September 2, 2015

Exemption No. 12714 Regulatory Docket No. FAA

− 20 15

− 1766

Mr. Brian Morson 12135 Sand Pebble Way Orlando, FL 32824

Dear Mr. Morson : This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends. By letter s dated May 12 and July 27, 2015 , you petitioned the Federal Aviation Administration (FAA) for an exemption

. You requested to operate an unm anned ai rcraft system (UAS) to conduct aerial video graphy and photography for real estate purposes

. See Appendix A for the petition submitted to the FAA des cribing the proposed operations and the regulations that the petitioner seeks an exemption

. The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner

. Airw orthiness Certification

The UAS proposed by the petitioner is a DJI Phantom 3

.2

The petitioner requested relief from 14 CFR part 21, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates

. In accordance with the statutory criteria provided in Section 333 of P ublic Law 112

− 95 in reference to 49 U

. S

. C

. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the Secre tary of Transportation has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 14 CFR part 21 , C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates , an d any associated noise certification and testing requirements of part 36, is not necessary.
The Basis for Our Decision You have requested to use a UAS for aerial data collection 1

. The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 20 14

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater propo rtions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest. Having reviewed your reasons for requesting an exemption, I find that

—

 They are similar in a ll material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213 ;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to the situation you present; and

 A grant of exemption is in the public interest.

Our Decision In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by th e Administrator, Mr. Brian Morson is granted an exemption from 14 CFR §§ 61.23(a) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a) , 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (part iculate measurement, etc.), or any other gathering of data by instruments aboard the UA.3

the ex tent necessary to allow the petitioner to operate a UAS to perform aerial data collection

. This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Mr. Brian Morson is hereafter referred to as the operator. Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 3 when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption

. 2. Operations for the purpose of closed

- set motion picture and television filming are not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine
co mpliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA 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 le nses, as specified on the PIC’s FAA

- issued airman medical certificate or U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times ; e lectronic messaging or texting is not permitted during flight operations. The PIC must be de signated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its op erations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the4

Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator mus t 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 or any l aw enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon w hich the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FA A’s UAS Integration Office (AFS− 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. 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 prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other p eople. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Pr ior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g. , inoperable components, items, or equipment. If the ins pection 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.

11. The operator must follow the UA S manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.

13. Under this grant of exemptio n, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Col u mbia, Pu erto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.5

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, ve ssels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (traini ng, proficiency, and experience

- building) an d determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated tr aining sessions. During traini ng, 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 wi th 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbo l as denoted on the current FAA

- published ae ronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request.

17. 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.

18. If the UAS loses communications or loses its GPS s ign al, the UA must return to a pre

- determined location within the pr ivate or controlled

- access property.

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

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organ ization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be cond ucted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA

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22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N− Number) markings in accordance with 14 CFR part 45, Subpa rt C. Markings must be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

24. The UA must remain clear and give way to all manned aviation operations and activities at all times.

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

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:
a. Barriers or structures are present that suffi ciently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protectio n and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons ; and b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard. The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons unde r this exemption.

27. All operations shall be conducted over private or control led

- access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. 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 FA A'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

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If this exemption permits operations for the purpose of closed

- set motion picture and television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the a rea of proposed filming. The 3

- day notificatio n may be waived with the concurrence of the FSDO. The plan of activities must include at least the following:
a. Dates and times for all flights; b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;
c. Name a nd phone number of th e person responsible for the on

- scene operation of the UAS; d. Make, model, and serial or N− Number of UAS to be used;
e. Name and certificate number of UAS PICs involved in the aerial filming; f. A statement that the operator has obtained permi ssion from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request; g. Signature of exemption holder or representative; and h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participa ting persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM. Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applica ble parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.8

This exemption terminates on September 30, 2017 , unless sooner superseded or rescinded. Sincerely, / s/ John S. Duncan Director, Flight Standards Service

EnclosuresBrian Morson 12135 Sand Pebble Way Orlando, FL 32824 Brian.Morson@gmail.com {PH) 407-432-5364 (FAX) 407-286-2719 May 12,2015

Docket Operations, M-30: U.S Department of Transportation (DOT) 1200 New Jersey Ave SE, Rm W12-140 West Building Ground Floor Washington, DC 20590

Subject: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. Part 21, 45.27(a), 45.29 (3) (c) (d) (e) (f) (g) (h), 61.113 (a) & (b), 91.103, 91.119, 91.121, 91.203, 91.151
Following the format of FAA Exemption No. 11138 -Regulatory Docket No. FAA- 2014-048, 11 have included:

1. Supplemental Response for Petition 2. PHANTOM 3 Safety Guidelines, 3. PHANTOM 3, Quick Start Manual vl.O, 4. PHANTOM 3 Professional User Manual 5. Personal protocols and controls- Safety/Flight concerns
Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F .R. Part 11, I, Brian Morson, a for the last 8 years a professional Videographer/Photographer for Real Estate Industry is preparing this exemption request myself, would like to apply for an exemption from the following Code of Federal Regulations (C.F.R) to be allowed commercial operation of lightweight Unmanned Aircraft Systems (sUAS) for aerial imaging and video of Orlando, Sarasota and Tampa Landmarks and homes I list for sale.

I have experience in flying hobby quads-copters for recreational purposes during the past 5 years without incident also I'm a participating member of the AMA (Academy of Model Aeronautics). I have added a hobby grade DJI Phantom 3 quad-copter (maximum gross weight 2.82 pounds, equipped with four rotors that are driven by electric motors powered by batteries, the UAS has a maximum airspeed of 31.10 knots) to my inventory equipped with a Sony EXMOR Yz.3" camera with intent for aerial videography/cinematography to enhance academic community awareness and augment real estate listing videos; following an exemption and approval by the FAA.Morson Petition May 12,2015 Page 2

My exemption request would permit operation of ultra-light weight, unmanned (piloted by remote control) in predetermined areas away from general public, airports, heliports and vehicular traffic, under 400ft. and after carefully reviewing, inspecting and examining the area of aerial observation. This would allow for community videos and within property boundaries for individual homeowner real estate listing videos/photos. I will abide all FAA requirements to ensure this exemption will provide a level of safety at least equal to existing rules and will only operate in a safe environment that is strictly controlled, are away from power lines, elevated lights, airports and actively populated areas; and I will conduct extensive preflight inspections and protocols, during which safety carries primary importance.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203

Given the size, weight, speed, and limited operating area associated with the aircraft to be utilized, I am asking exemption from 14CFRpart21, Subpart H (Airworthiness Certificates) and§91.203 (a) and (b) (Certifications required), subject to certain conditions and limitations, is warranted and meets the requirements for an equivalent level of safety under14CFRpart 11 and Section 333 of P.L. 112-95 (Section 333).

