UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No.

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:



### CERIOUS PRODUCTIONS LLC.

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIRE MENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

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

91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL

OPERATION OF a) DJI PHANTOM 2 VISION+ and b) DJI INSPIRE 1

UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112

- 95)

Submitted on JUNE 1 9

, 2015

CERIOUS PRODUCTIONS LLC.

Michael Cerdeiros

, Owner

9468 Descending Creek St

Las Vegas NV 89 123

917

- 470

- 42202 TABLE OF CONTENTS

Page

GLOSSARY OF ABBREVIATIONS

.................................................................. ............ 3

SUMMARY

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

INTRODUCTION AND INTERESTS OF PETITIONER.

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

BACKGROUND..........

...................................... ................................ ............................... 5

BASIS FOR PETITION

................................ ................................ ................................ ..... 5

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

................................ ........................ 6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH, CERIOUS PRODUCTIONS

LLC.

SEEKS EXEMPTION

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

THE EXTENT OF RELIEF CERIOUS PRODUCTIONS LLC. SEEKS AND THE

REASON

CERIOUS PRODUCTIONS LLC. SEEKS THE RELIEF

............................... .... 10

THE REASONS WHY GRANTING CERIOUS PRODUCTIONS LLC. ’S REQUEST

WOULD

BE IN THE PUBLIC INTEREST

.... ................................ ................................ .............. 13

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADV ERSELY

AFFECT SAFETY

................................ ................................ ................................ ........... 16

CONCLUSION

................................ ................................ ................................ ................ 323 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 Fede ral 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 2 012 (FMRA)

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 Landing4 SUMMARY

CERIOUS PROD UCTIONS LLC. seeks exemption from the requirements of 14

C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System

pursuant to Section 333 of the FAA Mo dernization and Reform Act of 2012 (FMRA).

This exemption will permit CERIOUS PRODUCTIONS LLC. to operate an Unmanned

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

photography for real estate photography, wedding videograp hy, special events, film sets

and landscape over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

My name is Michael Cerdeiros ., Owner of CERIOUS PRODUCTIONS LLC. . It

is my mission to provide my clients with expertise and knowledge in all aspects of

picture, video & audio production, as well as provide them with advanced technologies

& solutions that will increase efficiency, productivity and effectiveness. CERIOUS

PRODUCTIONS LLC. also provides clients with the highest qu ality digital content for

use in their commercial, personal, and non

- profit multimedia projects. CERIOUS

PRODUCTIONS LLC. has 10 years of professional experience in photography and

videography and has become recognized as an expert in this field.

CERIOUS P RODUCTIONS LLC. has 2 years of recreational/hobby experience in all

aspects of aerial video and photography. The objective of CERIOUS PRODUCTIONS

LLC. ’s aerial video and photography operations is to provide high quality imaging for a

variety of commercial, public, and residential uses, specifically targeting:

• Real Estate Videography and Photography

• Wedding Videography and Photography

• Land survey & appraisals

• Equipment Inspections

• Roof Inspections

• Construction sites before & after

• Precision Agriculture

• Crea tion of commercial messages for Television.

• Search and Rescue Operations

• Motion Picture Filming

• Increase public knowledge of UAS and promote safe UAS operations.5 BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 2 Vision+, and DJI Inspire 1 UASs

CERIOUS PRODUCTIONS LLC. seeks an exemption to operate DJI systems for

compensation or hire within the NAS. The DJI Phantom 2 Vision+ and DJI Inspire 1 are

vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control

Station (GCS) utilizing ele ctronic tablet or smart phone systems. The DJI Phantom 2

Vision+ has a maximum gross weight of approximately 2 pounds 11 ounces, while

having a length of 16 inches width of 16 inches, height of 8 inches, and a maximum

speed of approximately 29 knots. The D JI Inspire 1 has a maximum gross weight of 6

pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches,

and a maximum speed of approximately 42 knots. The DJI Phantom 2 Vision+ and DJI

Inspire 1 UAs are equipped with four main rotors; driven by Lithium Polymer battery

powered electric motors.

The DJI Phantom 2 Vision+ and DJI Inspire 1 UAs that will be operated by

CERIOUS PRODUCTIONS LLC. will be registered in accordance with 49 U.S.C.

44103, Registration of Aircraft , as well as 14 C.F.R Part 47, Aircraft Registration , and

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

.

BASIS FOR PETITION

Petitioner, CERIOUS PRODUCTIONS LLC. , pursuant to the provisions of the

Federal Aviation Regulations ( 14 C.F.R. § 11.61) and the FAA Modernization and

Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft

Systems

, hereby petitions the Administrator to commercially operate the DJI Phantom 2

Vision+, DJI Inspire 1 UASs in the Na tional Airspace System (NAS), and for an

exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121,

91.151(b), 91.405(a),

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

In consideration of the speed, weight, size, and limi ted operating area associated

with the unmanned aircraft and its operation, CERIOUS PRODUCTIONS LLC.

operation of DJI Phantom 2 Vision+ and DJI Inspire 1 UASs meets the conditions of

FMRA Section 333 and therefore, will not require an airworthiness certifi cate in

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

Accordingly, CERIOUS PRODUCTIONS LLC. requests relief from Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set

forth requirements for maintenance that on ly apply to aircraft with an airworthiness

certificate.

CERIOUS PRODUCTIONS LLC. submits that the requested relief is proper

since an equivalent level of safety will be ensured. CERIOUS PRODUCTIONS LLC.

will use experienced personnel or technicians to per form maintenance, alterations, or

preventive maintenance on the UASs using the methods, techniques, and practices

prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom

2 Vision+ and DJI Inspire 1 Instruction Manual). Further more, CERIOUS

PRODUCTIONS LLC. will document and maintain all maintenance records for the DJI6 Phantom 2 Vision+ and DJI Inspire 1 UASs.7 Relief from certain requirements of Section 61.113(a) and (b), entitled Private

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

PRODUCTIONS LLC. to the extent necessary to allow a Pilot in Command (PIC)

holding a private pilot or higher level certificate, as well as an airman medical certificate,

and who has demonstrated, by meeting minimum flig ht

- hour and currency requirements,

that the PIC is able to safely operate the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs

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

and maintaining appropriate distances from peo ple, vessels, vehicles and structures.

