UNITED ST AT ES OF AMERI CA DEP AR TMENTOF TRANSPOR TA TI ON FEDERAL

A VI AT IO N ADMINISTRA TI ON WA SHI NGT ON, DC

Regulatory

Docket No. _______________

IN THE MA

TTER OF THE PETITION FOR EXEMPTI ON OF: JAROMI R RIVERA

FOR AN EXEMPTION SEEKING R ELIEF FROM THE REQUIREMENTS OF TI TLE 14 OF THE CODE OF FEDERAL

REGULA

TI ONS SECTI ONS 61.1 13(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNI NG COMMERCIAL OPERA TI ON OF DJ I PHANT OM 3 AND DJ I INSPI RE 1 UNMANNED AI RCRAFTSYSTEMS PURSUANTTO SECTION 333 OF THE F AA MODERNIZA

TI ON AND REFORM ACTOF 2012 (PUBLIC LA

W 1 12

- 95)

Submitted on July

13 , 2015

JAROMI R RIVERA 2891 ROUTE 22 PA TTERSON, NY

12563 (813)

- 313

- 9939TA BLE OF CONTENTS Page

GLOSSAR

Y OF ABBREVIA

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

SUMMAR

Y.

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

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

BACKGROUND..................................................................................................................... 5

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

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

THE SPECI FI C SECTIONS OF 14 C.F .R. FROM WHI CH JAROMI R RIVERA SEEKS EXEMPTI ON.........................

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

THE EXTENT OF RELIEF JAROMI R RIVERA SEEKS AND THE REASON JAROMIR RIVERA SEEKS THE RELIEF...

..................... 9

THE REASONS WHY

GRANTING JAROMI R RIVERA REQUEST WOUL D BE IN THE PUBLIC INTEREST

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

THE REASONS WHY

GRANTING THE EXEMPTI ON WOULD NOT ADVERSEL

Y A FFECTSAFETY

................................................ ..............................12

CONCLUSION.................................................................................................... ...................19GLOSSAR Y OF ABBREVIA

TI ONS

AGL Above Ground Level AOI Area of Interest AT C Air T

raffic Control AT O Air T

raffic Organization AV Aerial V

ehicle CFR Code of Federal Regulations COA Certificate of Authorization FA A Federal Av iation Administration FA R Federal Av iation Regulation GCS Ground Control Station GPS Global Positioning Sy stem LO L Loss of Link NAS National Airspace S ys tem NOT AM Notice to Airman PI C Pilot In Command Section 333 FA A Modernization and Reform Act of 2012 (FMRA) SO Safety

Observer SOP Standard Operating Procedures UA Unmanned Aircraft UAS Unmanned Aircraft Sy stem VFR Vi sual Fl ight Rules VLOS Vi sual L ine of Site VMC Vi sual Meteorological Conditions VTOL Ve rtical T

akeof f and Landing DJI UA

V manufacturer ESC Electronic speed control FPV First Person V iew LI

- PO Lithium Poly mer battery RCV Radio Controlled vehicle**SUMMAR Y** 

JAROMI R RIVERA seeks exemption from the requirements of 14 C.F .R §§ 61.1 13(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft Sy stem pursuant to Section 333 of the F AA Modernization and Reform Act of 2012 (FMRA). This exemption will permit JA ROMI R RIVERA to operate an Unmanned Aircraft Sy stem (UAS) for the commercial purpose of conducting ae r ial video and photography for m arketing, film sets, real estate photograph y, commercials, special events, wedding cinematography , and landscape over certain areas of the United States.

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

My name is JAROMI R RIVERA , and I am a drone builder and operator (pilot) with expertise and knowledge in aspects of building programing and operating multiple ty pes of UAS'S along with camera set up and operation. JA ROMI R RIVERA also provides clients with the highest qualit y digital content for use in their commercial, personal, and non

- profit multimedia projects. JAROMI R RIVERA has 4

ye ars of RCV

experience and 5 y ears of radio controlled helicopter experience.

The objective of JAROMIR RIVERA ’ aerial video and photograph y operations is to provide high quality imaging for a variety

of commercial, public, and residential uses, along with test repaired drones for clients in a safe testing location away fro m all obstacles and people at all times. JAROMIR RIVERA will also provi de knowledge of UAS and promote safe UAS operations.**BACKGROUND**

Unmanned Aircraft Sy stems: DJIPhantom 3, DJ I Inspire 1 UASs JAROMI R RIVERA seeks an exemption to operate DJ I sy stems for compensation or hire within the NAS. The DJ I Phantom 3 and DJ I Inspire 1 are vertical takeof f and landing (VT OL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone s ys tems. The DJ I Phantom 3 has a maximum gross weight of approximately 2 pounds 14 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 DJ I 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 1 1.8 inches, and a maximum speed of approximately 42 knots. The DJI Phantom 3 and DJII nspire 1UAs are equipped with four main rotors; driven by L ithium Poly

mer batter y powered electric motors.

The DJ I Phantom 3 and DJII nspire 1 UAs that will be operated by JAROMI R RIVERA 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 Markings.

**BASIS FOR PETITION**

Petitioner
, JAROMI R RIVERA , pursuant to the provisions of the Federal Av iation Regulations (14 C.F .R. § 1 1.61) and the F

AA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Sy stems, hereby petitions the Administrator to commercially operate the DJ I Phantom 3, DJII nspire 1 UASs in the National Airspace S ystem (NAS), and for an exemption from the requirem ents of 14 C.F .R §§ 61.1 13(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its o peration, JAROMI R RIVERA operation of DJ I Phantom 3 and DJ I Inspire 1 UASs meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F .R. Part 21, Subpart H.

