, b y determining that the UAS are in compliance with the

o perating documents ( i. e., Monthly Maintenance Log, and DJI In spire 1 Instru ction Manual), and that th e aircraft are in a condition for safe flight.

5Emboss also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings,

as the DJ I I n spire 1 UAS will not have a ty pical barometric altimeter onboard. However, altitude information of the DJ I I nspire 1 UAS will be provided to the PI C via Global Positioning Sy stem (GPS) equipment and radio communications telemetry d ata link, which downlinks from t he UA to the GCS for active monitoring of the flight path. This altitude information, com bined with Emboss'

o peration of the DJ I Inspire 1 UAS within visual line of sight, at or below 400 feet AGL, will ensure a level of safet y equivalent to Sectio n 91.12 1.

Add itionally
, Emboss seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for f

light in VFR c onditions. Emboss submits that safety will not be af fected b y operation of the DJ I Inspire 1 UAS during day light hours in visual meteorolog ical conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration of approximately 23 minutes. Battery p ower indicators are also able to show exactly how much battery power is left, as well as how much time is needed to return safel y back to point of tak e of f.

I n accordance with 14 C.F .R. § 11

. 8 1, Emboss p r o v ides the following information in support of its petition for exemption:

**A. Name And Addr**  **ess Of The Petitioner** 

**.**
The name and address of th e Petitioner and point of contact is:

B r andon Selfors Owner / President Emboss , LL C 10360 72nd Street North Suite 811 Largo, Florida 33777

727-768-6115
brandon@embosswebworks.com

6**B**

**. T**  **he Specific Sections Of 14 C.F**  **.R. Fro**  **m Which** Emboss **, LLC Seeks Exempti**  **on.**

**1.** E mboss **Seeks Exemption Fr om**  **The Requir ements Of**  **Section 61.1 13(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) N o person who holds a private pilot certificate may act as a pilot in command (PI C) of an aircraft that is carry ing 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 employ

ment if

— (1) The flight is only incidental to that business or employment; and
(2) The ai rcraft does not carry passengers or propert y for compensation or hire.

**2.** E mboss **Seeks Exemption Fr om**  **The Requir ement**  **s Of Section 9 1** 

**. 7**  **(a).**
Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following:
(a) No person m ay

operate a civil aircraft unless it is in an airworthy condition.

**3.** E mboss **Seeks Exemption Fr om**  **The Requir ements 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, b y reference to an altimeter that is set, when operating

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

-- (i) The cur

rent 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 repo rted altimeter setting of an appropriate available station; or
(iii) I n the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure.

7**4.** E mboss **Seeks Exemption Fr om**  **The Requir ements**  **Of Section 91.1 51**  **(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 r otor cr aft under VFR conditions unless (considering wind and for

ecast weather conditions) ther e 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.** E mboss **Seeks Exemption Fr om**  **The Requir ement**  **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 airc raft 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.** E mboss **Seeks Exemption Fr om**  **The Requir**  **ements 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 an y aircraft th at 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.** E mboss **Seeks Exemption Fr om**  **The Requir ements**  **Of Sections 91.4 09**  **(a)(1) And 9**  **1. 40**  **9( a)**  **(2 ).** 
Section 91.409, entitled I nspections, subsection (a), states the following:
(a) Except as provided in paragraph (c) of t his section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

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

a pproved for return to service b y a person authorized b y § 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**8.** E m bo ss **Seeks Exemption Fr om**  **The Requir ements**  **Of Sections 9**  **1**

**. 4**  **17(a) And**  **91.417(b).**

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

(a) Except for work per formed in accordance with §§ 91.41 1 and 9 1.413, each registered own er 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
t he 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 b y the inspection program under which the aircraft and its appliances are maintained.
(v) The current st atus of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safet y directive number and revision date. If the AD or safety direc tive 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 altera tion to the airframe and currentl y installed engines, rotors, propellers, and appliances.

9(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 b y other work or for 1 ye ar after the work is performed.
(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred w ith the aircraft at the time the aircraft is sold.
(3) A list of defects furnished to a registered owner or operator under § 43.1 1 of this chapter shall be retained until the defects are repaired and the aircraft is approved for re turn to service.

**C. The Extent**  **Of Relief** Emboss **Seeks And**  **T he Reason**  Emboss **Seeks The Relief.** 

**1. Extent**  **Of Relief** Emboss **Seeks And**  **T he**  **Reason** Emboss **Seeks Relief Fr om**  **Section 61.113(a) And (b).** 

Relief from Section 61.1 13(a) and (b) entitled Private pilot privileges and limitations: Pilot in command, is requested to the extent necessary to allow a PI C holding a private pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met certain flight

hour and curren cy

requirements, to conduct the proposed UAS flight operations for compensation or hire.
This relief is requested since the limitations set forth in Section 61.1 13(a) and (b) state that a private pilot may , for compensation or hire, act as PI C of an aircr aft in connection with any business or employ ment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry

passengers or propert y for compensation or hire.