CERIOUS PRODUCTIONS LLC. seeks relief from Section 91.7(a), entitled

Civil aircraft airworthiness , because the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs

do not require an airworthiness certificate in accordance wi th 14 C.F.R. Part 21, Subpart

H. As such, CERIOUS PRODUCTIONS LLC. submits that they will ensure that the DJI

Phantom 2 Vision+ and DJI Inspire 1 UASs are in an airworthy condition, prior to every

flight, by determining that the UASs are in compliance with the operating documents

(i.e., Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1

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

CERIOUS PRODUCTIONS LLC. also seeks an exemption from the requirements

of S ection 91.121, entitled Altimeter Settings , as the DJI Phantom 2 Vision+ and DJI

Inspire 1 UAs will not have a typical barometric altimeter onboard. However, altitude

information of the DJI Phantom 2 Vision+ and DJI Inspire 1UAs will be provided to the

PIC via Global Positioning System (GPS) equipment and radio communications

telemetry data link, which downlinks from the UA to the GCS for active monitoring of

the flight path. This altitude information, combined with CERIOUS PRODUCTIONS

LLC. ’s operation of t he DJI Phantom 2 Vision+ and DJI Inspire 1 UASs within visual

line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section

91.121.

Additionally, CERIOUS PRODUCTIONS LLC. seeks an exemption from the

requirements of Section 9 1.151(b), entitled Fuel requirements for flight in VFR

conditions. CERIOUS PRODUCTIONS LLC. submits that safety will not be affected by

operation of the DJI Phantom 2

Vision+ and DJI Inspire 1 UAs during daylight hours in visual meteorological conditions

( VMC) under visual flight rules (VFR), with enough battery power to fly for a total

duration of approximately 13.5 minutes to the first point of intended landing and,

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

In accordance with 14 C.F.R. § 11.81, CERIOUS PRODUCTIONS LLC.

provides the following information in support of its petition for exemption:

A. Name And Address Of The Petitioner.

The name and address of the Petitioner and point of contact is:

Michael Cerdeiros c/o CERIOU S PRODUCTIONS LLC.

9468 Descending Creek St

Las Vegas NV 89123

Tel: ( 917) 470 4220

Email: mikecerdeiros@gmail.com8 B. The Specific Sections Of 14 C.F.R. From Which CERIOUS

PRODUCTIONS LLC. Seeks Exemption.

1. CERIOUS PRODUCTIONS LLC. Seeks Exemption From The

R equirements Of Section Part 21, Subpart H

14 C.F.R. Part 21, Subpart H, establishes the procedural requirements for the

issuance of airworthiness certificates as required by 14 C.F.R. §91.203(a)(1)

2. CERIOUS PRODUCTIONS LLC. Seeks Exemption From The

Requir ements Of Section 61.113(a) And (b).

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

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

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

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

hire; nor may that person, for compensation or hire, act as PIC of an aircraft.

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

connec tion with any business or employment if

—

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

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

hire.

3. CERIOUS PRODUCTIONS LLC. Seeks Exemption From The

Requirements Of Sect ion 91.7(a).

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

following:

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

4. CERIOUS PRODUCTIONS LLC. Seeks Exemption From The

Requirements Of S ection 91.121.

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

part:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight

level of that aircraft, as the case may be, by reference to an alti meter that is set,

when operating

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

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

within 100 nautical miles of the aircraft;

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

this section, the current reported altimeter setting of an appropriate

available station; or9 (iii) the case of an aircraft not equipped with a radio, the elevation of

the departure airport or an appropriate altimeter setting available

before departure.

5. CERIOUS PRO DUCTIONS LLC. Seeks Exemption From The

Requirements Of Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions

, subsection (b), states the following:

(b) No person may begin a flight in a rotorcraft under VFR conditions unl ess (considering wind and forecast weather conditions) there is enough fuel to fly

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

fly after that for at least 20 minutes.

6. CERIOUS PRODUCTIONS LLC. Seeks Exemption From The

Req uirement Of Section 91.405(a).

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

following: Each owner or operator of an aircraft

—

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

shall between re quired inspections, except as provided in paragraph (c) of this

section, have discrepancies repaired as prescribed in part 43 of this chapter[.]

7. CERIOUS PRODUCTIONS LLC. Seeks Exemption From The

Requirements Of Section 91.407(a)(1)

Section 91.407, entitl ed Operation after maintenance, preventive maintenance,

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

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

preventive maintenance, rebuilding, or alteration unless

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

43.7 of this chapter[.]

8. CERIOUS PRODUCTIONS LLC. Seeks Exemption From The

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

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

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

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

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

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

this chapter; or

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

with part 21 of this chapter.1

0 9. CERIOUS PRODUCTIONS LLC. Seeks Exemption From The

Requirements Of Sectio ns 91.417(a) And 91.417(b).

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

following:

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

registered owner or operator shall keep the following records fo r the periods

specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and

records of the 100

- hour, annual, progressive, and other required or

approved inspections, as appropriate, for each aircraft (in cluding 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 o f life

- limited parts of each airframe, engine,

propeller, rotor, and appliance.

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

are required to be overhauled on a specified time basis.

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

the last inspection required by the inspection program under which

the aircraft and its appliances are maintained.

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

safety directives including, for each, the meth od of compliance, the

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

directive involves recurring action, the time and date when the next

action is required.

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

major a lteration to the airframe and currently installed engines, rotors,

propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods

prescribed:

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

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

the work is performed.

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

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

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

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

aircraft is approved for return to service.10 C. The Extent Of Relief CERIOUS PRODUCTIONS LLC. Seeks And The Reason

CERIOUS P RODUCTIONS LLC. Seeks The Relief.

1. CERIOUS PRODUCTIONS LLC. Seeks Exemption From The Requirements

Of Section Part 21, Subpart H

Given the size and limited operating area associated with the UAS to be utilized by

CERIOUS PRODUCTIONS LLC. , an exemption from Part 21 Subpart H meets the

requirements of an equivalent level of safety under Part 11 and Section 333 of the

Reform Act.

The Federal Aviation Act (49 U.S.C.§ 44701(f)) and Section 333 of the Reform Act both

authorize the FAA to exempt aircraft from the requirement for an airworthiness

certificate, upon consideration of the size, weight, speed, operational capability, and

proximity to airports and populated areas of the particular UAS.

In all cases, an analysis of these criteria demonstrates that the UA S operated without an

airworthiness certificate, in the restricted environment and under the conditions proposed

will be at least as safe, or safer, than a conventional rotorcraft operating with an

airworthiness certificate without the restrictions and con ditions of the proposed UAS

operations.

2. Extent Of Relief CERIOUS PRODUCTIONS LLC. Seeks And The Reason

CERIOUS PRODUCTIONS LLC. Seeks Relief From Section 61.113(a) And

(b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limit ations:

Pilot in command , is requested to the extent necessary to allow a PIC holding a private

pilot or higher level certificate, as well as a current and valid airman medical certificate,

and who has met certain flight

- hour and currency requirements, to conduct the proposed

UAS flight operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state

that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection

wi th any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation

or hire.

