January 26 , 2016

operation thirteenOne, LLC’s Petition for Exemption Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations.

NAME AND ADDRESS OF PETITIONER

operation thirteenOne, LLC
Attn: Michael J. Huber Jr. 308 High St, Westville, NJ 08093
856

- 383

- 1321 info@op131.com

Dear Sir or Madam:

Pursuant to Section 3 3 3 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, operation thirteenOne, hereby applies for an exemption from the
listed F ederal Aviation Regulations to allow commercial operation of its UAS. Operations are to be conducted within conditions set forth by the FAA as required by Section 333 and are hence forth outlined below within this
document.

The request of exemption is for a DJI Phantom 3 Professional and DJI Inspire 1
Pro that will be used for aerial photography for operation thirteenOne. Additionally, requested with this exemption is the ability to use the UAS outside of the United States during travel as long as long as s afety operations of the governing NAS is followed and there are no restrictions stating flight is prohibited.

The following commercial operations are requested:

• Aerial photography/video for public/private use including: real estate, architecture, land surveying, engineering, and other rel ated professional
activities.

• Television, public events , cinemat ography and news gathering.

• Inspection of residential/commercial structures under contract with the owners or local government authority.

• Residential/commercial utility infrastructure.January 26 , 2016

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• Provide live video feed to assist with search and rescue operations only when the local authories or government has requested it by contract or
donation.

R EGULATIONS FROM WHICH EXEMPTION IS REQUESTED

• 14 CFR Part 21 subpart H

• 14 CFR 45.23 (b)

• 14 CFR 61.113 (a) & (b)

• 14 CFR 91.7 (a)

• 14 CFR 91.9 (b) (2)

• 14 CFR 91.103

• 14 CFR 91.109

• 14 CFR 91.119 (c)

• 14 CFR 91.121

• 14 CFR 91.151 (a)

• 14 CFR 91.203 (a) & (b)

• 14 CFR 91.405 (a)

• 14 CFR 91.407 (a) (1)

• 14 CFR 91.409 (a) (2)

• 14 CFR 91.417 (a) & (b)

Two UAS will be operated by operation thirteenOne, both manufactured by DJI
Innovations. The first is the DJI Phantom 3 Professional, with a total weight of
2lbs 13oz. The dimensions are 16in. x 16in. x 7.5in. Without wind the maximum speed is no more than 35mph and a cruising speed of 25mph. The DJI Professional has the ability to hover and move along a vertical and horizontal place simultane ously. The DJI Phantom 3 has four motors (Model DJI 3510), powered by a 4480mAh 4s LiPo Lithium Polymer battery. There are four propellers (Model DJI 1345). The DJI Pha n tom Professional is controlled by the C3 remote controller with an operating frequency of 2.400GHz

– 2.483GHz. The live video feed will have an operating frequency of 2.4GHz ISM with maximum range of 1.2 miles.

The second aircraft, the DJI Inspire 1 Pro, shares the same similar features as the
DJI Pha n tom 3 Professional, which are listed b elow. The Inspire 1 Pro weighs
7lbs. 8oz. and is slightly larger than the Phantom 3 Professional measuring
17.2in. x 17.7in. x 11.8in. Both of the UAS share the same software and flight
characteristics and have the same built

- in limitations. The applicant w ill operate both UAS in line of sight after following a pre

- flight checklist and
follow al l safety regulations, including : keeping the UAS under 400 feet, not flying within 5 miles of an airport/heliport, not flyin g near other aircraft, notJanuary 26 , 2016

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flying under th e influence, not fly ing directly over people, and not fly ing near
emergency responses.