Accordingly

, JAROMI R RIVERA 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 onl y apply to aircraft with an airworthiness certificate.

JAROMI R RIVERA submits that the r equested relief is proper since an equivalent level of safet y will be ensured. JAROMI R RIVERA will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practi ces prescribed in the operating documents (i.e., Monthly Maintenance L og, and DJ I Phantom 3 and DJ I Inspire 1 Instruction Manual). Furthermore, JAROMI R RIVERA will document and maintain all maintenance records for the DJ I Phantom 3 and DJII nspire 1 UASs.

Relief from certain requirements of Section 61.1 13(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested b y JAROMI R RIVERA to the extent necessary to allow a Pilot in Command (PI C) holding a private pilot or higher level certificate, as well as an airman medical certificate, and who has demonstrated, b y meeting minimum flight

- hour and currency requirements, that the PI C is able to safely operate the DJ I Phantom 3 and DJ I Inspire 1 UASs in a manner consistentwith this exemption, including evasive and emergency maneuvers and maintaining appropriate

distances from people, vessels, vehicles and structures.

JAROMI R RIVERA seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the DJIPhanto m 3 and DJ I Inspire 1 UASs do not require an airworthiness certificate in accordance with 14 C.F .R. Part 21, Subpart H. As such, JAROMI R RIVERA submits that he will ensure that the DJ I Phantom 3 and DJII nspire 1UASs 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 DJIPhantom 3 and DJ I Inspire 1 Instruction Manual), and that the aircraft are in a condition for safe flight.

JAROMI R RIVERA also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings, as the DJIPhantom 3 and DJ I Inspire 1 UAs will not have a t ypical barometric altimeter onboard. However, altitude information of the DJ I Phantom 3 and DJII nspi re 1UAs will be provided to the PI C via Global Positioning Sy stem (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 JAROMI R RIVERA operation of the DJ I Phantom 3 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

, JAROMI R RIVERA seeks an exemption from the requirements of Sec tion 91.151(b), entitled Fuel requirements for flight in VFR conditions. JAROMI R RIVERA submits that safet y will not be af fected b y operation of the DJ I Phantom 3 and DJ I Inspire 1 UAs during day light hours in visual meteorological conditions (VMC) under v isual flight rules (VFR), with enough battery power to fly for a total duration of approximately 15.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fl y after that for at least 4.5 minutes.

In accordance with 14 C .F .R. § 1 1.81, JAROMI R RIVERA provides the following information in support of its petition for exemption:

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

**.** The name and address of the Petitioner and point of contact is: JAROMI R RIVERA 2891 ROUTE 22 PA T TERSON, NY

12563 ( 813 )

- 313

- 9939 Email: jaromirrivera@gmail.com**B. The**  **Specific Sections Of 14 C.F .R. f**  **ro m Which**  **JAROMIR RIVERA Seeks Exemption.** 

**1. JAROMIR RIVERA**  **Seeks Exemption Fr om**  **The Requir ements Of Section 61.1**  **13(a) And**  **(b).** Section 61.1 13, 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 (PI C) of an aircraft that is carry ing passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PI C of an aircraft. b. A private pilot may

, for compensation or hire, act as PI C of an aircraft in connection with any business or employ

ment if

— i. The flight is onl y incidental to that business or employment; and ii. The aircraft does not carry passengers or property

for compensation or hire. **2. JAROMIR RIVERA**  **Seeks Exemption Fr om**  **The Requir ements Of Section 91.7(a).**  Section 91.7, entitled civil aircraft airworthiness, subsection (a), stat es the following: (a) No person may

operate a civil aircraft unless it is in an airworthy condition. **3. JAROMIR RIVERA**  **Seeks Exemption Fr om**  **The Requi re**  **ments Of Section 91.121.** Section 91.121, entitled Altimeter settings, subsection ( a), states the following, in part:

a. Each person operating an aircraft shall maintain th e cruising altitude or flight level of that aircraft, as the case may be, by referen ce to an altimeter that is set, when operating

-- Below 18,000 feet MSL, to

— i. The current reported altimeter setting of a station along the route and within 100

n autical miles of the aircraft; ii. If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; iii. In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before depar ture. **4. JAROMIR RIVERA**  **Seeks Exemption Fr om**  **The Requir ements 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 r otor craft under VFR con di tions unless (considering wind and for ecast weather conditions) ther e is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly afte r that for at least 20 minutes. **5. JAROMIR RIVERA**  **Seeks Exemption Fr om**  **The Requir ement Of Section 91.405(a).**  Section 91.405, entitled Maintenance required, subsection (a), s tates the following: Each owner or operator of an aircraft

— (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.] **6. JAROMIR RIVERA**  **Seeks Exemption Fr om**  **The Requir ements**  **Of Section 91.407(a)**  Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration, subsection (a)(1), states the following: (a) No person may operate any

aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alterat ion unless

-- (1) It has been approved for return to service b y a person authorized un der § 43.7 of this chapter [.] **7. JAROMIR RIVERA**  **Seeks Exemption Fr om**  **The Requir ements Of Sections 91.409(a)(1)**  **And 91.409(a)(2).** Section 91.409, entitled Inspections, subsection (a), states the following: (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless,within the preceding 12 calendar months, it has had

--

(1) An annual inspecti on in accordance with part 43 of this chapter and has been approved for return to service b y a person authorized by § 43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter

. **8. JAROMIR RIVERA**  **Seeks Exemption Fr om**  **The Requir ements 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 §§ 91.41 1 and 91.413, eac h registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: Records of the maintenance, preventive maintenance, and alteration and records of the 100

- hour, annual, progressive, and other requ ired or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include

— i. A description (or reference to data acceptable to the Administrat or) of the work performed; and ii. The date of complet ion of the work performed; and iii. The signature, and certificate number of the person approving the aircraft for return to service. Records containing the following information:

1. The total time in service of the airframe, each engine, each propeller, and each rotor

. 2. The current status of life

- limited parts of each airframe, engine, propeller
, rotor, and appliance. 3. The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. 4. 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. 5. The current status of applicable airworthines s directives (AD) and safet y directives including, for each, the method of compliance, the AD or safet y directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required. 6. Copies of the forms prescribed b y § 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances. b. The owner or operator shall retain the following records for the periods prescribed: i. Th e records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded b y other work or for 1 ye ar after the work is performed. ii. The records specified in paragraph (a)(2) of this section shall be retained and tr ansferred with the aircraft at the time the aircraft is sold. iii. A list of defects furnished to a registered owner or operator under § 43.1 1 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.**C. The Extent Of Relief JAROMIR RIVERA**  **Seeks And**  **The Reason JAROMIR RIVERA**  **Seeks**

**The Relief. 1.**  **Extent Of Relief JAROMIR RIVERA**  **Seeks And**  **The Reason JAROMIR RIVERA**  **Seeks Relief Fr**  **om Section 61.1**  **13(a) And (b).**  Relief from Section 61.1 13(a) and (b) entitled Private pilot privileges and limitations: Pilot in command, is requested to the extent necessary to allow a PI C holding a private pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met certain flight

- hour and currenc y requirements, to conduct the proposed UAS flight operations for compensation or hire. This relief is requested since the limitations set forth in S ection 61.1 13(a) and (b) state that a private pilot may

, for compensation or hire , act as PI C of an aircraft in connection with an y business or employ

ment if: (1) The flight is only incidental to that business or employ ment; and (2) The aircraft does not carry passengers or prop erty for compensation or hire. As set forth more full y be low
, JAROMI R RIVERA submits that an equivalent level of safet y will be maintained because no PI C will be allowed to operate the DJ I Phantom 3 UAS or DJI Inspire 1 UAS unless that PI C has met certain flight

- hour and currency requir ements, demonstrating that the PIC is able to safel y operate either the DJ I Phantom 3 or DJ I Inspire 1 UAS in a manner consistent with the operations specifications a s described in this exemption, including evasive and emergency maneuvers, as well as maintain ing appropriate distanc es from people, vessels, vehicles and structures. Further
, JAROMI R RIVERA submits that all flights of the DJ I Phantom 3 and DJ I Inspire 1 UASs, conducted b y the PI C pursuant to the grant of this Petition: (1) will be incidental to JAROMI R RIVERA ' business ; and (2) will not carry passengers or propert y for compensation or hire. **2. Extent Of Relief**  **JAROMIR RIVERA Seeks**  **And The Reason**  **JAROMIR RIVERA Seeks**  **Relief Fr om** **Section 91.7(a).** Relief from Section 91.7(a) entitled Civil aircraft airw orthiness, is requested to the extent required to allow JAROMI R RIVERA to determine that the DJ I Phantom 3 and DJ I Inspire 1 UASs are in airworth y condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., JAROMI R RIVERA Aerial Operations Manual, Monthly Maintenance Lo g, and DJIPhantom 3 and DJ I In spire 1 Instruction Manual). JAROMI R RIVERA seeks the requested relief bec ause the DJI Phantom 3 and DJ I Inspire 1 UASs do not require an airworthiness certificate in acco rdance with 14 C.F .R. Part 21, Subpart H. Therefore, JAROMI R RIVERA will ensure that the DJ I Phantom 3 and DJI Inspire 1 UASs are in airworth y condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Lo g, and DJIPhantom 3 and DJ I In spire 1 Instruction Manual) prior to every flight, and further, determine that the airc raft are in condition for safe flight, as stated in the conditions and limitations below

. **3. Extent Of Relief**  **JAROMIR RIVERA Seeks**  **And The Reason**  **JAROMIR RIVERA Seeks**  **Relief Fr**  **om Section 91.121.**  Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the DJ I Phantom 3 and DJII nspire 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 PI C at the ground contr ol station (GCS). Since the F AA requires that any altitude information concerning UAS operations be reported to air traf fic control (A

TC) in feet above ground level (AGL), JAROMI R RIVERA seeks the requested relief because the DJ I Phantom 3 and DJII nspire 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. Consideri ng the limited altitude of the proposed operations, relief from 14 CFR 91.121 issought to the extent necessary to comply

with the applicable conditions and limitations stated below

. As more full y set forth herein, an equivalent level of safet y will be mai ntained since the DJIPhantom 3 and DJ I Inspire 1 UAs are equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the PI C with alt itude information of the UA on the heads

- up display of the GCS. **4. Extent Of Relief**  **JAROMIR RIVERA Seeks**  **And The Reason**  **JAROMIR RIVERA Seeks**  **Relief Fr om** **Section 91.151(b).** Relief from Section 91.151(b) entitled Fuel requirements fo r flight in VFR condition s, is requested to the extent required to allow flights of the battery powered DJ I Phantom 3 and DJI Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 15.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fl y after that for at least 4.5 minutes. JAROMI R RIVERA seeks the requested relief because without an exe mption from Section 91.151(b), the flight time duration of the battery

powered DJ I Phanto m 3 and DJII nspire 1 UAs will severel y constrain the practicality

of any aerial video or stil l photo flight operations that JAROMI R RIVERA proposes to conduct pursuant to this Petition. Significantly