As set forth more fully below, CERIOUS PRODUCTIONS LLC. submits that a n equivalent level of safety will be maintained because no PIC will be allowed to operate

the DJI Phantom 2 Vision+ UAS or DJI Inspire 1 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 2 Vision+ or 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,

ve ssels, vehicles and structures.11 Further, CERIOUS PRODUCTIONS LLC. submits that all flights of the DJI Phantom 2

Vision+ and DJI Inspire 1 UASs, conducted by the PIC pursuant to the grant of this

Petition: (1) will be incidental to CERIOUS PRODUCTIONS LLC. ' business; and (2)

will not carry passengers or property for compensation or hire.

3. Extent Of Relief CERIOUS PRODUCTIONS LLC. Seeks And The Reason

CERIOUS PRODUCTIONS LLC. Seeks Relief From Section 91.7(a)

.

Relief from Section 91.7(a) entitled Civil airc raft airworthiness , is requested to the extent

required to allow CERIOUS PRODUCTIONS LLC. to determine that the DJI Phantom 2

Vision+ and DJI Inspire 1 UASs are in airworthy condition prior to every flight by

ensuring that the UAS is in compliance with the operating documents (i.e., the CERIOUS

PRODUCTIONS LLC. Aerial Operations Manual, Monthly Maintenance Log, and DJI

Phantom 2 Vision+ and DJI Inspire 1 Instruction Manual).

CERIOUS PRODUCTIONS LLC. seeks the requested relief because the DJI Phantom 2

Visi on+ and DJI Inspire 1 UASs do not require an airworthiness certificate in accordance

with 14 C.F.R. Part 21, Subpart H. Therefore, CERIOUS PRODUCTIONS LLC. will

ensure that the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs are in airworthy

condition based u pon its compliance with the operating documents (i.e., Monthly

Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1 Instruction Manual)

prior to every flight, and further, determine that the aircraft are in condition for safe

flight, as stated in t he conditions and limitations below.

4. Extent Of Relief CERIOUS PRODUCTIONS LLC. Seeks And The Reason

CERIOUS PRODUCTIONS LLC. Seeks Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings , may be required to allow flight

operat ions of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data

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

station (GCS). Since the FAA requires that any altitude information concerning UAS

operations be reported to air traffic control (ATC) in feet above ground level (AGL),

CERIOUS PRODUCTIONS LLC. seeks the requested relief because the DJI Phantom 2

Vision+ and DJI Inspire 1 UA’s altimeter may be set on the ground to zero feet AGL,

rather than the local barometric pressure or field altitude, before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is

sought to the extent ne cessary to comply with the applicable conditions and limitations

stated below. As more fully set forth herein, an equivalent level of safety will be

maintained since the DJI Phantom 2 Vision+ and DJI Inspire 1 UAs are equipped with

a barometric pressure se nsor and GPS equipment, which automatically ensures that a

ground level pressure setting will be established prior to each flight, and provides the PIC

with altitude information of the UA on the heads

- up display of the GCS.12 5. Extent Of Relief CERIOUS PRODUC TIONS LLC. Seeks And The Reason

CERIOUS PRODUCTIONS LLC. Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is

requested to the extent required to allow flights of the battery powere d DJI Phantom 2

Vision+ and DJI Inspire 1 UAs during daylight hours in visual meteorological conditions

(VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to the first

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

least 4.5 minutes. CERIOUS PRODUCTIONS LLC. seeks the requested relief because

without an exemption from Section 91.151(b), the flight time duration of the battery

powered DJI Phantom 2 Vision+ and DJI Inspire 1 UAs will severely constrain the

practicality of any aerial video or still photo flight operations that CERIOUS

PRODUCTIONS LLC. proposes to conduct pursuant to this Petition.

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

Vision+ and D JI Inspire 1 UASs, the DJI Phantom 2 Vision+ and DJI Inspire 1 operating

documents, and CERIOUS PRODUCTIONS LLC. ’s proposed operating limitations,

ensure that CERIOUS PRODUCTIONS LLC. will safely operate the battery powered

DJI Phantom 2 Vision+ and DJI In spire 1 UAs during daylight hours in visual

meteorological conditions (VMC), under visual flight rules (VFR), with enough battery

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

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

6. Extent Of Relief CERIOUS PRODUCTIONS LLC. Seeks And The Reason

CERIOUS PRODUCTIONS LLC. Seeks Relief From Sections 91.405(a),

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

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only

apply to aircraft with an airworthiness certificate, CERIOUS PRODUCTIONS LLC.

requests relief from these Sections because the DJI Phantom 2 Vision+ and DJI Inspire 1

UASs do not require airworth iness certificates. As set forth more fully below, the DJI

Phantom 2 Vision+ and DJI Inspire 1 UASs meet the conditions of FMRA Section 333

for operation without an airworthiness certificate. Accordingly, CERIOUS

PRODUCTIONS LLC. will use trained technicia ns to perform maintenance, alterations,

or preventive maintenance on the UASs using the methods, techniques, and practices

prescribed in the UAS operating documents (i.e., the CERIOUS PRODUCTIONS LLC.

Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ and

DJI Inspire 1 Instruction Manual). Furthermore, CERIOUS PRODUCTIONS LLC. will

document and maintain all maintenance records for the DJI Phantom 2

Vision+ and DJI Inspire 1 UASs.13 D. The Reasons Why Granting CERIOUS PRODUCTIONS LLC. R equest Would

Be In The Public Interest; That Is, How It Would Benefit The Public As A Whole.

Granting the present Petition will further the public interest by allowing CERIOUS

PRODUCTIONS LLC. to safely, efficiently, and economically perform aerial video and

photography of, real estate, wedding films, special events, precision agriculture, land

survey & appraisal, construction sites, equipment & roof inspections, film sets and

landscape over certain areas of the United States.

Additionally, use of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs will decrease

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

Notably, the benefits of CERIOUS PRODUCTIONS LLC. ’s proposed operation of the

DJI Phantom 2 Vision+ and DJI Ins pire 1 UASs will be realized without implicating any

privacy issues.

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

The DJI Phantom 2 Vision+ and DJI Inspire 1 UAs are battery powered and serve as a

safe, efficient, and economical alternat ive to the manned aircraft traditionally utilized to

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

aerial acquisitions, an exemption allowing the use of a DJI Phantom 2 Vision+ or DJI

Inspire 1 UAS would reduce the amou nt of manned aircraft in the NAS, reduce noise and

air pollution, as well as increase the safety of life and property in the air and on the

ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS,

congestion around airports cau sed by arriving and departing aircraft will be reduced. The

DJI Phantom 2 Vision+ and DJI Inspire 1 UAs do not require an airport to takeoff or

land.

Likewise, a reduction of manned aircraft conducting aerial video and photography

missions would result in fewer aircraft that must be handled by air traffic control during

the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 2

Vision+ and DJI Inspire 1 UASs

.