14 C.F.R. 45.27(a): Location of marks; non fixed-wing aircraft. 14 C.F.R. 45.29 (3) (c) (d) (e)(f)(h): Size of Marks

Furthermore I request an exemption from §45.23 Marking of the aircraft because my UAS will not have

a cabin, cockpit or pilot station on which to mark certain words or phrases. Additionally two -inch lettering is difficult to place on such a small aircraft with dimensions smaller than the minimal lettering requirement. I understand the need for markings and will mark my UAS in the largest possible lettering by placing the word "Experimental" or assigned number or name (based on a request or ruling by the FAA ) on its fuselage as required by §45.29(f) so that anyone assisting him as a spotter will see the markings. I also ask for an exemption from §§91.405{a),91.407(a)(1), 91.409(a)(2) and 91.417(a) and(b) Maintenance inspections may be required and should be granted since they only apply to aircraft with

an airworthiness certificate. But, as a safety precaution I will perform a preflight inspection of my UAS before each flight as outlined in his operating documents.

14 CFR 61.113 (a) & (b): Private pilot privileges and limitations: Pilot in command.

Under §61.113 (a) and(b) private pilots are limited to non-commercial operations, however I can achieve

an equivalent level of safety as achieved by current regulations because my UAS does not carry any pilots or passengers. While helpful, a pilots' license will not ensure remote control piloting skills. The risks of operating a UAS are far less than the risk levels inherent in the commercial activities outlined in 14 CFR part61,et seq., I requests an exemption from §61.113 Private Pilot Privileges and Limitations. A side note, I have already explored getting my pilot's license, at the direction of the FAA, I would gladly begin education and eventual licensing. Brian Morson Petition Page 3 Regarding UAS operational training, as stated previously I have Five years' experience flying numerous practice flights in remote' ' Morson Petition May 12,2015 Page 3

areas as a hobbyist simulating flights for future commercial use to gain familiarization with the characteristics of his UAS' performance under different temperature and weather conditions. I also own and practices on a computerized simulated flights software to maintain adequate skills and response reflex time. I'm also aware of a three-day drone training course in Sarasota Florida and would gladly attend if required by the FAA.

14 C.F.R. 91.103 (b) (1}, (b)(2}: Preflight Action.

If granted an exemption I agree to additional safety procedures including, but not limited to: 1) Keeping my USA within a radius distance of 1000 feet from the controller to both aid in direct line of sight visual observation. 2) Operate the UAS for 3-7 minutes per flight; land my UAS according to the manufacturer's recommended minimum level of battery power. 3) Operate my UAS only within visual line of sight (VLOS). 4) Use the UAS' global positioning system and Global Navigation Satellite System and Vison Positioning System (GPS/GLONASS) flight safety feature; it hovers and then slowly lands if communication with the remote control. 5) Conduct all operations under my own personal and flight safety protocols (including posting a warning sign reading: "Attention Aerial Photography in Progress -Remain Back Min 150 feet"). 6) I will operate and will actively analyze flight data and other sources of information to constantly update and enhance my safety protocols. 7) Contact respective airports if operations will be within 5 miles to advise them of his estimated flight time, flight duration, elevation of flight and other pertinent information. 8) Always obtain all necessary permissions prior to operation. 9) Have procedures in place to abort flights in the event of safety breaches or potential danger.

Aerial videography for geographical awareness of real estate marketing has been around for a long time through manned fixed winged aircraft and helicopters, but for small business, its expense has been costprohibitive. Granting this exemption would allow me to provide this service at a much lower cost. Further, my small UAS, when used properly, will pose no threat to the public given its small size and lack of combustible fuel when compared to larger manned aircraft. The operation of his UAS will minimize ecological damage and promote economic growth by providing information to companies looking to relocate or new build in the Orlando, Tampa and Sarasota areas of Florida.

One final comment, the use of UAS has already proven to increase the marketability of a home. For example please review the article published by ABC News Jan 6, 2015 by Susanna Kim via Good Morning America cites "Doug Trudeau". The article cites the FAA's exemption given to Doug Trudeau, for Real EstateMorson Petition May 12,2015 Page 4

# ~~"'----- Brian Morson

EnclosurePage 2 of 35 UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. FAA-2015-1766-0001

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: BRIAN MORSON FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMEN TS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b ), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNI NG COMMERCIAL OPERATION OF BLADE 350QX AP AND DJ UNMANNED AIRCRAF T SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

ADDEDUM: 1 Submitted on July 27, 2015

BRIAN MORSON 12135 Sand Pebble Way Orlando, FL 32824Page 3 of 35 TABLE OF CONTENTS Page

GLOSSARY OF ABBREVIATIONS. ........................

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

BASIS FOR PETITION ................................

................................................... ..................... THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH BRIAN MORSON SEEKS EXEMPTION ................................... ............................. .................5

THE EXTENT OF RELIEF BRIAN MORSON SEEKS AND THE REA SON BRIAN MORSON SEEKS THE RELIEF............... ............ .. ..................9 THE REASONS WHY GRANTING BRIAN MORSON REQUEST WOULD BE IN THE PUBLIC INTEREST .......... .................. ...................................13

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY ........................... .............................................. 16

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGIST ER. .... 31
ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT BRIAN MORSON REQUEST.... ....... .. 31

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

................................................... ........................ 34Page 4 of 35 GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level AOI Area of Interest ATC Air Traffic Control ATO Air Traffic Organization AV Aerial Vehicle CFR Code of Federal Regulations COA Certificate of Authorization FAA Federal Aviation Administration FAR Federal Aviation Regulation GCS Ground Control Station GPS Global Positioning System LOL Loss of Link NAS National Airspace System NOTAM Notice to Airman PIC Pilot In Command Section 333 FAA Modernization and Reform Act of 201 2 (FMRA) Section 333 SO Safety Observer SOP Standard Operating Procedures UA Unmanned Aircraft UAS Unmanned Aircraft System VFR Visual Flight Rules VLOS Visual Line of Site VMC Visual Meteorological Conditions VTOL Vertical Takeoff and LandingPage 5 of 35

B. The Specific Sections of 14 C.F.R. From Which BRIAN MORSON Seeks Exemption.

1. BRIAN MORSON Seeks Exemption from the Requirements of Section 61.113(a) and (b). Section 61.113, entitled Private pilot privileges a nd limitations: Pilot in command , subsections (a) and (b) prescribe the following, in relevant part:
(a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire , act as PIC of an aircraft. (b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if— (1) The flight is only incidental to that business or e mployment; and (2) The aircraft does not carry passengers or property for compensation or hire.