DJI PHANTOM 3 PREFESSIONAL & INSPIRE 1 PRO
General Features

• Ready to fly

• 3

- axis camera stabilization

• Precision flight and stable hovering

• GPS/GLONASS positioning & auto return home

• Onscreen real

- time flight parameters

• High Definition 4k Camera

• Camera tilt control

• Film straight down

• Supports Adobe DNG RAW

• Adobe lens profile support

• Camera parameter settings

• Album synchronization

• FAA no

- fly zone locked out via installed software
T ransmitter

• Operating Frequency: 2.400GHz

– 2.483 GHz

• Communication Distance (open area): CE: 2000m; FCC: 2000m

• Receiver Sensitivity(1%PER):

- 101dBm +/

- 2dBm

• Transmitter Power: CE: 16dBm; FCC: 20dBm

• Working Voltage: Phantom 1.2A @ 7.4V, Inspire 22.5V

• Battery: Pha n tom 6000 mAh LiPo 2s, Inspire 5700 mAh LiPo 6S High voltage battery
Camera

• HD Recording: 4096 x 2162p @ 24 fps, 1080p 60fps DJI GO APP

• System Requirement of Mobile Device: iOS Version 8.0 or above / Android system version 4.0 or above

• Mobile Device Support: Recommended: iPhone, iPad, iPod Touch

• Operating Environment Temperature: 0oC

- 40oC

• Max Resolution: 4096 x 2162p @ 24/25 fps

• FOV: 94o/85o

• Sensor size: 1/2.3" / Micro Four

- thirds

Given the small siz e of both UAS and the controlled environment provid ed

, the proposed operations will adhere to the Reform Act’s safety requirements. The approval of this application presents no national security issues. Regarding the level of safety surrounding the proposed operation and the public benefit,
reduction in en vironmental impacts, including but not limited to reducedJanuary 26 , 2016

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emissions and noise, the grant of the requested exemption is in the public
interest.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The operation limitations proposed for an equivalent or higher level of safety because operations will further enhance the safety of the persons and/or property using conventional aircraft. These limitations and conditions to which the applicant agrees to adhere to when conducting commercial operations
under the FAA issues exe mption as set forth in the Flight Operations Manual
include:

• The UAS will w eigh less than 55 lbs. (DJI Phantom 3 Professional weighs 2lbs. 13oz., Inspire 1 Pro weighs 7lbs. 8oz.)

• Both UAS will have a maximum operating speed of no more than 35mph.

• Flights w ill be operated within line of sight of the Pilot in Command and/or Visual Observer.

• Maximum flight time for each operation flight will be 20 minutes. Flights will be terminated at 25% power reserve or 20 minutes of flight time
whichever occurs first.

• Flig hts will be operated at an altitude of no more than 400 feet Above Ground Level and not more than 200 feet above an elevated platform from which filming is planned.

• Minimum crew for each operation will consist of the UAS Pilot, the Visual Observer and may include but not limited to a Camera Operator utilizing a separate camera controller (Inspire 1 Pro).

• A briefing will be performed regarding the planned UAS operations prior to each day’s flight.

• All flights will occur under Visual Flight Rules Meteorologic al Conditions only.

• Flight s will occur no closer than a 5

- mile radius of the geographic center/Airport Reference Point of a tower controlled or uncontrolled airport. The DJI Phantom 3 Professional and Inspire 1 Pro have built in software for all FAA regula ted 'No Fly Zones’ and was uploaded by DJI (February 2015) for all DJI drones to download and prevent any possible flights occurring within no

- fly zones.

• The Pilot in Command and Visual Observer will have been trained in operation of the UAS and receive up

- to

- date information for the particular UAS to be operated. Current Sectional Charts will also be available and reviewed prior to the start of filming or other operations.

• The Pilot in Command and Visual Observer will be able to communicate by voice, radio , and/or text al all times.January 26 , 2016

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• Written and/or verbal permission and permits will be obtained from territorial, state, county or city jurisdictions, including law enforcement, fire or other appropriate governmental agencies.

• If either UAS loses communications with the remote controller or loses GPS signal, the UAS will have the capability to return to a pre

determined location within a designated location , set during take

- off, and land automatically.

• Both UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or emergencies.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the UAS to be utilized by the applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 a nd 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, spe ed, operational capability, and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the
restricted environment and under th e conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating
with an airworthiness certificate without the restrictions and conditions proposed.