Conducting aerial acquisitions with the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS’s,

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

levels of air and noise pollution generated during traditional aerial video an d still

photography flight operations. By using battery power and electric motors, the DJI

Phantom 2 Vision+ and DJI Inspire 1 UASs produce no air pollution, and is the most

viable environmentally conscious alternative to the cabin class, six cylinder inte rnal

combustion engine aircraft that are typically utilized for aerial video and photography,

while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The DJI

Phantom 2 Vision+ and DJI Inspire 1 UAs, while reducing the carbon footprint o f aerial

acquisitions, also eliminates noise pollution, as the UAs are propelled by battery powered

electric motors, rather than an internal combustion engine.14 By using the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS’s to perform aerial

acquisitions, the substantial risk to life and property in the air and on the ground, which is

usually associated with traditional manned aircraft flight operations, will be substantially

reduced or completely eliminated. Aside from the lack of flight crew members located

o nboard the aircraft, the DJI Phantom 2 Vision+ and DJI Inspire 1 UAs (weighing

approximately 2 pounds 11 ounces and 6 pounds 7.5 ounces respectively, at their

maximum gross weights with lengths of 16 inches and 17.3 inches respectively, widths of

16 inches and 17.7 inches respectively, and with no fuel on board), has less physical

potential for collateral damage to life and property on the ground, and in the air,

compared to the manned aircraft that typically conduct similar operations (weighing

approximate ly 6,000 pounds with a wingspan of approximately 42 feet, a length of 34

feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations With The DJI Phantom 2

Vision+ and DJI Inspire 1 UASs Will Benefit The Economy.

In addi tion to being safe and efficient, the DJI Phantom 2 Vision+ and DJI Inspire 1

UASs are also an economical alternative to using manned aircraft to conduct similar

aerial operations. As such, operation of the DJI Phantom 2 Vision+ and DJI Inspire 1

UASs will allow United States based companies, like CERIOUS PRODUCTIONS

LLC. , to remain competitive and contribute to growth of the U.S. economy. Specifically,

with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”)

regulatory actions phasing out leaded aviation fuels, U.S. owned and operated

companies must adopt new and alternative technology in order to remain competitive.

Operating the battery powered DJI Phantom 2 Vision+ and DJI Inspire 1 UASs is one

such technology that not only a llows companies greater operational flexibility compared

to manned aircraft, but provides such flexibility without the high operational cost of a

traditional manned aircraft.

By operating the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs, companies such as

CERIOUS PRODUCTIONS LLC. , can remain competitive and profitable, and therefore,

provide greater job stability to employees and contractors, which will ultimately

contribute to growth of the U.S. economy. Improved financial performance of U.S.

companies, t hrough commercial use of the DJI Phantom 2 Vision+ and DJI Inspire 1

UASs, provides a stable workforce that increases consumer spending; improves local,

state, and federal tax revenues; and allows companies to invest in research and

development in order to remain competitive both in the United States and abroad.

4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for

decades, CERIOUS PRODUCTIONS LLC. ’s proposed operation of the DJI Phantom 2

Vis ion+ and DJI Inspire 1 UASs will not implicate any privacy issues. Specifically, the

DJI Phantom 2 Vision+ and DJI Inspire 1 UASs will be operated only in compliance with

operating documents (i.e., the CERIOUS PRODUCTIONS LLC. Aerial Operations

Manual, Mon thly Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1

Instruction Manual) which requires15 property owner involvement as well as local law enforcement notification, and in

accordance with the Federal Aviation Regulations, including the minimum a ltitude

requirements of 14 C.F.R. § 91.119.16 E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety,

Or How The Exemption Would Provide A Level Of Safety At Least Equal To That

Provided By The Rule From Which CERIOUS PRODUCTIONS LLC. Seek s

Exemption.

1. Reasons Why The DJI Phantom 2 Vision+ and DJI Inspire 1 UAs Meet The

Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section

333.

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

u nmanned aircraft and its operation, CERIOUS PRODUCTIONS LLC. ’s operation of

the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS’s meet the conditions of FMRA

Section 333, and will not require an airworthiness certificate in accordance with 14

C.F.R. Part 21, S ubpart H.

Section 333 provides authority for a UAS to operate without airworthiness certification

and sets forth requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national secu rity. 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 i f certain unmanned aircraft systems may operate safely in the national airspace system before completion of the plan

and rulemaking required by section 332 of this Act or the guidance required

by section 334 of this Act.

(b) Assessment of Unmanned Aircraft Sy stems.

-- In making the determination

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

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

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

populated areas, and operation within visual line of sight do not create

a hazard to users of the national airspace system or the public or pose a threat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or airworthiness certif ication under section 44704 of title 49, United

States Code, is required for the operation of unmanned aircraft

systems identified under paragraph (1).

(c) Requirements for Safe Operation.

-- If the Secretary determines under this

section that certain unmanned aircraft systems may operate safely in the

national airspace system, the Secretary shall establish requirements for the

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

In seeking this exemption, CERIOUS PRODUCTIONS LLC. submits th at the DJI

Phantom 2 Vision+ and DJI Inspire 1 UASs can operate safely in the NAS pursuant to

FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI Phantom 2

Vision+ and DJI Inspire 1 UASs; (b) the pilot certification requirement; and (c ) the17 specific operating limitations.18 a. The Specifications Of The DJI Phantom 2 Vision+ and DJI Inspire 1 UASs

Demonstrate Its Safe Characteristics.

The DJI Phantom 2 Vision+ and DJI Inspire 1 UASs do not create a hazard to users of

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

weight, speed, and operational capability.

i. Technical Specifications Of The DJI Phantom 2 Vision+ and DJI Inspire 1 UASs.

The technical specifications of the DJI Phantom 2 Vision+ and DJ I Inspire 1 UASs are

set forth by the DJI Phantom 2 Vision+ and DJI Inspire 1 Specifications and Data Sheet,

attached hereto as Exhibit A and B

.

ii. The DJI Phantom 2 Vision+ and DJI Inspire 1 UASs Autonomous Flight And

Navigation Modes Enable The UASs To Rem ain Within A Defined Operational

Area.

The DJI Phantom 2 Vision+ and DJI Inspire 1 UASs may be operated in both manual and

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

modes of the DJI Phantom 2 Vision+ and DJI Inspi re 1 UASs are provided at pages 23

- 41 of the DJI Phantom 2 Vision+; and pages 12

- 18 and 45

- 52 of the DJI Inspire 1 User

Manuals, attached hereto as Exhibit C and D.

iii. The DJI Phantom 2 Vision+ and DJI Inspire 1 UASs Are Designed For

Automatic Return To Hom e Point Or Hover In The Event Of Loss Of The Control

Link Or Navigation.