, as set forth below, the technical specifications of the DJ I Phantom 3 and DJI Inspire 1 UASs, the DJ I Phantom 3 and DJII ns pire 1 operating documents, and JAROMI R RIVERA proposed operating limitations, ensure that JAROMI R RIVERA will safely operate the battery

powered DJ I Phantom 3 and DJII nspire 1 UAs during daylight hours in visual meteorological conditions (VMC), under visual flight ru les (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. **5. Extent Of Relief**  **JAROMIR RIVERA Seeks**  **And The Reason**  **JAROMIR RIVERA Seeks**  **Relief Fr om** **Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b).**  Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) onl y apply to aircraft with an airworthiness certificate, JAROMI R RIVERA requests relief from these Sections because the DJ I Phantom 3 and DJII nspire 1 UAS s do not require airworthiness certificates. As set forth more fully below, the DJI Phantom 3 and DJII nspire 1 UASs meet the conditions of FMRA

Section 333 for operation without an airworthine ss certificate. Accordingly

, JAROMI R RIVERA will use trained techn icians to perform maintenance, alterations, or preventive maintenance on the UASs usin g the methods, techniques, and practices prescribed in the UAS operating documents (i.e., JAROMI R RIVERA Aerial Operations Manual, Monthly Maintenance Log, and D JIPhantom 3 and DJII nspire 1 Instruction Manual). Furthermore, JA ROMI R RIVERA will document and maintain all maintenance records for the DJ I Phantom 3 and DJII nspire 1 UASs.

**D. The Reasons**  **Why Granting JAROMIR RIVERA**  **Request Wo**  **uld Be In The Public Inter**  **est: That Is, How It**  **Wo uld Benefit**  **The Public As**  **A Whole.** 

Gr anting the present Petition will further the public interest by allowing JAROMI R RIVERA to safely

, ef ficiently , and economicall y perform aerial video and photograph y of construction sites, real estate, and landscape over certain areas of the United States. Additionally

, use of the DJIPhantom 3 and DJ I Inspire 1 UASs will decrease congestion of the NAS, reduce pollution, crashes and accidents caused by pilot error and provide significant benefits to the economy . Notabl y, the benefits of JAROMI R RIVERA ’ pr oposed operation of the DJ I Phantom 3 and DJII nspire 1 UASs will be realized without implicating any privacy issues.**1. The Public Will Benefit Fr**  **om Decr**  **eased Congestion Of The NAS.** 

The DJ I Phantom 3 and DJII nspire 1 UAs are battery powered and serve as a s afe, ef ficient, and economical alternative to the manned aircraft traditionally utilized to obtai n aerial imagery

. By reducing the amount of manned aircraft needed to p erform aerial acquisitions, an exemption allowing the use of a DJ I Phantom 3 or DJII nsp ire 1 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safet y of life and propert y in the air and on the ground. Furthermore, b y reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The DJ I Phantom 3 and DJ I Inspire 1 UAs do not require an airport t o takeof f or land. Likewise, a reduction of manned aircraft conducting aerial video and photography mi ssions would result in fewer aircraft that must be handled by air traf fic control during the ground, takeoff, departure, arrival, and landing phases of flight operations. **2. The Public Will Benefit Fr**  **om T**  **he Safety And Efficien**  **cy Of The DJI Phantom 3 and DJI**  **Inspir e 1 UASs.**  Conducting aerial acquisitions with the DJIPhantom 3 and DJ I Inspire 1 UASs, instead of manned aircraft, will greatly benefit the public by drasticall y reducing the levels of air and noise pollution generated during traditional aerial v ideo and still photograph y flight operations. By using battery

power and electric motors, the DJ I Phantom 3 and DJ I Inspire 1 UASs produce no air pollution, and is the most viable environmentally conscious alternati ve to the cabin class, six cy linder inter

nal combustion engine aircraft that are ty pically utilized for aerial video and photography

, while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The DJIPhantom 3 and DJ I Inspire 1 UAs, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAs ar e propelled by battery powered electric motors, rather than an internal combustion engine. By using the DJ I Phantom 3 and DJ I Inspire 1 UASs to perform aerial acquisitions, the substantial risk to life and propert y in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircra ft, the DJ I Phantom 3 and DJII nspire 1 UAs (weighing approximately 2 pounds 14 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 respecti vely , and with no fuel on board), has less ph ys ical potential for collateral damage to life and propert y on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing approximately

6,000 pounds with a wi ngspan of approximately 42 feet, a length of 34 feet, and a fuel capacit y of 180 gallons). **3. Performing**  **Aerial Vi**  **deo and Photography Operations Wi**  **th The DJI Phan**  **tom 3 and DJI**  **Inspir e 1 UASs Will Benefit The**  **Economy**

**.** In addition to being safe and efficient, the DJ I Phantom 3 and DJII nspire 1 UASs are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJ I Phantom 3 and DJII nspire 1 UASs will allow United States based companies, like Fiquett Drones, to remain competitive and co ntribute to growth of the U.S. economy . Specifically