(c) BRIAN MORSON Seeks Exemption From The Requirements of Section 91.7(a). Section 91.7, entitled Civil aircraft airworthiness , subsection (a), states the following:
(a) No person may operate a civil aircraft unless i t is in an airworthy condition. 3. BRIAN MORSON Seeks Exemption From The Requiremen ts of Section 91.121. Section 91.121, entitled Altimeter settings, subsec tion (a), states the following, in
part: (a) Each person operating an aircraft shall maintain th e cruising altitude or flight level of that aircraft, as the case may be, by refe rence to an altimeter that is set, when operating-- (1) Below 18,000 feet MSL, to-- (i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft;Page 6 of 35 (ii) If there is no station within the area prescribed i n paragraph (a)(1)(i) of this section, the current reported altimeter set ting of an appropriate available station; or (iii) In the case of an aircraft not equipped with a radi o, the elevation of the departure airport or an appropriate altimeter s etting available before departure. (b) BRIAN MORSON Seeks Exemption From The Requirements of Section 91.151(b). Section 91.151, entitled Fuel requirements for flight in VFR conditions , subsection (b), states the following: (b) No person may begin a flight in a rotorcraft un der VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assumin g normal cruising speed, to fly after that for at least 20 minutes.

5. BRIAN MORSON Seeks Exemption From The Requirement o f Section 91.405(a). Section 91.405, entitled Maintenance required , subsection (a), states the following: Each owner or operator of an aircraft—
(a) Shall have that aircraft inspected as prescribe d 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 4 3 of this chapter[.]

6. BRIAN MORSON Seeks Exemption from the Requirements of Section 91.407(a) (1) Section 91.407, entitled Operation after maintenance, preventive maintenance
, rebuilding, or alteration , subsection (a) (1), states the following: (a) No person may operate any aircraft that has undergo ne maintenance, preventive maintenance, rebuilding, or alteration unless-- (1) It has been approved for return to service by a per son authorized under § 43.7 Of this chapter [.]Page 7 of 35

(b) BRIAN MORSON Seeks Exemption From The Requirements of Sections 91.409(a) (1) and 91.409(a) (2). Section 91.409, entitled Inspections , subsection (a), states the following: (a) Except as provided in paragraph (c) of this section , no person may operate an aircraft unless, within the preceding 12 calendar m onths, it has had -- (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person aut horized by § 43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. (b) BRIAN MORSON Seeks Exemption from the Requirements of Sections 91.417(a) and 91.417(b). Section 91.417, entitled Maintenance records , subsections (a) and (b), state the following: (a) Except for work performed in accordance with §§ 91. 411 and 91.413, each registered owner or operator shall keep the followi ng records for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preventive maintenance, and alteration and records of the 100-hour, annual, progressive, and o ther required or approved inspections, as appropriate, for each aircraft (inc luding 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 t he 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:Page 8 of 35 (i) The total time in service of the airframe, each eng ine, each propeller, and each rotor. (ii) The current status of life-limited parts of each ai rframe, 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 b asis. (iv) The current inspection status of the aircraft, incl uding the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness dire ctives (AD) and safety directives including, for each, the method of compl iance, the AD or safety directive number and revision date. If the A D or safety directive involves recurring action, the time and date when t he next action is required. (vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe and currently inst alled engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following re cords for the periods prescribed: (1) The records specified in paragraph (a)(1) of this s ection shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed. (2) The records specified in paragraph (a) (2) of this section shall be retained and transferred with the aircraft at the time the a ircraft is sold. (3) A list of defects furnished to a registered owner o r operator under § 43.11 of this chapter shall be retained until the defects ar e repaired and the aircraft is approved for return to service.Page 9 of 35

C. The Extent Of Relief BRIAN MORSON Seeks And The Rea son BRIAN MORSON Seeks The Relief.

1. Extent Of Relief BRIAN MORSON Seeks And The Reason BRIAN D. MORSON Seeks Relief from Section 61.113(a) and (b). Relief from Section 61.113(a) and (b) entitled Private pilot privileges and

limitations: Pilot in command , is requested to the extent necessary to allow a P IC 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 an d currency requirements, to conduct the proposed UAS flight operations for compensation or hire. This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does n ot carry passengers or property for compensation or hire. As set forth more fully below, BRIAN MORSON submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the DJI PHANTOM 3, PROFESSIONAL UAS unless that PIC has met certain flight- hour and currency requirements, demonstrating that the PIC is able to safely operate either the DJI PHANTOM 3, PROFESSIONAL UAS in a manner consistent with the operations specifications as described in this exemption, incl uding evasive and emergency maneuvers, as well as maintaining appropriate distances from p eople, vessels, vehicles and structures.
Further, BRIAN MORSON submits that all flights of t he DJI PHANTOM 3, PROFESSIONAL UAS, conducted by the PIC pursuant to the grant of this Petition: (1)Page 10 of 35 will be incidental to BRIAN MORSON business; and (2 ) will not carry passengers or property for compensation or hire.

2. Extent Of Relief BRIAN MORSON Seeks And The Reas on BRIAN MORSON Seeks Relief From Section 91.7(a). Relief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to the extent required to allow BRIAN MORSON to determine that the DJI PHANTOM 3, PROFESSIONAL UAS are in airworthy condition prior t o every flight by ensuring that the UAS is in compliance with the operating documents ( i.e., the BRIAN MORSON Aerial Operations Manual, Monthly Maintenance Log, and DJI PHANTOM 3, PROFESSIONAL Instruction Manual). BRIAN MORSON seeks the requested relief because the DJI PHANTOM 3, PROFESSIONAL UAS do not require an airworthiness ce rtificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, BRIAN MORSON will ensure that the DJI PHANTOM 3, PROFESSIONAL UAS are in airworthy condit ion based upon its compliance with the operating documents (i.e., Mont hly Maintenance Log, and DJI PHANTOM 3, PROFESSIONAL Instruction Manual) prior t o every flight, and further,

determine that the aircraft are in condition for sa fe flight, as stated in the conditions

and limitations below

3. Extent Of Relief BRIAN MORSON Seeks And The Reason BRIAN MORSON Seeks Relief From Section 91.121. Relief from Section 91.121, entitled Altimeter sett ings, may be required to allow flight operations of the DJI PHANTOM 3, PROFESSIONA L UAS, which utilize a barometric pressure sensor, GPS equipment, and a ra dio communications telemetry dataPage 11 of 35 link to downlink altitude information from the UA t o the PIC at the ground control station (GCS). Since the FAA requires that any alti tude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), BRIAN MORSON seeks the requested relief because the DJI PHANTOM 3, PROFESSIONAL UA altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, be fore each flight. Considering the limited altitude of the proposed op erations, 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 h erein, an equivalent level of safety will be maintained since the DJI PHANTOM 3, PROFESSIONAL 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 disp lay of the GCS.