When the Control Link is lost, the DJI Phantom 2 Vision+ and DJI Inspire 1 UAs will

remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 2

Vision+ and DJI Inspire 1 UAs do not reacquire control link data from the GCS, the UAs

will assume that the Control Link is lost and the UAs will return to the home position

(i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown. A

c omplete description of the Failsafe Functions for the DJI Phantom 2 Vision+ UAS are

set forth at pages 32 through 34 of the DJI Phantom 2 Vision+ User Manual; and for the

DJI Inspire 1 at pages 13 through 15 of the DJI Inspire 1 User Manual, attached heret o as

Exhibit C and D.

iv. The DJI Phantom 2 Vision+ and DJI Inspire 1 GCS And Its Operation.

A complete description of the operation and specifications of the DJI Phantom 2 Vision+

and DJI Inspire 1 GCS and flight control software is provided at pages 7 throu gh 17 of

the DJI Phantom 2 Vision+ User Manual; and pages 24 through 34 of the DJI Inspire 1

User Manual. DJI Phantom 2 Vision+ and DJI Inspire 1 User Manuals are attached hereto

as Exhibits C and D.

b. Flight Operations Of DJI Phantom 2 Vision+ and DJI Insp ire 1 UASs Are

Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety

Observer.

CERIOUS PRODUCTIONS LLC. will only utilize certificated pilots who possess a

current and valid19 airman medical certificate to act as a pilot in command (PIC) of the DJI Phantom 2

Vision+ and DJI Inspire 1 UASs. Additionally, a safety observer will assist all pilots

during flight time.

c. Flights Of DJI Phantom 2 Vision+ and DJI Inspire 1 UASs Will Be Conducted

Pursuant To Specific Operating Limitations.

In seeking this exemption, CERIOUS PRODUCTIONS LLC. proposes to

commercially operate DJI Phantom 2 Vision+ and DJI Inspire 1 UASs for the special

purpose of conducting aerial video and photography over certain areas of United

States, pursuant to the followin g specific operating limitations:

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

aircraft described in the operating documents, rotorcraft UASs weighing less than 55

pounds maximum gross weight: DJI Phantom 2 Vision+ and DJI Inspire 1 Unmanned

Aircraft Systems. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant.

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

purpose of aerial video and photography.

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

4. The UA must be operated at an altitude of no more than 500 feet above ground level

(AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved by ATC. All altitudes reported to ATC must be in

feet AGL.

5. The UAs must be operated within visual line of sight (VLOS) of the PIC at all times.

This requires the PIC to be able to use human vision unaided by any devic e other than

corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate.

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted.

7. All operations must utilize a safety observer (SO). The SO may be use d to satisfy the

VLOS requirement as long as the PIC always maintains VLOS capability. The SO and

PIC must be able to communicate verbally at all times. Electronic messaging or texting is

not permitted during flight operations. The PIC must be designated b efore the flight and

cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the SO can perform the functions prescribed in the operating documents.

8. The SO must not perform any other duties beyond assisting the PIC with seeing and

avoiding other air traffic and other ground based obstacles/obstructions and is not

permitted to operate the camera or other instruments.

9. The operating documents and the grant of exemption must be accessible during UAS20 operations and made available to the Administrator upon request. If a discrepancy exists

between the conditions and limitations contained in the grant of exemption and the

procedures outlined in the operating documents, the conditions and limitations contained

in the grant o f exemption take precedence and must be followed. Otherwise, the operator

must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such

revisi ons and present updated and revised documents to the Administrator upon request.

The operator must also present updated and revised documents if it petitions for

extension or amendment to the grant of exemption. If the operator determines that any update o r 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

revision s to the operating documents.

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for

safe flight. If the inspection reveals a condition that affects the safe operation of the UAS,

the aircraft is prohibited from operatin g until the necessary maintenance has been

performed and the UAS is found to be in a condition for safe flight. The Ground Control

Station must be included in the preflight inspection. All maintenance and alterations must

be properly documented in the airc raft records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS

operation or flight characteristics, e.g. replacement of a flight critical component, must

undergo a functional test flight. The PIC who conducts the functional test f light must

make an entry in the aircraft records.

12. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable

components, items, or equipment, not already covered in the relevant sections of the

operating documents.

13. The operat or 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 operat ing documents. Maintenance, inspection,

alterations, and status of replacement/overhaul component parts must be noted in the

aircraft records, including total time in service, description of work accomplished, and

the signature of the authorized person ret urning the UAS to service.

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

Bulletins.

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

action taken against discrepancies discovered between inspections.

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

class medical certificate.20 18. The operator may not permit any PIC to operate unless the PIC meets the operator’s

qualification criteria and demonstrates th e ability to safely operate the UAS in a manner

consistent with how the UAS will be operated under the exemption, including evasive

and emergency maneuvers and maintaining appropriate distances from persons, vessels,

vehicles and structures. PIC qualificat ion flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator’s

PICs are permitted under the terms of the exemption. However, training operations may only be conducted during dedicated t raining sessions. During training, proficiency, and

experience

- building flights, all persons not essential for flight operations are considered

nonparticipants, and the PIC must operate the UA with appropriate distance from

nonparticipants in accordance wi th 14 C.F.R. § 91.119.

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All

operations must be conducted under visual meteorological conditions (VMC). If flight at

night is required, a special request will be made at the FAA office closest to proposed

area of operations. Flights under special visual flight rules (SVFR) are not authorized.

20. The UA may not operate within 5 nautical miles of an airport reference point as

denoted on a current FAA

- published aeronautical chart unles s a letter of agreement with

that airport’s management is obtained, and the operation is conducted in accordance with

a NOTAM as required by the operator’s COA. The letter of agreement with the airport

management must be made available to the Administrator upon request.

21. The UA may not be operated less than 500 feet below or less than 2,000 feet

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

22. If the UA loses communications or loses its GPS signal, it must return to a p re

determined location within the planned operating area and land or be recovered in

accordance with the operating documents.

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

accordance with the operating documents.

24. Th e PIC is prohibited from beginning a flight unless (considering wind and forecast

weather conditions) there is enough power to fly at normal cruising speed to the intended

landing point and land the UA with 25% battery power remaining.

25. The operator must ob tain an Air Traffic Organization (ATO) issued Certificate of

Waiver or Authorization (COA) prior to conducting any operations under the grant of

exemption. This COA will also require the operator to request a Notice to Airman

(NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the

operation. All operations shall be conducted in accordance with airspace requirements in

the ATO issued COA including class of airspace, altitude level and potential transponder

requirements.

26. All aircraf t operated in accordance with the exemption must be identified by serial

number, registered in accordance with 14 C.F.R. part 47, and have identification (N

Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as pra cticable.21 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 requir ed fewer than 14 C.F.R. 91.9 and 91.203 must be available to

the PIC at the Ground Control Station of the UAS any time the UAS is operating. These

documents must be made available to the Administrator or any law enforcement official

upon request.

29. The UA m ust remain clear and yield the right of way to all manned aviation

operations and activities at all times.