As set forth more full y below
, Emboss submits that an equivalent level of safet y will be maintained b ecause no PIC will be allowed to operate the DJ I Inspire 1 UAS unless that PI C has met certain f light -h our and currency requirements, demonstrating that the PIC is able to safely operate either the DJI Inspire 1 UAS in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures.

Fu rther
, Emboss su b mits that all flights of the DJ I Inspire 1 UAS, conducted by the PI C p ur suant to the g r ant of this Petition: (1) will be incidental to Emb o ss' b usin ess; and (2) will not carry p assengers or p r opert y for compensatio n or hire.

10**2. Extent**  **Of Relie f**  Emboss **Seeks And**  **The Rea son**  Emboss **Seeks Relief Fr om**  **Section 91.7(a).**

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent required to allow The Emboss to determine that the DJ I I n sp ire 1 UAS are in airworthy con dition pr ior to every flight b y ensuring that the UAS is in compliance with the operating documents Month ly Maintenance Lo g, and DJ I Inspire 1 I nstruction Manual).

Emboss seeks the requested relief because the DJ I Insp ire 1 UAS do not require an airworthi ness certificate in accordance with 14 C.F .R. Part 21, Subpart H. Therefore, Emboss will ensure that the DJI Inspire 1 UAS are in airwor th y condition based upon its compliance with the operating d ocuments (i.e., Monthly Maintenance Log, and DJI Inspire 1 ) pr ior to every flight, and f

u r ther
, d etermine that the aircraft are in condition for saf e flight, as stated in the co n ditions and limitations below

. **3. Extent**  **Of Relief** Emboss **Seeks And**  **T he**  **Reason** Emboss **Seeks Relief Fr om**  **Section 91.121.**

R elief from Sec tion 91.121, entitled Altimeter settings, may be r equ ired to allow flight operations of th e DJ I Inspire 1 UAS, which utilize a barometric p ressure sensor , GPS equipment, and a radio communications telemetry d ata link to downlink altitude information from t h e UA to the PIC at the ground control station (GCS). Since the FA A requires that any altitude info r mation concerning UAS

o perations be repor ted

to air traffic control (A TC) in feet above ground level (AGL), Emboss seeks th e r equested relief b ecause the DJ I In sp ir e 1 UA ’ s altimeter may b e set on the gro und to zer o f eet AGL, rather than the local baro metric 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 co mp ly with the applicable conditions and limitations stated below. As more fully set for th h erein
, an equivalent level of safet y will be maintained since the DJI Inspire 1 UAS are equipped with a barometric pressure sensor and GPS equip ment, which au tomatically ensu res that a g r o u n d lev el pressure setting will be established prior to each flight, and provides th e PI C with altitude information of the UA on the heads-u p d isplay of the GCS.

**4. Extent**  **Of Relief** Emboss **Seeks And**  **T he**  **Rea son**  Emboss **Seeks Relief Fr om**  **Section 91.151(b).**

R elief f r o m Sectio n 91.151(b) entitled Fuel requirements for flight in VFR condit ion s, is r equ ested to the extent required to allow flights of th e battery p o wered DJ I Inspire 1 UAS during day light hours in

v isu al meteorological conditions (VMC), under v isual flight rules (VFR), for a total duration of 23 minutes. Emboss seeks th e r eq u ested relief because without an exemption from Section 91.151(b ), the flight time duration of the b attery powered DJ I I n spire 1 UA S will severely constrain the practicality of any aerial video or still photo flight operations that Emboss proposes to conduct pursuant to this Petition.11

S ignificantly , as set forth below, the technical specifications o f the DJI In spir e 1 UAS, the DJI I nspire 1 operating documents, an d Emboss' proposed operating limitations,

e nsure that Emboss will safely o perate the battery po wered DJ I I n spire 1 U AS during day light hours in visual me teorological conditions ( VMC ), under visu al flight rules ( VFR), with enough b attery p ower to fly for a total duration of 23 minutes.

**5. Extent**  **Of Relief** Emboss **Se eks**  **And T**  **he Reason**  Emboss **Seeks Relief Fr om**  **Sections 91.405(a), 91.407(a)(1), 91.**  **409(a)(1) & (a)(2), And 91.417(a) & (b)** 

. Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only appl y to aircraft with an airworthiness certificate, Emboss requests relief from these Sections because the DJI Inspire 1 UAS do not require airworthiness certificates. As set forth more fully below , the DJ I Inspire 1 UAS meet the conditions of FMRA Section 333 for operation without an airworthiness c ertificate. Accordingly

, Emboss will use trained technicians to perform maintena nce, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS operating documents (M o n thly Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, Emboss will document and maintain al l maintenance records for the DJ I Inspire 1 UAS.