The UAS to be operated hereunder is less than 5 5lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured and designated area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator and under the requirements and in compliance with local public safety requirements. Lastly application of these same criteria demonstrates that there is no credible threat to national security posed by both UA S, due to their size, speed of oper ation, location of operation,
l ack of explosive materials or flammable liquid fuels, and inability to carry a
substantial external load.

14 C.F.R § 45.23 (b). Marking of the Aircraft When marks include only the Roman capital letter “N” and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificated aircraft, the operator must alsoJanuary 26 , 2016

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display on that aircraft near each entrance to the cabin, coc kpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “light

- sport,” “experimental,” or “provisional,” as applicable.

Even though either UAS will have no airworthiness certificate, an exe mption is requested as both UAS will have no entrance to the cabin, cockpit, or pilot station on which the word “Experimental” can be placed. Given the size of either UAS, two

- inch lettering will be impossible. The word “Experimental” will be placed on t he fuselage in compliance with §45.29 (f).

The equivalent level of safety will be provided by having both UAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the UAS will see the identification either of the UAS as “Experimental.”

14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in
Command No person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for co mpensation or hire; nor may that person, for compensation or hire, act as pilot in command of an
aircraft. A private pilot may, for compensation or hire, act as pilot in command of an aircraft in connection with any business or employment if

...

An equivalen t level of safety can be achieved by current r egulations because the applicant’s UAS do not carry any pilots or passengers nor property. The risks attendant to the operation of UAS is far less than the risk levels inherent in the
commercial activities outl ined in 14 CFR 61. The operation and limitations set forth in the FOM will equate to the safe operation of the UAS.

14 C.F.R. § 91.7 (a): Civil Aircraft Airworthiness No person may operate a civil aircraft unless it is in an airworthy condition. The pilot in command of a civil aircraft is responsible for determining whether that aircraft is in condition for safe flight. The pilot in command shall discontinue the flight when unairworthy mechanical, electrical, or structural conditions occur.

Given the size of either aircraft for maintenance and use of safety check lists prior to each flight an equivalent level of safety will be provided.

14 C.F.R. § 91.9 (b) (2): C ivil Aircraft Flight Manual in the Aircraft No person may operate a U.S.

- registered civil air craft

— For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there isJanuary 26 , 2016

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available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof.

The UAS doesn’t have the ability to carry a flight manual on the aircraft, due to it’s size and no cockpit. Instead the equivalent level of safety will be maintained by keeping the flight manual with the pilot operating the UAS from t he ground
with immediate access to it.

14 C.F.R. § 91.103: Preflight Action Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight.

An exemption is requested as the FAA approved rotorcraft flight manuals will not be provided. Instead the Pilot in Command will take all actions as stated in the manufacturer FOM in the pre

- flight inspection section, including but not limited to reviewing weather, flight batteries, landing and takeoff distances, and aircraft performance data before initiation of flight. Laminated preflight
checklists based on manufacturer’s recommendations of either aircraft will be
used.

14 C.F.R § 91.109: Flight Instruction No person may operate a civil aircraft (ex cept a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual
controls.

UAS operates using a RC transmitter that communicates to the aircraft via radio communications. The FAA has approved exemptions for flight training without dual controls and for flight instruction in experimental aircraft. The equivalent level of safety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the
aircraf t.

14 C.F.R § 91.119: Minimum Safe Altitudes Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes: (d) Helicopters, powered parachutes, and weight

shift

- control aircraft. If the operation is conduct ed without hazard to persons or property on the surface

.

Exemption is requested for a UAS that is a helicopter. Requests are made to operate at altitudes up to 400 feet Above Ground Level and not more than 200 above an elevated platform/structure from whi ch filming is planned. In the case where the structure that is being filmed/surveyed exceeds the height of 400January 26 , 2016

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feet, an exemption is requested to still be able to film/survey the structure as long as the UAS does not exceed an altitude of 200 feet above th e structure’s highest point and only be done in restricted zones where security clearance is
needed and other structures and people will not be exposed without pre

obtained consent.