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

31. Flight operations must be conducted at least 500 feet from all nonpartici pating

persons (persons other than the PIC, SO, operator trainees or essential persons), vessels,

vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from

the UA and/or debris in the event of an accident. The operator must ensure that

nonparticipating persons remain under such protection. If a situation arises where

nonparticipating persons leave such protection and are within 500 feet of the UA, flight

operations must cease immediately and/ or;

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller

of such vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determ ined that it

does not present an undue hazard, and;

c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present

an undue hazard to those persons per § 91.119(a).

32. All operations shall be conducted over private or controlled

- acce ss property with

permission from the land owner/controller or authorized representative. Permission from

land owner/controller or authorized representative will be obtained for each flight to be

conducted.

33. Any incident, accident, or flight operation that transgresses the lateral or vertical

boundaries of the operational area as defined by the applicable COA must be reported to

the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents must be reported

to the National Transportation Safety Board ( NTSB) per instructions contained on the

NTSB Web site: www.ntsb.gov

.

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And

(b) Would Not Adversely Affect Safety.

CERIOUS PRODUCTIONS LLC. submits t hat the equivalent level of safety

established by Section 61.113(a) and (b) will be maintained because no PIC will be

allowed to operate the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs unless that PIC

has demonstrated, by22 meeting minimum flight

- hour and currency requirements, that the PIC is able to safely

operate the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS in a manner consistent with the

exemption, including evasive and emergency maneuvers and maintaining appropriate

distances from people, vessels, ve hicles and structures.

Considering CERIOUS PRODUCTIONS LLC. ’s proposed area of operations,

and the operating limitations set forth

- above; the parallel nature of private pilot

aeronautical knowledge requirements to those of commercial pilot requirements (S ee

Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI

Phantom 2 Vision+ or DJI Inspire 1 UAS, CERIOUS PRODUCTIONS LLC. submits

that the additional manned airmanship experience of a commercially certificated pilot

would not correlate to the airmanship skills necessary for CERIOUS PRODUCTIONS

LLC. ’s specific proposed flight operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to

UAS, in circumstances similar, in all material respects, to t hose presented herein (e.g.

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110,

11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

CERIOUS PRODUCTIONS LLC. will not allow any PIC to operate the DJI

Phantom 2 V ision+ or DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting

minimum flight

- hour requirements or the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS

training and currency requirements, that the PIC is able to safely operate the DJI Phantom

2 Vision+ or DJI Inspire 1 UAS in a manner consistent with this exemption, including

evasive and emergency maneuvers and maintaining appropriate distances from people,

vessels, vehicles and structures.

Specifically, the PIC must have accumulated and logged, in a m anner consistent

with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot operating the same make and model of

UAS to be used for operations under the exemption). In addition to th e hour

requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days

(for currency purposes).

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight

experience that was obtained in compliance with applicable regulat ions will ensure an

equivalent level of safety during CERIOUS PRODUCTIONS LLC. ’ proposed

operations. The Administrator has held that prior documented flight experience that was

obtained in compliance with applicable regulations would ensure safe operations , stating

as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for

the purpose of motion picture filming (or similar operations), the PIC must have

accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total

time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a

multi

- rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have

accumulated and logged a minimum of 5 hours as a UAS pilot operat ing the same make

and model of UAS to be used for operations under the exemption. For clarification, the23 FAA considers these minimum hour requirements to be inclusive rather than additive; i.e.

5 hours make and model time may be included in the 10 hours o f multi

- rotor time and the

10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the

hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90

days (for currency purposes). The FAA finds that at a minimum, the flight

- hour

requirements in Exemption No. 11062 are appropriate to practice and build proficiency in

the skills necessary to safely conduct the petitioner’s proposed operations. The FAA also

finds that prior documented flight experience that was obtained in compliance with

applicable regulations would satisfy this requirement. Training, proficiency, and

experience

- building flights can also be conducted under the grant of exemption to

accomplish the required flight time. During training, profi ciency, and experience

- building

flights the PIC is required to operate the UA with appropriate distances in accordance

with 14 C.F.R 91.119.

Exemption No. 11138 at page 15.

Accordingly, CERIOUS PRODUCTIONS LLC. will ensure safe operations by

not allowing any PIC to operate the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS unless

that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements,

that the PIC is able to safely operate the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS in

a manner consistent with the exemption, including evasive and emergency maneuvers

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

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a)

Would Not Adversely Affect Safe ty.

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

because prior to every flight, CERIOUS PRODUCTIONS LLC. will ensure that the DJI

Phantom 2 Vision+ or DJI Inspire 1 UAS is in an airworthy condition based upon the

UAS’s compliance with its operating documents and as stated in the conditions and

limitations herein.

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

to UAS, in circumstances similar, in all material respects, to those presented herein (e.g.

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110,

11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would

Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained

because the altitude information of the DJI Phantom 2 Vision+ and DJI Inspire 1 UAs

will be provided to the PIC via GPS equipment and a radio communications tel emetry

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

path and altitude. This altitude information, combined with CERIOUS PRODUCTIONS

LLC. ’ operation of the DJI Phantom 2 Vision+ and DJI Inspire 1 UAs within visual li ne of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section

91.121. The altitude information will be generated by GPS equipment installed onboard

the aircraft.24 Prior to each flight, a zero altitude initiation point is automa tically 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, 1106 6, 11067, 11080, 11109, 11112, 11136, 11138,

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

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b)

Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equival ent level of safety established

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

Phantom 2 Vision+ and DJI Inspire 1 UASs; (2) the limitations on the proposed flight

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

CERIOUS PRODUCTIONS LLC. will ensure that it will safely operate the battery

powered DJI Phantom 2 Vision+ and DJI Inspire 1 UAs during daylight hours in VFR

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

first point of intended landing and, assuming normal cruising speed, to fly after that for

at least 4.5 minutes.

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

2 Vision+ and DJI Inspire 1 UASs; the limitations on the proposed flight operations; and

the location of the proposed operations, will ensure an equivalent level of safety

established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the

DJI Phantom 2 Vision+ and DJI Inspi re 1 UASs provide audible and visual warnings to

the PIC at the GCS when the UAs experiences low battery voltage, the first warning

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

10% remaining battery power. At the criti cally low battery level, the DJI Phantom

Vision+ and DJI Inspire 1 UASs will descend and land automatically.

Significantly, previous exemptions granted by the FAA concerning Section

91.151 establish that safety is not adversely affected when the technical characteristics

and operating limitations of the UAS are considered. Relief has been granted for manned

aircraft to operate at less than the minimums prescribed in Section 91.151, including

Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previ ously granted

relief from Section 91.151 specific to UAS, in circumstances similar, in all material

respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042,

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11 138, 11150,

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

6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect

Safety.