**D. The Reasons Why Granting**  Emboss **Request W ould Be In**  **The Public Interest; That Is, How It**  **Wo uld Benefit**  **The Public As**  **A Whole.** 
Granting the present Petition will further the public interest b y allowing Emboss to safely
, ef ficiently
, and economically perform aerial video and photography of construction sites, real estate, events and civic landscape over certain areas of the United States.
Additionally, use of the DJI Inspire 1 UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the econom y. Notably , the benefits of Emboss' proposed operation of the DJ I Inspire 1 UAS will be realized without implicating an y privacy issues.

**1. The Public Will Benefit Fr om**  **Decr ease**  **d Congestion Of The NAS.** 

The DJ I I n spire 1 UAS are battery powered and serve as a safe, eff icient, and economical alternative to the manned aircraft traditionally u tilized to obtain aerial imagery . By reducing the amount of manned aircraft needed to perfo r m aerial acquisitions, an exemption allowing the use of a DJI Inspire 1 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air p ollution, as well as increase the safet y o f life and propert y in the air and on the ground.

12F urthermore, b y reducing the number of manned aircraft operating in the NAS, congestion

around airports caused by arriving and departing aircraft will be reduced. The DJ I In spire 1 UAS do not require an airport to take of f or land. L ikewise, a reduction of manned aircraft conducting aerial video and photograph y missions would result in fewer aircraft that must be h andled b y air traf

fic control during the ground, takeoff
, departure, arrival, and la nding phases

o f f ligh t operations.

**2. The Public Will B**  **enefit Fr om**  **The Safety And Efficiency Of**  **The DJI** Inspire 1 **UAS.**
Conducting aerial acquisitions with the DJ I Inspire 1 UAS, instead of manned aircraft, will gr eatly b enefit the public b y d r astically reducing the levels of air and noise pollution generated during traditional aerial video and still photog raphy flight operations. By usin g battery power and electric motors, the DJI Inspire 1 UAS produce no air pollution, and is the most viable environmentall y
con scious alternative to the cabin class, six cy linder internal combustion engine aircraft that are ty picall y utilized for aerial video and photograph y, while burning approximately 20-30 gallons per hour of leaded aviation fuel. The DJ I Inspire 1 UAS, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAS are propelled by battery powered electric motors, rather than an internal combustion engine.

B y using the DJI I nspire 1 UAS to perform aer ial acquisitions, the substan tial risk to life and property in the air and on the ground, which is usually associated with traditio n al manned aircraft flight

o p erations, will be substan tially red u ced or completely eliminated. Aside f ro m the lack of flight crew members located onboard the aircr aft, the DJ I Inspire 1 UAS ( weig hing approximately 6

. 5 pounds at their maximum gross weight with diagonal dimension of 581 mm , and with no fuel on board), has l ess p h y sical potential fo r

collateral damage to life and propert y on the gr ound, and in the air
, compared to th e manned aircraft that ty pically co nduct similar operatio ns (weighing approximately 6 , 0 00 pounds with a wingspan of

approximately 42 feet, a leng th of 34 feet, an d a fuel capacity of 180 gallons).

**3. Performing**  **Aerial Vi**  **deo and Photography Operations Wi**  **th The DJI**  Inspire 1 **UAS Will Benefit**  **The Economy**

**.**
I n addition to being safe and efficient, the DJ I Inspire 1 UAS are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI I n spire 1 UAS will allow United States based companies, like Emboss Photography/V ideo, to remain competitive and contribute to growth of the U.S. economy . Specifically , with the rising cost of aviation fuel and th e Environmental Protection Agency (“EP A”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative techno logy in

o r d er to remain competitive. Operating the battery p owered DJI In spire 1 UAS is o ne such technology that n o t only allows companies greater operational flexibility compared to manned aircraft, but provides s uch flexibility without the high operational cost of a traditional manned aircraft.

13B y operating the DJI Inspire 1 UAS, companies such as Emboss can remain

competitive and profitable, and therefore, provide greater job stability to employ ees and

c ontractors, which will ultimately contribute to growth of the U.S. economy . I mproved financial performance of U.S. companies, through commercial use of the DJI Inspire 1 UAS, provides a stable workforce that increases consumer spending; impro ves local, state, and federal tax revenues; and allows companies to invest in resea r ch and development in order to remain competitive both in the United States and abroad.