, with the rising cost of aviation fuel an d the Environmental Protection Agency (“EP A”) regulatory

actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology i n order to remain competitive. Operating the battery

powered DJ I Phantom 3 and DJII nspire 1 UASs is one such technology that not only

allows companies greater operational flexibility co mpared to manned aircraft, but provides such flexibility

without the high operational cost of a traditional manned aircraft. By operating the DJ I Phantom 3 and DJII nspire 1 UASs, companies such as Fiquett Drones,can remain competitive and profitable, and therefore, provi de greater job stability to employ ees and contractors, which will ultimately contribute to growth of the U.S. economy . Improved financial performance of U.S. companies, through commercial use of the DJI Phantom 3 and DJII nspire 1 UASs, provides a stable w orkforce 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. Ther**  **e Ar**  **e No Privacy Issues.** Similar to the manned aerial acquisition flight operation s that have been conducted for decades, JAROMI R RIVERA proposed operation of the D JIPhantom 3 and DJ I Inspire 1 UASs would not implicate any

privacy issues. Specifically , the D JIPhantom 3 and DJ I Inspire 1 UASs will be operated only

in compliance with operat ing documents (i.e., JAROMI R RIVERA Aerial Operations Manual, Monthly Maintenance Log, and DJIPhantom 3 and DJII nspire 1 Instruction Manual) which requires propert y owne r involvement as well as local law enforcement notification, and in accordance with the Federal Av iation Regulations, including the minimum altitude requirements of 14 C.F .R. § 91.1 19.

**E. The Reasons**  **Why Granting The Exemption W ould Not**  **Adversely Affect Safety**  **, Or How**  **The Exemptio**  **n Wo**  **uld Pr ovide**  **A Level Of Safety**  **At Least Equal To**  **T hat Pr**  **ovided By The Rule**  **Fr om** **Which JAROMIR RIVERA**  **Seeks Exemption.**

**1. Reasons Why The DJI Phantom 3 and DJI Inspir**  **e 1 UAs Meet The Conditions Of The FA**  **A Modernization and Reform**  **Act of 2012 (FMRA) Sect ion 333.**  In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, JAROMI R RIVERA ’ operation of the DJI Phantom 3 and DJII nspire 1 UASs meet the conditions of FMRA Sectio n 333, and wil l not require an airworthiness certificate in accordance with 14 C.F .R. Part 21, Subpart H. Secti on 333 provides authority for a UAS to operate without airworthiness certificati on and sets forth requirements for considering whether a UAS will create a haz ard to user s of the NAS or the public, or otherwise pose a threat to national security . Specificall y, FMRA

Section 333 states the following, in part:

**a.** In General.

-- Notwithstanding an y other requirement of this subtitle, and not later than 180 day s after the date of enactment of this Act, the Sec retary of T ransportation shall determine if certain unmanned aircraft sy stems may operate s afely

in the national airspace sy stem before completion of the plan and rulemaking required by section 332 of this Act or the guidance required b y section 334 of this Act. **b.** Assessment of Unmanned Aircraft S ys tems

. - - In making the determination under subsection (a), the Secretary shall determine, at a minimum

— **i.** Which ty

pes of unmanned aircraft s ys tems, 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

n ational airspace s ys tem or the public or pose a threat to nat ional security ; and whether a certifi cate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft s ys tems identified under paragraph (1)

. **c.** Requirements for Safe Operation

. - - If the Secretary determines under this section that certain unmanned aircraft sy stems may operate safely

in the national airspace s ys tem, the Secretary

shall establish requirements for the safe operation of such aircraf t sy stems in the national airspace sy stem.In seeking this exemption, JAROMI R RIVERA submits that the DJIPhantom 3 and DJ I Inspire 1 UASs can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by : (a) the characteristics of the DJ I P hantom 3 and DJII nspire 1 UASs; (b) the pilot certification requirement; and (c) the s pecific operating limitations. i. **The Specifications Of The DJI Phantom 3 and DJ**  **I Inspir e 1 UASs**  **Demonstrate Its Safe Characteristics.**  The DJ I Phantom 3 and DJII nspire 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

. ii. **Te chnical Specifications Of**  **The DJI Phantom 3 and DJI Inspir e 1 UASs.**  The DJ I P hantom 3 and DJII nspire 1 Specifications and Data Sheet, attached hereto as Appendix A and B, set the technical specifications of the DJ I Phantom 3 and DJ I Inspire 1 UASs forth

. iii. **The DJI Phantom 3 and DJI Inspir e 1 UASs**  **Autonomous Flight And**  **Navigation Mo**  **des Enable The UASs T o Remain Within**  **A Defined**  **Operational Ar**  **ea.** The DJ I Phantom 3 and DJII nspire 1 UASs may be ope rated in both manual and fully autonomous flight modes. A complete description of the flight and navigational modes of the DJ I Phantom 3 an d DJ I In spire 1 UASs is provided at pages 25

- 35 of the DJ I Phantom 3 and pages 12

- 16 and 45

- 50 of the DJ I In spire 1 User Manuals, attached hereto as Exhibit C and D. iv. **The DJI Phantom 3 and DJI Inspir e 1 UAS**  **s Ar**  **e Designed For A**  **utomatic Return T**  **o Home Point Or** 

**Hover In**  **The Event Of Loss Of**  **The Contr ol**  **Link Or Navigation.**  When the Control L ink is lost, the DJIPhantom 3 an d DJ I Inspire 1 UAs will remain stationary

, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 3 and DJII nspire 1 UAs d o not reacquire control link data from the GCS, the UAs will assume that the Control L ink is lost and the UAs will return to the home position (i.e., failsafe mode ) via GPS, and will descend to the takeof f position and shutdown. A complete description of the Failsafe Functions of the DJ I Phantom 3 UAS are set forth at pages 27 through 29 and for the DJ I In spire 1 at pages 13 through 15 of the DJ I Phantom 3 and DJII nspire 1 User Manuals, attached hereto as Exhibit C and D.