4. Extent Of Relief BRIAN MORSON Seeks And The Reason BRIAN MORSON Seeks Relief From Section 91.151(b). Relief from Section 91.151(b) entitled Fuel require ments for flight in VFR conditions, is requested to the extent required to allow flights of the battery powered DJI PHANTOM 3, PROFESSIONAL and DJ UAs during daylight hours in visual meteorological conditions (VMC), under visual fligh t rules (VFR), for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. BRIAN MORS ON seeks the requested relief because without an exemption from Section 91.151(b), the fl ight time duration of the batteryPage 12 of 35

powered DJI PHANTOM 3, PROFESSIONAL UA will severel y constrain the practicality of any aerial video or still photo flight operation s that BRIAN MORSON proposes to conduct pursuant to this Petition. Significantly, a s set forth below, the technical specifications of the DJI PHANTOM 3, PROFESSIONAL U AS, operating documents, and BRIAN MORSON proposed operating limitations, ensure that BRIAN MORSON will safely operate the battery powered DJI PHANTOM 3, P ROFESSIONAL UA during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total durati on of 13.5 minutes to the first point of intended landing and, assuming normal cruising spee d, to fly after that for at least 4.5

minutes.

5. Extent Of Relief BRIAN MORSON Seeks And The Reason BRIAN MORSON Seeks Relief From Sections 91.405(a), 91.407 (a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b). Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1 ) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certif icate, BRIAN MORSON requests relief from these Sections because the DJI PHANTOM 3, PROF ESSIONAL UAS do not require airworthiness certificates. As set forth mo re fully below, the DJI PHANTOM 3,

PROFESSIONAL UAS meet the conditions of FMRA Sectio n 333 for operation without an airworthiness certificate. Accordingly, BRIAN MO RSON will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in th e UAS operating documents (i.e., the BRIAN MORSON Aerial Operations Manual, Monthly Main tenance Log, and DJI PHANTOM 3, PROFESSIONAL Instruction Manual). Furthe rmore, BRIAN MORSON

will document and maintain all maintenance records for the DJI PHANTOM 3,

PROFESSIONAL UAS.Page 13 of 35

D. The Reasons Why Granting BRIAN MORSON Request Wo uld Be In The Public Interest; That Is, How It Would Benefit The Public As A Whole.
Granting the present Petition will further the publ ic interest by allowing BRIAN MORSON too safely, efficiently, and economically pe rform aerial video and photography of real estate and landscape over certain areas of the United States. Additionally, use of the DJI PHANTOM 3, PROFESSIONA L UAS will decrease congestion of the NAS, reduce pollution, and provid e significant benefits to the economy. Notably, the benefits of BRIAN MORSON proposed oper ation of the DJI PHANTOM 3, PROFESSIONAL UAS will be realized without implicati ng any privacy issues.

1. The Public Will Benefit From Decreased Congestion O f The NAS. The DJI PHANTOM 3, PROFESSIONAL UA are battery powe red and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of ma nned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJ I PHANTOM 3, PROFESSIONAL

UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life a nd property in the air and on the ground. Furthermore, by reducing the number of manned aircr aft operating in the NAS, congestion around airports caused by arriving and d eparting aircraft will be reduced. The DJI PHANTOM 3, PROFESSIONAL UA do not require an ai rport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photographyPage 14 of 35 missions would result in fewer aircraft that must b e 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 Effici ency of the DJI PHANTOM 3, PROFESSIONAL UAS.
Conducting aerial acquisitions with the DJI PHANTOM 3, PROFESSIONAL UAS, instead of manned aircraft, will greatly benefit th e public by drastically reducing the levels of air and noise pollution generated during traditi onal aerial video and still photography flight operations. By using battery power and elect ric motors, the DJI PHANTOM 3, PROFESSIONAL UAS produce no air pollution, and is t he most viable environmentally conscious alternative to the cabin class, six cylin der internal combustion engine aircraft that are typically utilized for aerial video and photogr aphy, while burning approximately 20-30 gallons per hour of leaded aviation fuel. The DJI P HANTOM 3, PROFESSIONAL UA, while reducing the carbon footprint of aerial acqui sitions, also eliminates noise pollution, as the UA are propelled by battery powered electric mo tors, rather than an internal combustion engine. By using the DJI PHANTOM 3, PROFESSIONAL UA S to perform aerial acquisitions, the substantial risk to life and prop erty 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 la ck of flight crew members located onboard the aircraft, the DJI PHANTOM 3, PROFESSION AL UA weighing approximately 2.82 pounds respectively, at their maximum gross we ights with BLADES widths of 23.22 inches respectively, and with no fuel on board), ha s less physical potential for collateral damage to life and property on the ground, and in t he air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with aPage 15 of 35 wingspan of approximately 42 feet, a length of 34 f eet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations With the DJI PHANTOM 3 PROFESSIONAL UAS Will Benefit the Economy

. In addition to being safe and efficient, the DJI PH ANTOM 3, PROFESSIONAL UAS are also an economical alternative to using man ned aircraft to conduct similar aerial operations. As such, operation of the DJI PHANTOM 3 , PROFESSIONAL UAS will allow United States based companies, like BRIAN MORSON, t o remain competitive and contribute to growth of the U.S. economy. Specifica lly, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) reg ulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies m ust adopt new and alternative technology in order to remain competitive. Operatin g the battery powered DJI PHANTOM 3, PROFESSIONAL UAS is one such technology that not only allows companies greater operational flexibility compared to manned aircraft , but provides such flexibility without the high operational cost of a traditional manned aircraft. By operating the DJI PHANTOM 3, PROFESSIONAL UAS, c ompanies such as BRIAN MORSON, can remain competitive and profitable , and therefore, provide greater job stability to employees and contractors, which w ill ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S . companies, through commercial use of the DJI PHANTOM 3, PROFESSIONAL UAS, provide s a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the