**4. Ther e**  **Are No Privacy Issues.**
Similar to the manned aerial acquisition flight operations that have been conducted for decades, Emb o ss' proposed operati on of the DJ I Inspire 1 UAS will not imp licate any privacy issues. Specifically , the DJI I n spire 1 UAS will be operated only in comp liance with operating documents (M o n thly Maintenance Log, and DJI Inspire 1 Instruction Manual) which requires property o wne r involvement as well as local law enforcement notification, and in accordance with the Federal Av iation Regulations, including the minimum altitude requirements of 14 C.F. R

. § 9 1

. 1 19.

**E. T**  **he Rea**  **sons W**  **hy Granting The Exemption W o**  **uld Not Adversely**  **Affect S afety**  **, Or**  **How The**  **E x**  **emption W ould Pr**  **ovide A**  **L evel Of Safety**  **At Least Equal T**  **o T**  **hat Pr ovided By**  **The Rule Fr**  **om Which**  Emboss **Seeks Exemption.**

**1. Reasons Why The DJI**  Inspire 1 **UAS Meet The Conditions Of The F**  **AA Modernization and**  **Reform Act of 2012 (FMRA) Sect**  **ion 333**

. In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, Emb o ss' operation of the DJI I n spir e 1 UAS meet the conditions of FMRA Section 333, and will not require an airworthi n ess 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 o r the public, or otherwise pose a threat to national security . Specifically

, FMRA Section 333 states the following, in part:
(a ) In General.

-- Notwithstanding any other r equir ement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secr etary of Tr ansportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system befor e completion of the plan and rule

- making re quir ed by section 332 of this Act or the guidance requir ed by section 334 of this Act.

14(b

) Assessment of Unmanned Air craft Systems.

-- In making the determination under subsection (a), the Secr

etary shal l determine, at a minimum

-- (1 ) which types of unmanned air craft systems, if any

, as a r esult of their size, weight, speed, operational capability

, pr oximity to airports and populated ar eas, and operation within visual line of sight do not cr eate a haz ar

d 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 S tates Code, is r

e quir ed for the operation of unmanned air craft systems identified under paragraph (1).
(c) Requir

ements for Safe Operation.

-- If the Secr etary determines under this section that certain unmanned air

craft systems may operate safely in the national airspace syst em, the Secr etary shall establish r

equir ements for the safe operation of such aircraft systems in the national airspace system.
In seeking this exemption, Emboss submits that th e DJ I In spir e 1 UAS can o perate safel y in the NAS p ursuant to FMRA Section 333 , as demo nstrated by : (a) the characteristics of the DJ I Inspire 1 UAS; (b) the pilot certification requirement; and (c) the sp ecific operating limitations.

**a. T**  **he Specifications Of The DJI** Inspire 1 **UAS Demonstrate Its Saf e Characteristics.** 

The DJ I Inspire 1 UAS does not create a hazard to u sers of the NAS or the pu b lic, or other wise pose a th reat to national security considering its size, weigh t, speed, an d o p erational capabilit y

**i . Te**  **chnical Specifications Of The DJI**  Inspire 1 **UAS.**

Th e technical spe cifications of th e DJ I Inspire 1 UAS are set forth by the DJI Inspire 1 User Manual, attached hereto as Appendix A.

**ii. The DJI**  Inspire 1 **UAS Global Positioning Modes Enable The UAS**  **To Rem**  **ain Within A**  **Defined Operational Ar**  **ea.**

The DJ I Inspire 1 UAS may be operated in both manual and global positioning flight modes. A complete description of the flight and navigational modes of the DJI I n spir e 1 UAS is provided at p ag es 1 1 of the DJ I I n sp ir e 1 User Man u al attach ed h ereto as Appendix A.

**iii. The DJI**  Inspire 1 **UAS Are Designed Fo**  **r Automatic Return T**  **o Home Point Or Hover**  **In The Event Of Loss Of**  **The Contr ol Link Or**  **Navigation.**

When the Control Link is lost, the DJI Inspire 1 UAS will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Inspire 1 UAS does not reacquire control lin k data from th e GCS, the UAS will assume that the Control L ink is lost an d the will r eturn to the h o me position (i. e. , failsafe mode) via GPS, and will descend to the takeof f po sitio n and shutdow n.

15A complete description of the Failsafe Functions of the DJ I In spire 1 UAS are set forth at pages 12

through 14 of the DJ I I n sp ir e 1 User Manual, attached hereto as App en dix A.

**iv**

**. T**  **he DJI** Inspire 1 **GCS And Its Operation.** 

A co mplete description of th e operation and specifications of the DJ I I nspire 1 GCS and flight control

so f tware is provided at pages 23 through 29 of the DJI I n spire 1 User Manual. DJ I I n spire 1 User Manual is attached hereto as Ap pendix A.

**b. Flight Operatio**  **ns Of DJI** Inspire 1 **U AS Is**  **L imited T**  **o The Line Of Sight Of A**  **Certificated Pilo**  **t in Command With A**  **Saf ety Observer** 

**.** Emboss v id eo p r o d

u ctio n staf

f will be the onl y persons to act as a pilot in command (PIC ) of the
DJ I Inspire 1 UAS. Additionally , a saf et y observer will assist h im at all times during flight time.