In seeking this exemption, CER IOUS PRODUCTIONS LLC. submits that the

equivalent level of safety with regard to the regulatory maintenance and alteration

requirements established25 by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be

met because CERIOUS PRODUCTIONS LLC. will use trained technicians to perform

maintenance, alterations, or preventive maintenance on the UASs using the methods,

techniques, and practices prescribed in the operating documents (i.e., the CERIOUS

PRODUCTIONS LLC. Aerial Operatio ns Manual, Monthly Maintenance Log, and DJI

Phantom 2 Vision+ and DJI Inspire 1 Instruction Manual). Furthermore, CERIOUS

PRODUCTIONS LLC. will document and maintain all maintenance records for the DJI

Phantom 2 Vision+ and DJI Inspire 1 UASs.

Since the D JI Phantom 2 Vision+ and DJI Inspire 1 UASs will be inspected as

prescribed by the operating documents, CERIOUS PRODUCTIONS LLC. will maintain

the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and

91.409(a)(2). A copy of the D JI Phantom 2 Vision+ and DJI Inspire 1 User Manuals are

attached hereto as Exhibit C and D ; a copy of the DJI Phantom 2 Vision+ and DJI Inspire

1 UAS Maintenance LOG is attached hereto as Exhibit E

.

Likewise, the exemption sought will not adversely affect safety because

CERIOUS PRODUCTIONS LLC. will use trained technicians to perform maintenance,

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

practices prescribed by the operating documents.

Furthermore, the exemption s ought would maintain an equivalent level of safety

established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the

DJI Phantom 2 Vision+ and DJI Inspire 1 UASs will be performed by trained technicians.

Maintenance will be documented and maintained utilizing the monthly maintenance log.

Significantly, previous exemptions granted by the FAA concerning Sections

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

is not adversely affected when the t echnical characteristics and operating limitations of

the UAS are considered.

In consideration of CERIOUS PRODUCTIONS LLC. ’s proposed operating

limitations, the operating documents, and the technical aspects of the DJI Phantom 2

Vision+ and DJI Inspire 1 UAS’s, CERIOUS PRODUCTIONS LLC. submits that safety

will not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a),

91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously

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

presented herein (e.g.

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110,

11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

7. The FAA May Pre scribe Any Other Conditions For Safe Operation.

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

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

PRODUCTIONS LLC. requests that the FAA prescribe special condi tions for the

intended operation of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs, which contain

such safety standards that the Administrator finds necessary to establish a level of safety26 equivalent to that established27 by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121,

91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such

special conditions will permit safe operation of the UAs for the limited purpose of

conducting aerial video and photogr aphy over certain areas of the United States for

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

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

threat to national security; and f urther, provides the authority for such UAS to operate

without airworthiness certification in accordance with any requirements that must be

established for the safe operation of the UAS in the NAS.

Likewise, the Administrator may prescribe special conditi ons pursuant to 14

C.F.R. § 21.16, for operation of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs,

since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design 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 aircraft, aircraft engine, or prope ller

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

he prescribes special conditions and amendments thereto for the product. The special

conditions are issued in accordance with Part 11 of this chapter and conta in such safety

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

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

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for Leading Edge’s intended operation of the DJI Phantom 2

Vision+ and DJI Inspire 1 UASs, which contain such safety standards that the

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

by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121,

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

F. A Summary That Can Be Published In The Federal Registe r, stating:

The Rules From Which CERIOUS PRODUCTIONS LLC. Seeks

Exemption:

CERIOUS PRODUCTIONS LLC. 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 CERIOUS

PRODUCTIONS LLC. Seeks:

This exemption will permit CERIOUS PRODUCTIONS LLC. to commercially operate an

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

photography over certain areas of the United States.28 Any Additional Information, Views, Or Arguments Available To Support

CERIOUS PRODUCTIONS LLC. ’s Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012

(FMRA) Section 3 33, which directs the Secretary of Transportation to determine if

certain UAS may operate safely in the NAS. As such, CERIOUS PRODUCTIONS

LLC. ’s request for exemption may be granted pursuant to the authority of FMRA Section

333 and 14 C.F.R. Part 11, as se t forth above. FMRA Section 333 sets forth the

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

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

authority for such UAS to operate w ithout airworthiness certification. As discussed in

detail above, CERIOUS PRODUCTIONS LLC. will operate the DJI Phantom 2 Vision+

and DJI Inspire 1 UASs safely in the NAS, without creating a hazard to users of the

NAS, or the public, or otherwise pose a th reat to national security.29 Conclusion

As set forth her e in, CERIOUS PRODUCTIONS LLC. seeks an exemption pursuant to 14 C.F.R. §

11.61	and	section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	(FMRA),	which	will	permit	safe

operation	of	the	DJI	Phant om	2	Vision	+	and	DJI	Inspire	1	UAS’s	commercially,	Without	an	airworthiness

certificate,	for	the	limited	purpose	of	conducting	aerial	video	and	photography	over	certain	areas	of

United	States,	By	granting	this	petition	the	FAA	administrator	will	be	fulfi lling	the	congressional	mandate

of	the	FAA	Modernization	and	reform	act	of	2012,	while	also	advancing		the	interests	of	the	public,	by

allowing Cerious	Productions	LLC. to	safely	efficiently and	economically	operate	the	DJI	Phantom	2	Vision

Plus	and	DJI	In spire	1	UASs	commercially	whine	the	NAS.

Wherefore,	in	accordance	with	the	Federal	Aviation	Regulations	and	the	FAA	Modernization	and	reform

act	of	2012,	Section	333 Cerious	Productions	LLC. respectfully	requests	that	the	administrator	grant	this

petition for	an	example	from	the	requirements	of	14	C.F.R.	Sections	61.113(a)	&	(b)	91,7(a),	91.121,

91.151(b),	91.405(a),	91.407(a)(1),	91 .409(a)(1)	&	(a)(2)	,	and	91.417(a)	&	(b)		and	permit Cerious

Productions	LLC. to	operate	the	DJI	Phantom	2	Vision	+	and	DJI Inspire	1	UAS	commercially	for	the	purpose

of	conducting	aerial	video	and	photography	over	certain	areas	of	the	united	states.

June	1 9 2015

Respectfully	Submitted

Cerious	Productions	LLC.