United States and abroad.Page 16 of 35 4. There Are No Privacy Issues. Similar to the manned aerial acquisition flight ope rations that have been conducted for decades, BRIAN MORSON proposed operation of the DJI PHANTOM 3, PROFESSIONAL UAS will not implicate any privacy iss ues. Specifically, the DJI PHANTOM 3, PROFESSIONAL UAS will be operated only i n compliance with operating documents (i.e., the BRIAN MORSON Aerial Operations Manual, Monthly Maintenance Log, and DJI PHANTOM 3, PROFESSIONAL In struction Manual) which requires property owner involvement as well as loca l law enforcement notification, and in accordance with the Federal Aviation Regulations, i ncluding the minimum altitude requirements of 14 C.F.R. § 91.119.

E. The Reasons Why Granting The Exemption Would Not Ad versely Affect Safety, Or How The Exemption Would Provide A Level Of Safet y At Least Equal To That Provided By The Rule From Which BRIAN MORSON Seeks Exemption.

1. Reasons Why the DJI PHANTOM 3, PROFESSIONAL UA Meet the Conditions of the FAA Modernization and Reform Act of 2012 (FMRA) Section 333. In consideration of the size, weight, speed, and li mited operating area associated with the unmanned aircraft and its operation, BRIAN MORSON operation of the DJI PHANTOM 3, PROFESSIONAL UAS meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in ac cordance 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 consi dering whether a UAS will create aPage 17 of 35 hazard to users of the NAS or the public, or otherw ise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part: (a) In General.--Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system befo re completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act. (b) Assessment of Unmanned Aircraft Systems.--In making the determination under subsection (a), the Secretary s hall determine, at a minimum-- (1) ) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capabilit y, proximity to airports and populated areas, and operation with in visual line of sight do not create a hazard to users of th e national airspace system or the public or pose a threat to n ational security; and (2) ) whether a certificate of waiver, certificate of a uthorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation o f unmanned aircraft systems identified under paragraph (1). (c) Requirements for Safe Operation.--If the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shal l establish requirements for the safe operation of such aircraf t systems in the national airspace system.

In seeking this exemption, BRIAN MORSON submits tha t the DJI PHANTOM 3, PROFESSIONAL and UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) The characteristics of the DJI PHANTOM 3, PROF ESSIONAL
UAS; (b) The pilot certification requirement; and (c) th e specific operating

limitations.Page 18 of 35 a. The specifications of The DJI PHANTOM 3 , PROFESSIONAL, UAS Demonstrate Its Safe Characterist ics.

The DJI PHANTOM 3, PROFESSIONAL UAS do not create a hazard to users of the NAS or the public, or otherwise pos e a threat to national security considering its size, weight, speed, and operationa l capability.

i. Technical Specifications of the DJI PHANTOM 3, PROF ESSIONAL UAS. The technical specifications of the DJI PHANTOM 3, PROFESSIONAL UAS are set forth by the DJI PHANTOM 3, PROFESSIONA L Specifications and Data Sheet, previously attached hereto as Exhibit A and B.

ii. The DJI PHANTOM 3, PROFESSIONAL and DJ UASs Autonomous Flight and Navigation Modes Enable the U ASs to Remain Within A Defined Operational Area. The DJI PHANTOM 3, PROFESSIONAL UAS may be operated in both manual and fully autonomous flight modes. A complet e description of the flight and navigational modes of the DJI PHANTOM 3, PROFES SIONAL UAS is provided at page 25 of the DJI PHANTOM 3, PROFESSIO NAL User Manuals, as submitted previously Exhibit C and D.

iii. The DJI PHANTOM 3, PROFESSIONAL UAS is designed for Automatic Return to Home Point or Hover In The even t Of Loss Of The Control Link or Navigation. When the Control Link is lost, the DJI PHANTOM 3, P ROFESSIONAL UA will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI PHANTOM 3, PROFESSIONAL and DJ UAs do not reacq uire control linkPage 19 of 35 data from the GCS, the UAs will assume that the Con trol Link is lost and the UAs will return to the home position (i.e., fai lsafe mode) via GPS, and will descend to the takeoff position and shutdown. A complete description of the Failsafe Functions of the DJI PHANTOM 3, PROFESSIONAL UAS are set forth at pages 13 through 14 at pages users’ manual as previously provided. Description of the operatio n and specifications of the DJI PHANTOM 3, PROFESSIONAL GCS and flight control soft ware is provided at pages 34 through 38 of the DJI PHANTOM 3 User manua l. Manual. DJI PHANTOM 3, PROFESSIONAL User Manuals as previously

attached hereto as Exhibits C and D.

b. Flight Operations of DJI PHANTOM 3, PROFESSIONAL UA S Are Limited to the Line Of Sight of a Certificated Pilo t in Command With A Safety Observer. BRIAN MORSON will only utilize certificated pilots who possess a current and valid airman medical certificate to act as a pi lot in command (PIC) of the DJI PHANTOM 3, PROFESSIONAL and DJ UASs. Additionally, a safety observer will assist all pilots during flight time.

c. Flights Of DJI PHANTOM 3, PROFESSIONAL UAS Will Be Conducted Pursuant To Specific Operating Limitation s. In seeking this exemption, BRIAN MORSON proposes to commercially operate DJI PHANTOM 3, PROFESSIONAL UAS for the spe cial purpose of conducting aerial video and photography over certai n areas of United States, pursuant to the following specific operating limitations:

1. Operations authorized by this grant of exemption wi ll be limited to the following aircraft described in the operating docum ents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: DJI PHANTOM 3, PROFESSIONAL Unmanned Aircraft Systems. Proposed op erations of any other aircraft will require a new petition or a pet ition to amend this grant.Page 20 of 35 2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and phot ography.

3. The UAs may not be flown at an indicated airspeed e xceeding 20 knots.

4. The UA must be operated at an altitude of no more t han 500 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is mad e and approved by ATC. All altitudes reported to ATC must be in feet AGL.

5. The UAs must be operated within visual line of sigh t (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 specifi ed on the PIC’s FAAissued airman medical certificate. 6. The use of first person view (FPV) by the PIC or sa fety observer (SO) is not permitted.