v. **The DJI Phantom 3 and DJI Inspir e**  **1 GCS And It’**  **s Operation.** A complete description of the operation and specifications of the DJ I Phantom 3 and DJ I Inspire 1 GCS and flight control software is provided at pages 32 through 43 of the DJ I Phantom 3 User Manual and pages 40 through 47 of the DJII nspire 1 User Manual. DJ I Phantom 3 and DJII nspire 1 User Manuals are attached hereto as Exhibits C and D. vi. **Flight Operations Of DJI Phantom 3 and DJI Inspir**  **e 1 UASs Are Limited**  **To The Line Of Sight Of**  **A Certificated Pilot in Co**  **mmand With A**  **Safety Obs**  **erver .**  JAROMI R RIVERA will only utilize certificated pilots who possess a current and valid airman medical certificate to act as a pilot in command (PI C ) of the DJIPhantom 3 and DJ I Inspire 1 UASs. Additionally , a safet y observer will assist all pilots d

uring flight time. vii. **Flights Of DJI Phantom 3 and DJI Inspir e 1 UAS**  **s Wi**  **ll Be Conducted Pursu**  **ant To**  **Specific Operating Limitations.** In seeking this exemption, JAROMI R RIVERA proposes to commercially operate DJ I Phantom 3 and DJII nspire 1 UASs for the spec ial purpose of conducting aerial video and photograph y over certain areas of United States, pursuant to th e following specific operating limitations: 1. Operations authorized b y this grant of exemption wi ll be limited to the following aircraft described in th e operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: DJ I Phantom 3 and DJ I Inspire 1 Unmanned Aircraft Sy stems. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant. 2. U AS 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 b y the procedures specified in the operating documents unless a special request is made and approved b y AT C. All altitudes reported to AT C must be in feet AGL

. 5. The UAs must be operated within visual line of sight (VLOS) of the P IC at all times. This requires the PI C to be able to use human vision unaided by an y device other than corrective lenses, as specified on the PI C’ s FA A

- issued airman medical certificate. 6. The use of first person view (FPV) b y the PI C or s afet y ob server (SO) is not permitted. 7. All operations must utilize a safet y observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC alway s maintains VLOS c apability

. The SO and PI C must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PI C must e nsure that the SO can perform the functions prescribed in the operating documents. 8. The SO must not perform any other duties bey ond ass isting the PI C with seeing and avoiding other air traf fic and other ground based obstacles/obstru ctions and is not perm itted to operate the camera or other instruments. 9. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy

exists between the conditions and limitat ions contained in the grant o f exemption and the procedures outlined in the operating documents, the conditions and limitat ions contained in the grant of exemption take precedence and must be followed. Otherwise , the operator must follow the procedures as outlined in its operating documents. The ope rator may update or revise its operating documents. It is the operator ’s responsibility to tr ack such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. I f theoperator determin es that any update or revision would af fect the basis upon which the F

AA granted the exe mption, then the operator must peti tion for amendment to its grant of exemption. The F AA’s U AS Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operating documents. 10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition f or safe flight. If the inspection reveals a condition that aff ects 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 saf e flight. The Ground Control Station must be included in the preflight inspection. All maintenance an d alterations must be properly documented in the aircraft records. 11. Any UAS that has undergone maintenance or alterations that af fect the UA S operation or f

light characteristics, e.g. replacement of a flight

cr itical component, must undergo a functional test flight. The PIC who conducts the functional tes t flight must make an entry in the a ircraft records. 12. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not alread y covered i n the relevant sections of the operating documents. 13. The operator must follow the UAS manufacturer ’s aircraft/component, maintenance, overhaul, replacement, inspectio n, and life limit requirements. 14. The operator must carry out its maintenance, i nspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspec tion, alterations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description of work accompli shed, and the signature of the authorized perso n returning the UAS to service. 15. Each UASs operated under this exemption must comply with all manufacturer Saf

et y Bulletins. 16. The authorized person must make an entry in the air craft record of the corrective action taken against discrepancies discovered between inspections. 17. The PI C must possess at least a private pilot certificate and at least a current third

- class medical certificate. 18. The operator may

not permit any

PI C to operate unles s the PI C meets the operator ’s qualification criteria and demonstrates the ability to safel y operate the UAS in a manner consistent with how the UA S will be operated under the exemption, including evasive and e mergency maneuvers and maintaining appropriate distances f rom persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F .R. § 61.51(b). Flights for the purposes of training the operator ’s PICs are permitted under the terms of the exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency , and ex perience

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

not be conducted during night
, as defined in 14 C.F .R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will be made at the F AA of fi ce closest to proposed area of operations. Flights under special v isual flight rules (SVFR) are not authorized. 20. The UA

may not operate within 5 nautical miles of an airport reference point as denoted on a current F AA

- published aeronautical chart unless a letter of agreement with that airport’ s management is obtained, an d the operation is conduc ted in accordance with a NOT AM as required b y the operator ’s COA. The letter of agreement with the airport managem ent must be made available to the Administrator upon request. 21. The UA

may not be operated less than 500 feet below or less than 2,000 feet horizontally

from a cloud or when visibility is less than 3 statute miles from the PI C. 22. If the UA

loses communications or loses its GPS s ignal, it must return to a pre

- determined location within the planned operating area and land or b e recovered in accordance with the operating documents. 23. The PI C must abort the flight in the event of unpredicte d obstacles or emergencies in accordance with the operating documents. 24. The PI C is prohibited from beginning a flight unless (considering wind

and forecast weather conditions) there is enough power to fl y at normal cruising speed to the intended landing point and land the UA with 25% battery power remaining. 25. The operator must obtain an Air T raf fic Organizati on (A