**c. Flig**  **hts Of DJI** Inspire 1 **UAS Will Be Conducted Pursuant T o Specific Opera**  **t ing**  **L imitations.**  In seeking this exemption, Emboss proposes to commercially op erate DJ I In spir e 1 UAS fo r the special purpose of conducting aerial video and photograp h y o v er 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, ro tor craft UAS weighing less than 55 pounds maximum gross weight: DJI I n sp ir e 1 Unmanned Aircraft Sy stems. Proposed operations of an y other aircraft will req uir e a
n ew petition or a petition to amend this grant.
2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photography

. 3. The UAS may not be flown at an indicated airspeed exceeding 20 knots.

4. The UA

must be operated at an altitude of no more than 400 feet above ground level (AGL), as indicated b y the procedures specified in the operating documents unless a special request is made and approved b y AT C. All altitudes reported to AT C must be in feet AGL.
5. The UAS must be operated within visual line of sight (VLOS) of the PI C at all time s. This requires the PI C to be able to use human vision unaided by any device other than corrective lenses, as specified on the PI C’ s F

AA -issued airman medical certificate.
6. The use of first person view (FPV) b y the PI C or safet y observer (SO) is not pe rmitted.

167. All operations must utilize a safet y observer (SO). The SO may be used to satisfy the VLOS

requirement as long as the PI C alway s maintains VLOS capability . The SO and PI C 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 PI C must ensure that the SO can perform the functions prescribed in the operating documents.
8. The SO must not perform any other duties beyond assisting the PI C 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 proced ures 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

u pdate or revise its operating documents. I t 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 f or extension or amendment to the grant of exemption. If the operator determines that any update or revision would af fect the basis upon which the F

AA granted the exemption, then the operator must petition for amendment to its grant of exemption. The F

AA ’s UAS I ntegration Of

fice (AFS

- 80) may

be contacted if questions arise regarding updates or revisions to the operating documents.
10. Prior to each flight the PI C must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection rev eals a condition that af fects 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 properl y documented in the aircraft records.

11

. An y UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a fli ght critical component, must undergo a functional test flight. The PI C who conducts the functional test flight must make an entry in the aircraft records.
12. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable componen ts, items, or equipment, not alread y 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 recor ds, including total time in service, description of work accomplished, and the signature of the authorized person returning the UAS to service.

1715. Each UAS operated under this exemption must comply with all manufacturer Safet y Bulletins.

16. The a uthorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections.

17. The PI C must possess at least a private pilot certificate and at least a current third class medical certif icate.
18. The operator may not permit any PIC to operate unless the PIC meets the operator ’s qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption, inclu ding evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PI C 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 PI Cs are permitted under the terms of the exemption. However , training operations may

onl y be conducted during dedicated training sessions. During training, proficiency , and experience

- building flights, all persons not essential for flight o perations are considered nonparticipants, and the PI C must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F .R. § 91.1 19.
19. UAS operations may

not be conducted during night, as defined in 14 C.F .R. § 1.1. All operat ions must be conducted under visual meteorological conditions (VMC). I f flight at night is required, a special request will be made at the F AA of fice 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 F AA

- published aeronautical chart unless a letter of agreement with that airport’ s management is obtained, and the operation is conducted in accorda nce with a NOT AM 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 PI C.

22. If the UA

loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in accordance with the operating documents.

23. The PI C must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents.

24. The PI C is prohibited from beginning a flight unless (considering wind and forecast weather

c onditions) there is enough power to fl y at normal cruising speed to the intended landing point and land the UA with 25% battery power remaining.

1825. The operator must obtain an Air T raf fic Organization (A

TO) issued Certificate of W aiver or Authoriz ation (COA) prior to conducting an y operations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (NOT AM) 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 AT O 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 n umber
, registered in accordance with 14 C.F .R. part 47, and have identification (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 an y time the UAS is operating. These documents must be made available to the Administrator or an y l aw enforcement official upon request.

29. The UA

must remain clear and y ield the right of way to all manned aviatio n operations and activities at all times.
30. The UAS may not be operated b y 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 PI C, SO, operator trainees or essential persons), vessels, vehicles, and structures unless:
a. Barriers or structures are present that suf ficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonpart icipating persons remain under such protection. I f 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, vehicl es or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PI C has made a safet y assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, an d;
c. Operations nearer to the PI C, SO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.1 19(a).