The equivalent level of safety will be achieved given the size, weight, a nd speed of the UAS as well as the location where it is operated. No flight will be taken without the permission of the property owner of local officials. Because of the advance notice to the property owner and participants in the filming activity, all
aff ected individuals will be aware of the planned flight operations. The low

altitude operations of the UAS will ensure separation between UAS operations and the operations of conventional aircraft that must comply with Section
91.119.

14 C.F.R. § Altimeter Settings 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 altimeter that is set

.

An exemption is requested as the UAS only has a GPS read out and not a true barometric altimeter. An equivalent level of safety will be achieved by the operator, using the safety check list and live data monitoring provided by the UAS to the transmitter and also confirming altitude of the la unch site shown on the GPS altitude before flight.

14 C.F.R. § 91.151 (a): Fuel Requirements for Flight in VFR Conditions No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is e nough fuel to fly to the first point of intended landing and, assuming normal cruising speed

— During the day, to fly after that for at least 30 minutes; or At night, to fly after that for
at least 45 minutes.

An exemption is requested as the UAS does not u se fuel, instead a LiPo battery is used providing only a maximum flight time of 25 minutes. In order to meet the reserve requirements, flight time would be limited to 10 minutes. Due to the battery limitations and since being operated in a predetermined ar ea, a longer time frame for flight in daylight or twilight VFR conditions are requested.

Operation of the UAS will be in tightly controlled areas where only people and property owners or official representatives who have signed waivers will be
allowed. Ex emption is requested to allow flight times of 20 minutes or 25% ofJanuary 26 , 2016

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battery power

— whichever comes first. Since UAS will always be in line of sight this will provide enough power to return to the operator for landing.

14 C.F.R. § 91.203 (a) and (b): Carryin g Civil Aircraft Certification and Registration Except as provided in §91.715, no person may operate a civil aircraft unless it has within it the following : An appropriate and current airworthiness certificate.
Each U.S. airworthiness certificate used to comply with this subparagraph (except a special flight permit, a copy of the applicable operations specifications issued under §21.197(c) of this chapter, appropriate sections of the air carrier manual required by parts 121 and 135 of this chapter containi ng that portion of the operations specifications issued under §21.197(c), or an authorization under §91.611) must have on it the registration number assigned to the aircraft under part 47 of this chapter. However, the airworthiness certificate
need not hav e on it an assigned special identification number before 10 days
after that number is first affixed to the aircraft. A revised airworthiness certificate having on it an assigned special identification number, that has been affixed to an aircraft, may only be obtained upon application to an FAA Flight
Standards district office.

No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displa yed at the cabin or cockpit entrance so that it is legible to

passengers or crew.

A fully loaded UAS weighs no more than 55 lbs. and is operated by a pilot on the ground. There is no cockpit or storage on the UAS to hold such documents.

An equivalent lev el of safety will be achieved by keeping such documents with the pilot at the ground control point where the pilot will have immediate access, as long as they are applicable to the UAS.

14 C.F.R. § 91.405 (a); 407 (a) (1); 409 (a) (2); 417 (a) & (b): Main tenance Inspections Each owner or operator of an aircraft

— 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;

These sections and Part 43 apple to an aircraft with an airworthiness certificate, which do not apply to the UAS. Therefore maintenance will be completed by the owner in accordance to the flight manuals and operatin g handbooks.January 26 , 2016

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An equivalent level of safety will be achieved because of the size of the UAS
and limited flight time in restricted areas. In case any mechanical issues occur the UAS can be immediately landed and will not be operated at heights no higher tha n 400 feet Above Ground Level. The operator will perform required maintenance and keep logs of any maintenance performed before attempting flight again. Maintenance and inspections will be performed in accordance with
the UAS Manufacturer’s User Manual. Th e UAS will only take flight when it is in known working order.

Sincerely,

Michael J. Huber Jr. operation thirteenOne, LLC 308 High St, Westville, NJ 08093
856

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