TO) issued Certificate of Wa iver or Authorization (COA) prior to conducting an y operations under the grant of exemption. This COA will also require the operator to requ est a Notice to Airman (NOT AM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the AT O issued CO A including class of airspace, altitude level and potential transponder requirements. 26. All aircraft operated in accordance with the exemptio n must be identified by s erial number, registered in accordance with 14 C.F .R. part 47, and have identification (N

- Number) markings in accordance with 14 C.F .R. part 45, Subpart C . Markings must be as large as practicable. 27. Before conducting operations, the radio frequency s pectr um used for operation and control of the UA must compl y with the Federal Communicat ions Commission (FCC) or other appropriate government oversight agency

requirements. 28. The documents required fewer than 14 C.F .R. 91.9 and 91.203 must be available to the PI C at the Ground Control Station of the UAS an y time the UAS is operating. These documents must be made available to the Administrator or an y law enforcement official upon request. 29. The UA

must remain clear and y ield the right of way to all manned aviation operation s and activities at all times. 30. The UAS may

not be operated b y the PIC from any moving device or vehicle.31. Flight operations must be conducted at least 500 feet from all

nonparticipating persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehic les, and structures unless:

a. Barriers or structures are present that suf ficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protectio n. I f a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediatel y and/or; b. The aircraft is operated near vessels, vehicles or structur es where the owner/controller of such vessels, vehicles or structures has granted permission and th e PI C has made a safet y assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, and;

c. Operations nearer to the PI C, SO, operator traine es or essential persons do not present an undue hazard to those persons per § 91.1 19(a). 32. All operations shall be conducted over private or c ontrolled

- access propert y with permission from the land owner/controller or a uthorized repres entative. 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 operation al area as defined by the applicab le COA must be reported to the FA A's UAS Integration Of fice (AFS

- 80) within 24 hours. Acc idents must be reported to the National Tr ansportation Safet y Board (NTSB) per instructions containe d on the NTSB W eb site: www .ntsb.g ov

. **2. Reasons Why**  **An Exemption Fr om**  **The Requir eme**  **nts Of Section 61.1 13(a)**  **And (b) W**  **ould Not**  **Adversely Affect Safety** 

**.** JAROMI R RIVERA submits that the equivalent level of safet y established by Section 61.1 13(a) and (b) will be maintained because no PIC will be allowed to operate the DJI Phantom 3 and DJII nspire 1 UASs unless that PI C has de monstrated, by meeting minimum flight

- hour and currency requirements, that the PI C is able to sa fely operate the DJ I Phantom 3 or DJ I Inspire 1 UAS in a manner consistent with the ex emption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels , vehicles and structures. Considering JAROMI R RIVERA ’ proposed area of operations, and the operating limitations set forth

- above; the parallel nature of privat e pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 1 1062); and the airmanship skills necessary to safel y operate the DJ I Phantom 3 or DJII nspire 1 UAS, JAROMI R RIVERA submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for JAROMI R RIVERA ’ specific proposed flight operations. The F AA has previously

granted relief from Section 61.1 13 (a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11 062, 1 1063, 1 1064, 1 1065, 1 1066, 1 1067, 1 1080, 1 11 09, 1 111 0, 1 111 2, 1 11 36, 1 11 38, 1 11 50, 111 53, 1 11 56, 1 11 58, 1 11 59, 1 11 60, 1 11 61). JAROMI R RIVERA will not allow an y P IC to operate the DJ I Phantom 3 or DJ I Inspire 1 UAS unless that PI C has demonstrated, by meeting minimum flight

- hour requirements or the DJ I Phantom 3 or DJII nspire 1 UAS training andcurrency requirements, that the PI C is able to safely operate the DJ I Phantom 3 or DJ I Inspire 1 UAS in a manner consistent with this exemption, including e vasive and emergency maneuvers and maintaining appropriate distances from people, vess els, vehicles and structures. Specifical ly

, the PIC must have accumulated and logged, in a manner 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 the hour requirements, the PI C must accomplish 3 takeof fs and landings in the preceding 90 day s (for currency purposes). As in E xemption Nos. 1 1062, 1 11 38, and 1 11 53, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safet y during JAROMI R RIVERA ’ proposed operations. The Administrator has held that pri or documented flight experience that was obtained in compliance with applicable regulations would ensure safe o perations, stating as follows: In Exemption No. 1 1062, the F AA required that prior to conducting operations for the purpose of motion picture fil ming (or similar operations), the PI C 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 operati ons under Exemption No. 1 1062, the PI C must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption. For clarification, the F AA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi

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

AA finds that at a minimum, the flight hour requirements in Exemption No. 1 1062 are appropriate to practice and build proficiency

in the skills necessary

t o safel y conduct the petitioner ’s proposed operations. The FA A also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Tr aining, proficiency , and experience

building fli ghts can also be conducted under the grant of exemption to accomplish the required flight time. During training, proficiency , and experience

- building flights the PI C is required to operate the UA

with appropriate distances in acc ordance with 14 C.F .R 91.1 1 9.