1932. 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. An y incident, accident, or flight operation that transgresses the latera l or vertical boundaries of the operational area as defined by the applicable COA

must be reported to the F AA's UAS Integration Of fice (AFS- 80) within 24 hours. Accidents must be reported to the National Tr ansportation Safet y Board (NTSB) per instructions contained on the NTSB W eb site: www .ntsb.gov

. **2. Reasons Why An Exemption Fr**  **om The Requir**  **ements Of Section 61.1 13(a)**  **And (b) Wo**  **uld Not Adversely**  **Affect Safety**

**.**
Emboss submits that the equivalent level of safet y establ ished by Section 61.1 13(a) and (b) will be maintained because no PIC will be allowed to operate the DJ I I nspire 1 UAS unless that PI C has d emonstrated, b y meeting minimum flight -h our and currency requirements, that the PI C is able to safel y operate the DJ I Inspire 1 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, veh icles and structures.

C onsidering Emboss' proposed area of operations, and the operating lim itations set f o rth -a b o v e; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11 062); and the air manship skills necessary to safel y operate the DJI I nspire 1 UAS, Emboss su b mits that the additional manned airmanship experience of a

co mmercially certificated pilot would not correlate to the airmanship skills necessary f o r Emboss' sp ecific proposed flight operations.

The F AA has previously

granted relief from Section 61.1 13(a ) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11 063, 11064, 11065, 1 1066, 1 1067, 11080, 1 11 09, 1 111 0, 1 111 2, 1 11 36, 1 11 38, 1 11 50, 1 11 53, 1 11 56, 111 58, 1 11 59, 1 11 60, 1 11 6 1).

Emboss will not allow any PI C to operate the DJI Inspire 1 UAS unless that PI C has demonstrated, by meeting minimum flight -h our requirements or the DJI Inspire 1 UAS training and currency requirements, that the PIC is able to safel y operate the DJ I Inspire 1 UAS in a manner consistent with this exemption, including evasive and emerg ency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.
Specifically

, the PIC must have accumulated and logged, in a manner cons istent with 14 C.F .R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). I n addition to the hour req uirements, the PI C must accomplish 3 takeof fs and landings in the preceding 90 day s (for currency purposes).

20As in Exemption Nos. 1 1062, 1 11 38, and 1 11 53, prior documented flight experience that was

o b tain ed in compliance with applicable regulat ions will en sur e an equ ivalent level of safet y durin g Emboss' p r oposed operations. Th e Administrator has held that prior documen ted flight ex p erience that

was o btained in compliance with ap p licab le regulations would ensure safe operations, stating as foll o ws: In Exemption No. 1 1062, the F AA required that prior to conducting operations for the purpose of motion picture filming (or similar operations), the PI C must have accumulated and logged, in a manner consistent with 1 4 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi

- rotor UAS. Prior to operations under Exemption No. 1 1062, the PI C must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption. For clarification, the F AA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi

- rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PI C must accomp lish 3 takeof fs and landings in the preceding 90 day s (for currency purposes). The F

AA finds that at a minimum, the flight

- hour requirements in Exemption No. 1 1062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the petitioner ’s proposed operations. The FA A also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Tr ainin g, proficiency , and experience -building flights can also be conducted under the grant of exemption to accomplish the required flight time. During training, proficiency , and experience- building flights the PI C is required to operate the UA

with appropriate distances in accordance with 14 C.F .R 91.1 19.
Exemption No. 1 11 38 at page 15.
Accordingly, Emboss will ensure safe operations by n o t allowing any PIC to operate the DJ I Inspire 1 UAS unless that PI C has demonstrated, by meeting minimum flight-h our and currency requirements, that the PI C is able to safely operate the DJ I Inspire 1 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from p eople, vessels, vehicles and structures.
**3. Reasons Why An Exemption Fr**  **om The Requir**  **ements Of Section 91.7(a) Wo**  **uld Not Adversely**  **Affect Safety**

**.** The equivalent level of safet y established b y Section 91.7(a) will be maintained because prior to every f light, Emboss will ensure that the DJ I I nspire 1 UAS is in an airworth y condition based upon the UAS’ s compliance with its operating documents and as stated in the conditions and limitations herein.
Additionally

, the F AA has previously

granted relief from Section 91 .7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11 063, 11064, 11065, 1 1066, 1 1067, 11080, 1 11 09, 1 111 0, 1 111 2, 1 11 36, 1 11 38, 1 11 50, 1 11 53, 1 11 56, 111 57, 1 11 58, 1 11 59, 1 11 60, 1 11 61).

21**4. Reasons Why An Exemption Fr**  **om The Requir**  **ements Of Section 91.121 Wo**  **uld Not Adversely** 

**Affect Safety**

**.** The eq u iv alen t lev el of safet y established b y Section 91.121 will be maintained because the altitude in formation of the DJ I I n sp ir e 1 U AS will be provided to the PI C via GPS equipment and a radio

co mmu n ications telemetry d ata link, which downlinks from the UA to th e GC S for active monitoring of the flight path and altitude. Th is altitude info r mation, combined with Emboss' op eration of th e DJ I Inspire 1 UAS within visual line of sight, at or below 5 0 0 feet AGL, will ensure a level of safety equivalent to Sectio n 91.121. The altitu d e information will b e generated b y GPS equipment installed

o nboard the air craft. Prior to each flight, a zer o altitude initiation point is automatically established by the UAS at ground lev el.

The F AA 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 No s. 1 1062, 11063, 11064, 1 1065, 11 066, 11067, 11080, 1 11 09, 1 111 2, 1 11 36, 1 11 38, 1 11 50, 1 11 53, 1 11 56, 1 11 57, 1 11 58, 1 11 59, 1 11 60, 111 61).
**5. Reasons Why An Exemption Fr**  **om The Requir**  **ements Of Section 91.151(b) Wo**  **uld Not Adversely**  **Affect Safety**

**.**
A grant of this exemption would ensure an equivalent level of safety established by 14 C.F .R. Section 9 1

. 1 5 1( b) as a result of (1) the technical specifications of the DJI Inspire 1 UAS; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accord ingly
, Emboss will ensure that it will safely operate the battery powered DJ I Inspire 1 UAS during day light hours in VFR conditions, with enough battery power to fl y for a total duration of 23 minutes.
Here, as in Exemp tion No. 1 11 09, the technical specifications of the DJ I Inspire 1 UAS; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safety established by 1 4 C.F .R. Section 91.151(b). Furt h ermore, safet y will be ensured as the DJ I Inspire 1 UAS provide audible and visual warnings to the PI C at the GCS when the UAS experiences low battery v o ltage, the first warning occurring at approximately 33 % remaining battery power , and again at approx i mately 1 5 % remaining battery power

. At the critically low battery level, the DJ I Inspire 1 UAS will descend and land automatically

. Significantly

, previous exemptions granted by the F AA concerning Section 91.151 establish that safety is not adversel y affe cted 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. More over , the F AA 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, 1 1063, 11 064, 11065, 11066, 1 1067, 1 1080, 111 09, 1 111 0, 1 11 36, 1 11 38, 1 11 50, 1 11 53, 1 11 56, 1 11 57, 1 11 58, 111 59, 1 11 60, 1 11 61).

22**6. Reasons Why An Exemption Fr**  **om The Requir**  **ements Of Sections 91.405(a), 91.407(a)(1),**

**91.409(a)(1) & (a)(2), And 91.417(a) & (b)**  **Wo uld Not**  **Adversely Affect Safe**  **ty**

**.** In seeking this exemption, Emboss 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 9 1.417(a) & (b) will be met b ecause Emboss 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 (Monthly Maintenance Lo g, and DJI Inspire 1 I nstruction Manu al). Furthermore, Emboss will document and maintain all maintenance

r ecords for the DJ I Inspire 1 UAS.

Since the DJ I I n spire 1 UAS will be inspected as prescribed b y the operating documents, Emboss will maintain the equivalent level of safet y establ ished by Sections 91.405(a), 91.409(a)(1), and 9 1.409(a)(2). A cop y of the DJ I Inspire 1 User Manuals are attached hereto as Appendix A ; a copy of the DJ I I n spire 1 UAS Maintenance LOG is attached hereto as Appendix B.
Likewise, the exemption sought will not adversel y affect safety because Emboss will use trained technicians to perform mainten ance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed b y t he operating d ocuments.
Furthermore, the exemption sought would maintain an equivalent level of safety established b y Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI Inspire 1 UAS will be p erformed b y

t rained technicians. Maintenance will be documented and maintained u tilizin g the monthly maintenance log.
Significantly

, previous exemptions granted by the F AA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safet y is not adversely af fected when the technical characteristics and operating limitations of the UAS are considered.

I n consideration of Emboss' proposed operating limitations, the operating documents, and the technical aspects of the DJ I Inspire 1 UAS, Emboss su b mits that safet y will not be adversel y affected b y gr anting exemption from 1 4 C.F .R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 9 1

. 417(a) and (b). The F AA h as prev iously g ranted relief sp ecific to UAS in circumstances similar , in all material respects, to those presented herein (e.g. Exem ptio n Nos. 1 1062, 11063, 11064, 11065, 1 1 066, 11067, 11080, 11 1 09, 11 1 1 0, 11 1 1 2, 11 1 36, 1 11 38, 11 1 50, 11 1 53, 11 1 56, 11 1 57, 11 1 58, 1 1 1 5 9, 1 11 60, 11 1 6 1).

23**7. The F**

**AA May Pr**  **escribe Any Other**  **Conditions For**

**Safe Operation.**

I n accordance with Sec tion 333 of th e F AA Modernization and Reform Act of 2012 (FMRA) and 14 C.F .R. § 21.16 en titled Special C o nditions, Emboss r equests that the F AA p r escribe special conditions for the intended operation of the DJ I Inspire 1 UAS, which contain such safet y stan dards th at th e Ad ministrator finds necessary to establish a level of safet y eq u ivalent to that estab lished b y 1 4 C.F .R. Part 21, Subpart H, and 14 C.F .R §§ 61.1 13( a) & (b), 91.7 (a), 91.121, 91.151(b), 9 1

. 4 0 5 (a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91 .417(a) & (b). Such special conditions will permit safe o peration of the UAS for the limited purpose of con du cting aerial v ideo and photography

o v er certain areas of th e United States for compensation or hire. FMR A Section 333 sets forth the requirements fo r considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a t hreat to national security; and f u r ther , provides the authority f or such UAS to operate without airworthine ss certificatio n in accordance with an y req uirements that must be established for the safe operation of the UAS in the NAS.
Likewise, the Ad min istr ato r may p rescribe special conditions pursuant to 14 C.F .R. § 21 .1 6, f or
o peration of the DJ I Inspire 1 UAS, sin ce the airworthiness regulations of 14 C

. F .R

. Part 21 do not

co n tain ad equate or

ap pr op r iate safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special C onditions, states the follo win g:

If the F AA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safet y 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 1 1 of this chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FA A finds necessary to establish a level of safet y 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 FA A may prescribe sp ecial conditions for Emboss intended operation of the DJ I I n spir e 1 UAS, which contain such safety standards that the Ad ministrator finds n ecessary to estab lish a level of safety equiv alent to that established by 1 4 C .F

. R

. Par t 2 1 , Subpart H, and 14 C.F .R Sections 61.1 13(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).

24**• A**  **Summary T**  **hat Can Be Published In T**  **he Federal Register , stating:**  **The Rules Fr om** 

**Which** E m boss **Seeks Exemption:**

Emboss seeks exemption fr om the r equir ements of 14 C.F .R Section s 61.1 13(a)&(b), 91.7(a), 91.121, 9 1.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & ( a ) (2), and 9 1 .417(a) & (

b )

.
**A Brief Description Of**  **The Natur e Of**  **The Exemption** Emboss **Seeks:**
This exemption will permit Emboss to commerc ially operate an Unmanned Air craft System (UAS) for the purpose of conducting aerial video and photography over certain

ar eas of the United States.

**• Any**  **Ad ditional Information,**  **Vi ews,**  **Or A**  **rguments Av** 

**a ilable**  **To Suppo**  **rt** Emboss' **Request.**
This Petition is made pursuant to the F AA Modernization and Reform Act of 2012
(FMRA) Section 333, which directs the Secretary o f Tr ansp ortation to d etermine if certain UAS may

o perate safel y in the NAS. As such, Emboss' r eq u est for exemption may b e granted pur suant to the authority o f FMRA Section 333 and 1 4 C .F .R. Part 1 1, as set for th above.

FMRA Section 333 sets forth the requirements for considering whethe r 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, Emb oss will op e rate the DJ I Inspire 1 UAS safel y in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to n ational secu r ity

.
**CONCLUSION**

As set forth herein, Emboss seeks an exemption pursu ant to 14 C.F.R. § 1 1.61 and Secti on 333 of the FA A Mo d ernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI I n sp ir e 1 UAS commercially , without an airworthiness cer tificate, for th e limited p u r p ose of conducting aerial video and p hotograph y ov er certain are as of the United States. By g ranting this Petition, the F AA A

dministrator will be fulfilling the Congressional man date of the F AA Modernization and Reform Act of 2012, while also advancing the intere sts of the public, b y allowing Emboss to safely
, efficien tly , and economically o p erate the DJ I Inspire 1 UAS commercially within the NAS.

25**W HEREFORE,**  in accordance with the Federal Av iation Regulations and the FA A Modernization and Reform Act of 2012, Section 333, Emboss respectfully requests tha t the Administrator grant this Petition for an exemption from the requirements of 14 C.F. R Sections 61.1 13(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 Emboss to operate the DJ I Phanto m 3 UAS commerciall y for the purpose of conducting aerial video and photograph y over certain areas of the United States.

Dated: October 23 , 2015
Respectfully submitted,

B r andon Selfors Owner/President Emboss , LL C 10360 72nd Street North Suite 811 Largo, Florida 33777 727-768-6115 brandon@embosswebworks.com
Appendices: A

– Link to DJI Inspire 1 Manual: Click on link below

h ttp ://www.dji.com/product/inspire-1/download

DJI Inspire 1 Professional (q u adcopter) C raft Seri al #: Model #: T600 FCC ID: Camera Serial #: R ep eater Serial #:

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