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC always main tains 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 hi s or her designation for the duration of the flight. The PIC must ensure that th e SO can perform the functions prescribed in the operating documents.

8. The SO must not perform any other duties beyond ass isting the PIC with seeing and avoiding other air traffic and other ground bas ed obstacles/obstructions and is not permitted to operate the camera or other ins truments.
9. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administra tor upon request. If a discrepancy exists between the conditions and limit ations contained in the grant of exemption and the procedures outlined in the ope rating documents, the conditions and limitations contained in the grant o f exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator m ay update or revise its operating documents. It is the operator’s responsib ility to track such revisions and present updated and revised documents to the Ad ministrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. I f 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 t he operating documents.Page 21 of 35

10. Prior to each flight the PIC must inspect the UAS t o ensure that it is in a condition for safe flight. If the inspection reveal s a condition that affects the safe operation of the UAS, the aircraft is prohibit ed from operating until the necessary maintenance has been performed and the UA S is found to be in a condition for safe flight. The Ground Control Stati on must be included in the preflight inspection. All maintenance and alteratio ns must be properly documented in the aircraft records.

11. Any UAS that has undergone maintenance or alteratio ns that affect the UAS operation or flight characteristics, e.g. replaceme nt of a flight critical component, must undergo a functional test flight. T he PIC who conducts the functional test flight must make an entry in the ai rcraft records.

12. The pre-flight inspection must account for all pote ntial discrepancies, e.g. inoperable components, items, or equipment, not alr eady covered in the relevant sections of the operating documents. 13. The operator must follow the UAS manufacturer’s air craft/component, maintenance, overhaul, replacement, inspection, and life limit requirements.

14. The operator must carry out its maintenance, inspec tions, and record keeping requirements, in accordance with the operating docu ments. Maintenance, inspection, alterations, and status of replacement/ overhaul component parts must be noted in the aircraft records, including total t ime in service, description of work accomplished, and the signature of the authori zed person returning the UAS to service.

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

16. The authorized person must make an entry in the air craft record of the corrective action taken against discrepancies disco vered between inspections.

17. The PIC must possess at least a private pilot certi ficate and at least a current third- class medical certificate.

18. The operator may not permit any PIC to operate unle ss 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 maneuver s and maintaining appropriate distances from persons, vessels, vehicl es and structures. PIC qualification flight hours must be logged in a mann er consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training th e operator’s PICs are permitted under the terms of the exemption. However, training operations may only be conducted during dedicated training sessions. Durin g training, proficiency, and experience-building flights, all persons not essent ial for flight operations arePage 22 of 35 considered nonparticipants, and the PIC must operat e the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119.

19. UAS operations may not be conducted during night, a s defined in 14 C.F.R. § 19.1. All operations must be conducted under visual meteo rological conditions (VMC). If flight at night is required, a special request will be made at the FAA office closest to proposed area of operatio ns. Flights under special visual flight rules (SVFR) are not authorized.

20. The UA may not operate within 5 nautical miles of a n airport reference point as denoted on a current FAA-published aeronautical cha rt unless a letter of agreement with that airport’s management is obtaine d, 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 mus t 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 les s than 3 statute miles from the PIC.

22. If the UA loses communications or loses its GPS sig nal, it must return to a predetermined location within the planned operating ar ea and land or be recovered in accordance with the operating documents.

23. The PIC must abort the flight in the event of unpre dicted obstacles or emergencies in accordance with the operating docume nts.

24. The PIC is prohibited from beginning a flight unles s (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 25% battery power remaining.

25. The operator must obtain an Air Traffic Organizatio n (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting a ny operations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance , but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA includi ng class of airspace, altitude level and potential transponder requiremen ts.
26. All aircraft operated in accordance with the exempt ion must be identified by serial number, registered in accordance with 14 C.F .R. part 47, and have identification (N- Number) markings in accordance w ith 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable

. 27. Before conducting operations, the radio frequency s pectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government ov ersight agency requirements.Page 23 of 35

28. The documents required fewer than 14 C.F.R. 91.9 an d 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made avai lable to the Administrator or any law enforcement official upon request.

29. The UA must remain clear and yield the right of way to all manned aviation operations and activities at all times.

30. The UAS may not be operated by the PIC from any mov ing device or vehicle.

31. Flight operations must be conducted at least 500 fe et from all nonparticipating persons (persons other than the PIC, SO, operator t rainees or essential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficientl y protect nonparticipating persons from the UA and/or debris in the event of a n accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticip ating persons leave such protection and are within 500 feet of the UA, fligh t operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or struc tures has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined th at it does not present an undue hazard, and;

c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a).

32. All operations shall be conducted over private or c ontrolled-access property with permission from the land owner/controller or a uthorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted.

33. Any incident, accident, or flight operation that tr ansgresses the lateral or vertical boundaries of the operational area as defi ned by the applicable COA must be reported to the FAA's UAS Integration Offic e (AFS-80) within 24 hours. Accidents must be reported to the National T ransportation Safety Board (NTSB) per instructions contained on the NTSB Web s ite: www.ntsb.gov

.Page 24 of 35 2. Reasons Why an Exemption from the Requirements of S ection 61.113(a) and (b) Would Not Adversely Affect Safety. BRIAN MORSON submits that the equivalent level of s afety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI PHANTOM 3, PROFESSIONAL UAS unless that PIC has dem onstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the DJI PHANTOM 3, PROFESSIONAL UAS in a manner consist ent with the exemption, Including evasive and emergency maneuvers and maint aining appropriate distances from people, vessels, vehicles and structures. Considering BRIAN MORSON proposed area of operation s, and the operating limitations set forth-above; the parallel nature of private pilot aeronautical knowledge
requirements to those of commercial pilot requireme nts (See Exemption No. 11062); and
the airmanship skills necessary to safely operate t he DJI PHANTOM 3, PROFESSIONAL UAS, BRIAN MORSON submits that the additional manne d airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for BRIAN MORSON specific proposed flight operations. The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material resp ects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 1 1067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11 160, 11161).Page 25 of 35 BRIAN MORSON will not allow any PIC to operate the DJI PHANTOM 3, PROFESSIONAL UAS unless that PIC has demonstrated, by meeting minimum flighthour requirements or the DJI PHANTOM 3, PROFESSIONA L UAS training and currency requirements, that the PIC is able to safe ly operate the DJI PHANTOM 3,

PROFESSIONAL UAS in a manner consistent with this e xemption, including evasive and emergency maneuvers and maintaining app ropriate distances from people, vessels, vehicles and structures. Specifically, the PIC must have accumulated and log ged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time a s a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot op erating the same make and model of UAS to be used for operations under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes).
As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with app licable regulations will ensure an equivalent level of safety during BRIAN MORSON p roposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as

follows: In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of video and photography (or similar operations), the PIC must have accumulated and logged, in a mann er consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotor craft pilot including at least 10 hours logged as a UAS pilot with a multi-r otor UAS. Prior to operations under Exemption No. 11062, the PIC must also have accumulatedPage 26 of 35 and logged a minimum of 5 hours as a UAS pilot oper ating the same make and model of UAS to be used for operations under th e exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make a nd model time may be included in the 10 hours of multi-rotor time and th e 10 hours may be included in the total 25 hours of UAS rotorcraft ti me. In addition to the hour requirements, the PIC must accomplish 3 takeoffs an d landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight-hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in th e skills necessary to safely conduct the petitioner’s proposed operations. The F AA also finds that prior documented flight experience that was obtained in c ompliance with applicable regulations would satisfy this requireme nt. Training, proficiency, and experience-building flights can also be conduct ed under the grant of exemption to accomplish the required flight time. D uring training, proficiency, and experience-building flights the PI C is required to operate the UA with appropriate distances in accordance wit h 14 C.F.R 91.119.

Exemption No. 11138 at page 15. Accordingly, BRIAN MORSON will ensure safe operatio ns by not allowing any PIC to operate the DJI PHANTOM 3, PROFESSIONAL UAS unless that PIC has demonstrated, by meeting minimum flight-hour an d currency requirements that the PIC is able to safely operate the DJI PHANTOM 3,

PROFESSIONAL UAS in a manner consistent with the e xemption, including evasive and emergency maneuvers and maintaining app ropriate distances from people, vessels, vehicles and structures.

3. Reasons Why an Exemption from the Requirements of S ection 91.7(a) Would Not Adversely Affect Safety. The equivalent level of safety established by Secti on 91.7(a) will be maintained because prior to every flight, BRIAN MORSON will en sure that the DJI PHANTOM 3, PROFESSIONAL UAS is in an airworthy condition based upon the UAS’s compliancePage 27 of 35 with its operating documents and as stated in the c onditions and limitations herein. Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all material resp ects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 1 1067, 11080, 11109, 11110, 11112,
11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11 160, 11161)

4. Reasons Why an exemption from the Requirements of S ection 91.121 would not adversely affect Safety. The equivalent level of safety established by Secti on 91.121 will be maintained

because the altitude information of the DJI PHANTOM 3, PROFESSIONAL UA will be provided to the PIC via GPS equipment and a radio c ommunications telemetry data link, which downlinks from the UA to the GCS for ac tive monitoring of the flight path and altitude. This altitude information, combined with BRIAN MORSON operation of the DJI PHANTOM 3, PROFESSIONAL UAs within visual line of s ight, at or below 500 feet AGL, will ensure a level of safety equivalent to Se ction 91.121. The altitude information will be generated by GPS equipment installed onboar d the aircraft. Prior to each flight, a zero altitude initiation point is automat ically established by the UASs at ground

level. The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption
Nos. 11062, 11063, 11064, 11065, 11066, 11067, 1108 0, 11109, 11112, 11136, 11138,
11150, 11153, 11156, 11157, 11158, 11159, 11160, 11 161).Page 28 of 35 5. Reasons Why an Exemption from the Requirements of S ection 91.151(b) Would Not Adversely Affect Safety. A grant of this exemption would ensure an equivalen t level of safety established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJI PHANTOM 3, PROFESSIONAL UAS; (2) the limitations on the proposed flight operations; and (3) the location of the proposed fl ight operations. Accordingly, BRIAN MORSON will ensure that it will safely operate the battery powered DJI PHANTOM 3, PROFESSIONAL UA during daylight hours in VFR condit ions, with enough battery power to fly for a total duration of 13.5 m inutes to the first point of intended landing and, assuming normal cruising speed, to fly after t hat for at least 4.5 minutes. Here, as in Exemption No. 11109, the technical spec ifications of the DJI PHANTOM 3, PROFESSIONAL UAS; the limitations on the proposed flight operations; and the location of the proposed operations, will e nsure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Further more, safety will be ensured as the DJI PHANTOM 3, PROFESSIONAL UAS provide audible and vis ual warnings to the PIC at the GCS when the UAs experiences low battery voltag e, the first warning occurring at approximately 33% remaining battery power, and agai n at approximately 10% remaining battery power. At the critically low batt ery level, the DJI Phantom Vision+ and DJ UASs will descend and land automatically. Significantly, previous exemptions granted by the F AA concerning Section 91.151 establish that safety is not adversely affected whe n the technical characteristics and operating limitations of the UAS are considered. Re lief has been granted for mannedPage 29 of 35 aircraft to operate at less than the minimums presc ribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Mor eover, the FAA has previously granted relief
from Section 91.151 specific to UAS, in circumstanc es similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 1 0808, 10673, 11042, 11062, 11063,
11064, 11065, 11066, 11067, 11080, 11109, 11110, 11 136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

6. Reasons Why An Exemption From The Requirements Of S ections 91.405(a), 91.407(a) (1), 91.409(a) (1) & (a) (2), And 91.417(a) & (b) Would Not Adversely Affect Safety. In seeking this exemption, BRIAN MORSON submits tha t the equivalent level of safety with regard to the regulatory maintenance an d alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a )(2), and 91.417(a) & (b) will

be met because BRIAN MORSON will use trained techni cians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i. e., the BRIAN MORSON Aerial Operations Manual, Monthly Maintenance Log, and DJI PHANTOM 3, PROFESSIONAL Instruction Manual). Furthermore, BRIA N MORSON will document

and maintain all maintenance records for the DJI PH ANTOM 3, PROFESSIONAL UAS. Since the DJI PHANTOM 3, PROFESSIONAL UAS will be i nspected as prescribed by the operating documents, BRIAN MORSON will maintain the equivalentPage 30 of 35 level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of
the DJI PHANTOM 3, PROFESSIONAL User Manuals are at tached hereto as Exhibit C and D; a copy of the DJI PHANTOM 3, PROFE SSIONAL UAS Maintenance LOG is as previously attached hereto as Exhibit E. Likewise, the exemption sought will not adversely a ffect safety because BRIAN MORSON will use trained technicians to perform main tenance, alterations or preventive
maintenance on the UAS using the methods, technique s, and practices prescribed by the operating documents. Furthermore, the exemption sought would maintain an equivalent level of safety established by Sections 91.407, 91.417(a) and 91.41 7(b), because all maintenance of the DJI PHANTOM 3, PROFESSIONAL UASswill be performed b y trained technicians.

Maintenance will be documented and maintained utili zing 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 safety is not adversely affected when the technical character istics and operating limitations of the

UAS are considered. In consideration of BRIAN MORSON proposed operating limitations, the operating documents, and the technical aspects of t he DJI PHANTOM 3, PROFESSIONAL UAS, BRIAN MORSON submits that safety will not be adversely affected by granting exemption from 14 C.F.R. Secti ons 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has pr eviously granted relief specificPage 31 of 35 to UAS in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11 066, 11067, 11080, 11109, 11110,
11112, 11136, 11138, 11150, 11153, 11156, 11157, 11 158, 11159, 11160, 11161).

F. A Summary That Can Be Published in the Federal Regi ster, stating: The Rules from Which BRIAN MORSON Seeks Exemption: BRIAN MORSON seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a ), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). A Brief Description of the Nature of the Exemption BRIAN MORSON Seeks: This exemption will permit BRIAN MORSON to commerci ally operate an Unmanned Aircraft System (UAS) for the purpose of c onducting aerial video and photography over certain areas of the United States

. G. Any Additional Information, Views, or Arguments Ava ilable To Support BRIAN MORSON Request. This Petition is made pursuant to the FAA Moderniza tion and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. As such, BRIAN M ORSON request for exemption may be granted pursuant to the authority of FMRA Se ction 333 and 14 C.F.R. Part 11, as

set forth above. FMRA Section 333 sets forth the re quirements for considering whether a

UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the author ity for such UAS to operate without

airworthiness certification. As discussed in detail above, BRIAN MORSON will ope rate the DJI PHANTOM 3, PROFESSIONAL and DJ UASs safely in the NAS, with out creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.Page 32 of 35 7. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 333 of the FAA Moderniza tion and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Condi tions, BRIAN MORSON requests that the FAA prescribe special conditions for the i ntended operation of the DJI
PHANTOM 3, PROFESSIONAL UAS, which contain such saf ety standards that Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.11 3(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a) (1), 91.409(a) (1) & (a) (2), and 91.417(a) & (b). Such special conditions will permit safe operation of th e UAs for the limited purpose of conducting aerial video and photography over certai n areas of the United States for compensation or hire. FMRA Section 333 sets forth t he requirements for considering

whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate

without airworthiness certification in accordance w ith any requirements that must be established for the safe operation of the UAS in th e NAS. Likewise, the Administrator may prescribe special c onditions pursuant to 14 C.F.R. § 21.16, for operation of the DJI PHANTOM 3, PROFES SIONAL and DJ UASs, since the airworthiness regulations of 14 C.F.R. Part 21 do n ot contain adequate or appropriate safety standards, due to the novel or unusual design featu res of the aircraft. Section 21.16, entitled Special Conditions, states the following: If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an air craft, aircraft engine, or propeller because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and ame ndments thereto for the product. The special conditions are issued in accordance wit h Part 11 of this chapter and contain such safety standards for the aircraft, air craft engine or propeller as the FAA finds necessary to establish a level of safety equi valent to that established in the regulations.Page 33 of 35

See 14 C.F.R. § 21.16. Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for Leading Edge’s intended operation of the BLADE 350 QX AP and DJ UASs, which contain such safety st andards that the
Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).Page 34 of 35 CONCLUSION As set forth herein, BRIAN MORSON seeks an exemptio n pursuant to 14 § 11.61 and Section 333 of the FAA Modernization an d Reform Act of 2012 (FMRA), which will permit safe operation of the DJI PHANTOM 3, PROFESSIONAL UAS commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also ad vancing the interests of the public, by allowing BRIAN MORSON to safely, efficiently, and e conomically operate the DJI
PHANTOM 3, PROFESSIONAL and DJ UASs commercially wi thin the NAS.

WHEREFORE , in accordance with the Federal Aviation Regulatio ns and the FAA Modernization and Reform Act of 2012, Section 333, BRIAN MORSON respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.1 21, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and per mit Leading Edge to operate the DJI PHANTOM 3, PROFESSIONAL UAS commercially for the pu rpose of conducting aerial video and photography over certain areas of the Uni ted States. Dated: July 27, 2015

Respectfully submitted,

BRIAN MORSONPage 35 of 35 **BRIAN MORSON 12135 Sand Pebble**  **Way Orlando Florida Tel: (407)**  **432-5364**

**Appendices:**

**A - Monthly Maintenance Log**Page 36 of 35 **APENDIX - A**

**Maintenance Log**

UAS$#:$ Date(Issue( Discovered Date(Issue(

Addressed Issue(Description(&(Maintenance(Conducted Maintenance (Performed (By :((( Print(&(Sign

Software(Updates

Airframe(

Engines

Propellers

Camera(Gimbal

Landing(Gear

Vibration(Dampening

Other:CONCLUSION

As set forth herein, BRIAN MORSON seeks an exemption pursuant to 14

§ 11.61 and Section 333 of the FAA Modernization and Reform Act of2012 (FMRA),

which will permit safe operation of the DJI PHANTOM 3, PROFESSIONAL UAS commercially, without an airworthiness certificate, for the limited purpose of conducting

aerial video and photography over certain areas of the United States. By granting this
Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA

Modernization and Reform Act of2012, while also advancing the interests of the public, by allowing BRIAN MORSON to safely, efficiently, and economically operate the DJI

PHANTOM 3, PROFESSIONAL and DJ UASs commercially within the NAS. WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA

Modernization and Reform Act of 2012, Section 333, BRIAN MORSON respectfully

requests that the Administrator grant this Petition for an exemption from the requirements

of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.15l(b), 91.405(a), 91.407(a)(l),
91.409(a)(l) & (a)(2), and 91.417(a) & (b), and permit Leading Edge to operate the DJI

PHANTOM 3, PROFESSIONAL UAS commercially for the purpose of conducting aerial

video and photography over certain areas of the United States.

Dated: July 27, 2015

Page 34 of 35 Respectfully submitted,

BRIAN MORSON