Exemption No. 1 11 38 at page 15. Accordingly

, JAROMI R RIVERA will ensure safe operations b y not allowing an y P IC to operate the DJ I Phantom 3 or DJ I Inspire 1 UAS unless that PI C has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PI C is able to safely operate the DJ I Phantom 3 or DJII nspire 1 UAS in a manner consistent with th e exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

**CONCLUSION** JAROMI R RIVERA seeks an exemption pursuant to 14 C.F .R. § 1 1.61 and Section 333of the F AA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJ I Phantom 3 and DJII nspire 1 UASs 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 F AA A dministrator will be fulfilling the Congressional mandate of the F AA Modernization and Reform Act of 2012, while als o advancing the interests of the public, by allowing JAROMI R RIVERA to safel y, ef ficiently
, and economically

operate the DJ I Phantom 3 and DJII nspire 1 UA Ss commerciall y within the NAS. WHEREFORE, in accordance with the Federal Av iation Regulations and th e F AA Modernization and Reform Act of 2012, Section 333, JAROMI R RIVERA respectfull y requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F .R Sections 61.1 13(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91. 407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit JAROMIR RIVERA to operate the DJ I Phantom 3 and DJII nspire 1 UASs commerciall y for the purpose of conducting aerial video and photograph y over certain areas of the United States.

Dated: J une 15 , 2015 Submitted by JAROMI R RIVERA

**APPENDIX**

**– A** DJIPHANT OM 3 TECHNI CAL SPECIFICA

TI ONS

JAROMI R RIVERA only utilizes safe and reliable UASs. DJ I is an industry leader in small UAS production. DJ I UASs are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJ I software provides real

- time altitude and location information to the PI C via the linked monitor (smart phone/t ablet devices)

DJIPhantom 3 1.1 Aircraft 1.1.1 Supported Battery

– DJ I 6000AH L iPo Battery 1.1.2 We ight (Battery

& Propellers Included)

– 2lbs 1 1.810oz (1242g) 1.1.3 Hover Accuracy

(Ready to Fly)

– Ve rtical: .8m; Horizontal: 2.5m 1.1.4 M ax Yaw Angular Ve locity

- 200/s 1.1.5 Max Ti lt Angel

- 35 1.1.1.6 Max Ascent Speed

– 6m/s 1.1.6 Max Descent Speed

– 2m/s 1.1.7 Max Flight S peed

– 15m/s (NOTRECOMMENDED) 1.2 Gimbal 1.2.1 Wo rking Current

– Static: 750mA; Dy namic: 900mA 1.2.2 Control Accuracy

- ±0.03 1.2.3 Controllable Range

– Pi tch:

- 90

- 0 1.2.4 Maximum Angu lar Speed

– Pitch: 90/s 1.3 Camera 1.3.1 Operating Temperature Range

- 32F

- 104F (0C

- 40C) 1.3.2 Sensor Size

– 1/2.3” 1.3.3 Ef fective Pixels

– 14M 1.3.4 Resolution

– 4384x3288 1.3.5 HD V

ide o Recording

– 1080p30 & 720p 1.3.6 Recording Field of V iew

- 11 0/85

**APPENDIX**

**– B** DJII NSPI RE 1 TECHNICAL SPECIFICA

TI ONS

JAROMI R RIVERA only utilizes safe and reliable UASs. DJ I is an industry leader in small UAS production. DJ I UASs are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJ I software provides real

- time altitude and location information to the PI C via the linked monitor (smart phone/tablet devices)

DJII nspire 1 1.1 Aircraft 1.1.1 Model

– T600 1.1.2 We ight (Battery

I ncluded)

– 6lbs 7.5291oz (2935g) 1.1.3 Hovering Accuracy

(GPS Mode)

– Ve rtical: 0.5m; Horizontal: 2.5m
1.1.4 Max Angular V

elocit y

– Pitch: 300 /s; Yaw: 150 /s
1.1.5 Max Ti lt Angle

- 35 1.1.6 Max Ascent Speed

– 5m/s 1.1.7 Max Descent Speed

– 4m/s 1.1.8 Max Speed

– 22m/s (A TTImode, no wind

– NOT RECOMMENDED) 1.1.9 Max Flight Altitude

– 4500m 1.1.10 Max Wi nd Resistance

– 10m/s 1.1.11 Max Flight Time

– Approximately 18 minutes 1.1.12 Motor Model

– DJ I 3510 1.1.13 Propeller Model

– DJ I 1345
1.1.14 Operating Temperature Range

– 14 F to 104 F (

- 10 C to 40 C) 1.1.15 Dimensions

– 17 1⁄4” x 17 3⁄4” x 12” 1.2 Gimbal 1.2.1 Model

– ZENMUSE X3 1.2.2 Output Power (with camera)

– Static: 9W; In Motion: 1 1W 1.2.3 Operating Current

– Static: 750mA; In Motion: 900mA
1.2.4 Angular V

ibration Range

- ±0.03 1.2.5 Mounting

– Detachable
1.2.6 Controllable Range

– Pitch:

- 90 to +30 ; Pan: ±320
1.2.7 Mechanical Range

– Pitch:

- 125 to 45 ; Pan: ±330
1.2.8 Max Controllable Sp eed

– Pitch: 120 /s; Pan: 180 /s 1.3 Tr ansmitter 1.3.1 Name

– C1 1.3.2 Operating Frequency

– 5.728

- 5.850GHz; 2.400

- 2.483GHz 1.3.3 Communicating Distance (unobstructed)

– 2000m 1.3.4 Output Power

– 9W
1.3.5 Operating Temperature Range

- 14 F to 104 F (

- 10 C to 40 C) 1.3.6 Battery

– 600mAh LiPo 2SAll specifications can be found in the attached user manual or at

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

- 1/spec