# Michael Cerdeiros

____________________ Michael Cerdeiros , (Own er)

9468 Descending Creek St.

Las Vegas NV 89123

917

- 470

- 4220

Appendices

A

- DJI Phantom 2 Vision+

B

- DJI Inspire 1 Specifications Data Sheet

C

- DJI Phantom 2 Manufactures User Manual

D

- DJI Inspire 1 manufacturer’s User Manual

E

- Monthly Maintenance Log30 APPENDIX

– A

DJI PHANTOM 2 VISION+ TECHNICAL SPECIFICATIONS

CERIOUS PRODUCTIONS LLC. only utilizes safe and reliable UASs. DJI is an

industry leader in small UAS production. DJI UASs are loaded with ground breaking

software enabling the user to set parameters which wi ll not allow flight into controlled

airspace. Parameters can also be set to limit flight to no higher than a predetermined and

set altitude as well as limit flight to a predetermined and set distance. In addition, DJI

software provides real

- time altitude a nd location information to the PIC via the linked

monitor (smart phone/tablet devices)

1.1 DJI Phantom 2 Vision+

1.1.1 Aircraft

1.1.1.1 Supported Battery

– DJI 5200mAH LiPo Battery

1.1.1.2 Weight (Battery & Propellers Included)

– 2lbs 11.810oz (1242g)

1.1.1.3 Hover Accuracy (Ready to Fl y)

– Vertical: .8m; Horizontal: 2.5m

1.1.1.4 Max Yaw Angular Velocity

- 200 0 /s

1.1.1.5 Max Tilt Angel

- 35 0

1.1.1.6 Max Ascent Speed

– 6m/s

1.1.1.7 Max Descent Speed

– 2m/s

1.1.1.8 Max Flight Speed

– 15m/s (NOT RECOMMENDED)

1.1.2 Gimbal

1.1.2.1 Working Current

– Static: 750mA; Dynamic: 900mA

1.1.2.2 Control Accuracy

- ±0.03 0

1.1.2.3 Controllable Range

– Pitch:

- 90 0

- 0 0

1.1.2.4 Maximum Angular Speed

– Pitch: 90 0 /s

1.1.3 Camera

1.1.3.1 Operating Temperature Range

- 32 0 F

- 104 0 F (0 0 C

- 40 0 C)

1.1.3.2 Sensor Size

– 1/2.3”

1.1.3.3 Effective Pixels

– 14M

1.1.3.4 Resolution

– 4384x3288

1.1.3.5 HD Video Recording

– 1080p30 & 720p

1.1.3.6 Reco rding Field of View

- 110 0 /85 0

1.1.4 Transmitter

1.1.4.1 Operating Frequency

– 5.728GHz

– 5.85GHz

1.1.4.2 Communication Distance (unobstructed)

– FCC Compliance: 800m

1.1.4.3 Receiver Sensitivity (1%PER)

- - 93dBm

1.1.4.4 Transmitter Power

– FCC Compliance: 100mW

1.1.4.5 Working Voltage

– 120mA@3.7V30 1.1.5 Range Extender

1.1.5.1 Operating Frequency

– 2412

- 2462MHz

1.1.5.2 Communication Distance (unobstructed)

– 500

- 700m

1.1.5.3 Transmitter Power

– 20dBm

1.1.5.4 Power Consumption

– 2W31 APPENDIX

– B

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

CERIOUS PRODUCTI ONS LLC. only utilizes safe and reliable UASs. DJI is an

industry leader in small UAS production. DJI UASs are loaded with ground breaking

software enabling the user to set parameters which will not allow flight into controlled

airspace. Parameters can als o be set to limit flight to no higher than a predetermined and

set altitude as well as limit flight to a predetermined and set distance. In addition, DJI

software provides real

- time altitude and location information to the PIC via the linked

monitor (smart phone/tablet devices)

2.2 DJI Inspire 1

2.2.1 Aircraft

2.2.1.1 Model

– T600

2.2.1.2 Weight (Battery Included)

– 6lbs 7.5291oz (2935g)

2.2.1.3 Hovering Accuracy (GPS Mode)

– Vertical: 0.5m; Horizontal: 2.5m

2.2.1.4 Max Angular Velocity

– Pitch: 3000/s; Yaw: 1500/s

2.2.1.5 Max Tilt Angle

- 350

2.2.1.6 Max Ascen t Speed

– 5m/s

2.2.1.7 Max Descent Speed

– 4m/s

2.2.1.8 Max Speed

– 22m/s (ATTI mode, no wind

– NOT RECOMMENDED)

2.2.1.9 Max Flight Altitude

– 4500m

2.2.1.10 Max Wind Resistance

– 10m/s

2.2.1.11 Max Flight Time

– Approximately 18 minutes

2.2.1.12 Motor Model

– DJI 3510

2.2.1.13 Propeller Model

– DJI 1345

2.2.1.14 Operating Temperature Range

– 140F to 1040F (

- 100C to 400C)

2.2.1.15 Dimensions

– 17 1⁄4” x 17 3⁄4” x 12”

2.2.2 Gimbal

2.2.2.1 Model

– ZENMUSE X3

2.2.2.2 Output Power (with camera)

– Static: 9W; In Motion: 11W

2.2.2.3 Operating Current

– Static: 750mA; In Motion: 900mA

2.2.2.4 Angular Vibration Range

- ±0.030

2.2.2.5 Mounting

– Detachable

2.2.2.6 Controllable Range

– Pitch:

- 900 to +300; Pan: ±3200

2.2.2.7 Mechanical Range

– Pitch:

- 1250 to 450; Pan: ±3300

2.2.2.8 Max Controllable Speed

– Pitch: 1200/s; Pan: 1800/s

2.2.3 Camera

2.2.3.1 Name

– X3

2.2.3.2 Model

– FC350

2.2.3.3 Total Pixels

– 12.76M32 2.2.3.4 Effective Pixels

– 12.4M

2.2.3.5 Image Max Size

– 4000x3000

2.2.3.6 ISO R ange

– 100

- 3200

2.2.3.7 Field of View

- 940

2.2.3.8 CMOS

– Sony EXMOR 1/2.3”

2.2.3.9 HD Video Recording

– UHD(4K):

4096x2160p24/25, 3840x2160p24/25/30; FHD: 1920x1080p24/25/30/48/50/60;

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

2.2.3.10 Operating Temperature Range

- 320F

- 1040F (00C

- 400C)

2.2.4 Transmitter

2.2.4.1 Name

– C1

2.2.4.2 Operating Frequency

– 5.728

- 5.850GHz; 2.400

- 2.483GHz

2.2.4.3 Communicating Distance (unobstructed)

– 2000m

2.2.4.4 Output Power

– 9W

2.2.4.5 Operating Temperature Range

- 140F to 1040F (

- 100C to 400C)

2.2.4.6 Battery

– 600mAh LiPo 2S33 APPENDIX

- C



### DJI PHANT OM 2 VISION+ Manufacturer’s User Manual

User manual can be found at:

http://www.dji.com/product/phantom

- 2

- vision/download

APPENDIX

- D



### DJI Inspire 1 Manufacturer’s User Man ual

User manual can be found at:

http://www.dji.com/product/inspire

- 1/download34 APPENDIX

- E

MONTHLY(MAINTENANCE(LOG

month:' ''year:''

UAS(#:( Date'Issue

Discover d Date'Issue

Addre ssed Issue''Description'&'Maintenance'Conducted Maintenance'Performed'by:''

Print'&'Sign

Software'Updates

Airframe

Engines

Propellers

Camera'Gimbal

Landing'Gear

Vibration'Dampening

Other: