UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC

Regulatory Docket No. TBD

______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

### Sunshine Yachts, LLC

FOR AN EXEMPTION SEEKING RELIEF F ROM THE REQUIREMENTS 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 DJI PHANTOM 2 VISION + AND 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 30 , 2015

Morris Neal Fredrick 12130 Sugarloaf Key Street #101 Tampa, FL 33626

239

- 404

- 8662 ssymorris@gma i l .com

TABLE OF CONTENTS PageGLOSSARY OF ABBREVIATIONS.................................................................................3

SUMMARY..........................................................................................

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

INTRODUCTION AND INTERESTS OF PETITIONER.................................................4

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

BASIS FOR PETI TION......................................................................................................................... ..5

NAME AND ADDRESS OF PETITIONER...........................................................7
THE SPECIFIC SECTIONS OF 14 C.F.R . FROM WHICH SUNSHINE YACHTS, LLC SEEKS EXEMPTION.................................................................................8
THE EXTENT OF RELIEF SUNSHINE YACHTS, LLC SEEKS AND THE REASON THE RELIEF..........................11
THE REASONS WHY GRANTING S UNSHINE YACHTS, LLC REQUEST WOULD BE IN THE PUBLIC INTEREST .../...................................................14
THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY................................................................... ......17
CONCLUSION.................................................................................................................32

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level
AOI Area of Interest
ATC Air Traffic ControlAT O Air Traffic Organization
AV Aerial Vehicle
CFR Code of Federal Regulations
COA Certificate of Authorization
FAA Federal Aviation Administration
FAR Federal Aviation Regulation
GCS Ground Control Station
GPS Global Positioning Sy stem
LOL Loss of Link
NAS National Airspace System
NOTAM Notice to Airman
PIC Pilot In Command
Section 333 FAA Modernization and Refor m Act of 2012 (FMRA)
SO Safety Observer
SOP Standard Operating Procedures UA (UAV) Unmanned Aircraf t
UAS Unmanned Aircraft System

VFR Visual Flight Rules
VLOS Visual Line of Site
VMC Visual Meteorological Conditions
VTOL Vertical Takeoff and Landing

SUMMARY

SUNSHINE YACHTS, LLC seeks exemption from the requirements of 14 C.F.R

§§ 6 1.113(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 Modernization and Reform Act of 2012 (FMRA). This exemptio n will

perm it Sunshine Yachts, LLC to operate an Unmanned Aircraft System (UAS) for thecommercial purpose of conducting aerial video and p hotography of boats and sailboats

, real estate, and landscape over certain areas of the United States.

INTRODUCTION AND INTERE STS OF THE PETITIONER

Sunshine Yachts, LLC is owned and operated by Morris Neal Fredrick. Neal is 52
years old and has a B.S. degree in Aviation Management

. My areas of interests i nclude
photography of yachts and photography and home inspections of real e state.

The o bjective of Sunshine Yachts, LLC is Aerial V i deo and Photography Services

for providing high quality imaging for a variety of commercial, public, and residential
uses, specifically targeting:

• Aerial photograph y an d videography of marine vessel s ( for sellers and buyers )

• Aerial photography and videography for realtors, home builders, home
contractors, and/or home inspectors for real estate marketing and inspections of

home exteriors

• Aerial photography for c ons truction sites before, during and aft er completion

• Providing for community demands in the need of low cost small

- unmanned
aircraft operations for photography and videography

.

BACKGROUND

Sunshine Yachts, LLC seeks an exemption to operate DJI Phantom 2 Vision +, DJI
Inspire 1 UAS 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 S ) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone
systems. The DJI Phantom 2 Vis ion + has a maximum gross weight of approximately 2pounds 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 DJI Inspire 1 has a
maximum gross weight of 6 pounds 7.5 oun ces, 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 1UAs 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

Sunshine Yachts, LLC and 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, Sunshine Yachts, 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 National Airspace System (NAS), and for an exemption from

th e 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 limited operating area associated

with the unmanned aircraft and its operation, Sunshine Yachts, LLC operation s of DJI

Phantom 2 Vision + and DJI 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.Acc ordingly, Sunshine Yachts, 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 only apply to aircraft with an airworthiness certificate.

Sun shine Yachts, LLC submits that the requested relief is proper since an
equivalent level of safety will be ensured. Sunshine Yachts, LLC will perform personnel
perform maintenance, alterations, or pr eventive maintenance on the UAS using the
methods, techniq ues, and practices prescribed in the operating documents (i.e., Monthly
Maintenance Log, and DJI Phantom 2 Vision + and DJI Inspire 1 Instruction Manual).

Furthermore, Sunshine Yachts, LLC will document and maintain all maintenance records

for the DJI Phan tom 2 Vision + and DJI Inspire 1 UAS

.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private
pilot privileges and limitations: Pilot in command , is requested by Sunshine Yachts, LLC
to the extent necessary to allow a Pilot in Com mand (PIC) holding a private pilot or
higher level certificate, as well as an airman medical certificate, and who has
demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC
is able to safely operate the DJI Phantom 2 Vision + and 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.

Sunshine Yachts, LLC seeks relief from Section 91.7(a), enti tled Civil aircraft

airworthiness

, because the DJI Phantom 2 Vision + and DJI Inspire 1 UAS do not require
an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such,

Sunshine Yachts, LLC submits that he will ensure that the DJI Phantom 2 Vision + and
DJI Inspire 1 UAS are in an airworthy condition prior to every flight by determining thatthe UAS 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.

Sunshine Yachts, LLC also seeks an exemption from the requirements of Section

91.121, entitled Altimeter Settings , as the DJI Phantom 2 Vision+ and DJI Insp ire 1 UAS
will not have a typi cal barometric altimeter onboard. However, altitude information of the
DJI Phantom 2 Vision + and DJI Inspire 1 UAS will be provided to the PIC via Global
Positioning System (GPS) equipment and radio communications telemetry data link,

which downlinks fr om the UA S to the GP S equipment for active monitoring of the flight
path. This altitude information, combined with Sunshine Yachts, LLC operation of the

DJI Phantom 2 Vision + and DJI Inspire 1 UAS within visual line of sight, at or below

700 feet AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, Sunshine Yachts, LLC seeks an exemption from the requirements of
Section 91.151(b), entitled Fuel requirements for flight in VFR conditions . M Sunshine

Yachts, LLC submits that safety w ill 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). The UAS battery power to fly is a
total duration of approximately 13.5 min utes 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, Sunshine Yachts, LLC provides the
following information in support of its petition fo r exemption:

A. Name And Address Of The Petitioner.
The name and address of the Petitioner and point of contact is:

Morris Neal Fredrick 12130 Sugarloaf Key Street #101 Tampa, FL 33626 239

- 404

- 8662 Email: ssymorris@gmail.com

B. The Specific Section s Of 14 C.F.R. From Which Sunshine Yachts LLC, seeks Exemption.

1. Sunshine Yachts, LLC s eeks Exemption from t he Req uirements Of Section 61.113(a) a nd (b).

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

,
subsection s (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 com pensation or hire, act as PIC of an aircraft. (b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if:

(1) The flight is only incidental to that business or employment; and
(2) The air craft does not carry passengers or property for compensation or

hire.

2. Sunshine Yachts, LLC s eeks Exemption from t he Requirements Of Section 91.7(a).Section 91.7, entitled Civil aircraft airworthiness , subsection (a), states the
following:
(a) No pe rson may operate a civil aircraft unless it is in an airworthy condition.

3. Sunshine Yachts, LLC s eeks Exemption From The Requirements Of Section 91.121.

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

part:

(a ) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

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

-- (i) The current reported altimeter s etting of a station along the route and within 100 nautical miles of the aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; o r (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 departure.

4. Sunshine Yachts, LLC s eeks Exemption from t he Requirements Of Section 91.151(b).

Se ction 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 unless (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.

5. Sunshine Yachts, LLC s eeks Exemption from t he Requirement Of Section 91.405(a).

Section 91.405, entitled Maintenance r equired , subsection (a), states thefollowing: Each o wner 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 secti on, have discrepancies repaired as prescribe d in part 43 of this chapter.

6. Sunshine Yachts, LLC s eeks Exemption From The Requirements Of Section 91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive maintenance,
rebuilding, or alteration

, subsection (a)(1), states the following: (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

— (b) (1) It has been approved for return to service by a person authorized under § 4 3.7 of this chapter. (2)
7. Sunshine Yachts, LLC seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2).

Section 91.409, entitled Inspections , subsection (a), states the following:
(a) Except as provided in paragraph (c) of this s ection, 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.

8. Sunshine Yachts, LLC seeks Exemption from t he Requirements Of Sections 91.417(a) And 91.417(b).

Section 91.417, entitled Maint enance 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 for the periods specified in paragraph (b) of this sec tion: (1) Records of the maintenance, preventive maintenance, and alteration and records of the 100

- hour, annual, progressive, and other required orapproved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propelle r, 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 certif icate number of the person approving the aircraft for return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor. (ii) The current status of life

- limi ted 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 aircra ft, 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, t he method 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 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:

(1) The records specified in paragraph (a)(1) of this se ction 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 air craft is sold. (3) A list of defects 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.C. The Extent o f Relief Sunshine Yacht s, LLC seeks and t he Reason Sunshine Yachts, LLC seeks the r elief.

1. Extent o f Relief and reason Sunshine Yachts, LLC seeks Relief From Section 61.113(a) a nd (b).

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

limitations: P ilot 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 t he
proposed UAS flight operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b)
state that a private pilot may, for compensation or hire, act as PIC of an aircraft in
connection with any b usiness 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, Sunshine Yachts, LLC submits that an equivalen t 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 training hour s

and has demonstrated that the PIC is able to safely operate either the D JI 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, vessels, vehicles and s tructures.

Further, Sunshine Yachts, 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 thisPetition: (1) will be incidental to Sunshine Yachts, LLC business; and (2) will not c arry
passengers or property for compensation or hire.

2. Extent Of Relief Sunshine Yachts, LLC seeks and t he Reason Sunshine Yachts, LLC seeks Relief f rom Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to
the extent required to allow Sunshine Yachts, 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 operat ing documents (i.e., Aerial

Op erations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJI
Inspire 1 Instruction Manual).

Sunshine Yachts, LLC seeks the requested relief because the DJI Phantom 2
Vision+ and DJI Inspire 1 UASs do not require an airworthiness certificat e in accordance
with 14 C.F.R. Part 21, Subpart H. Therefore, Sunshine Yachts, LLC will ensure that the

DJI Phantom 2 Vision+ and DJI Inspire 1 UAS are in airworthy condition based upon its
compliance with the ope rating documents (i.e., Maintenance Log, an d 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 the conditions and

limitations below.

3. Extent Of Relief Sunshine Yachts, LLC se eks and t he Reason Sunshine Yachts, LLC seeks Relief f rom Section 91.121.

Relief from Section 91.121, entitled Altimeter settings , may be required to allow
flight operations of the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS , which utilize a
barometric p ressure sensor, GPS equipment, and a radio communications telemetry data

link to downlink altitude information from the UA V to the PIC at the ground control
station (GCS). Since the FAA requires that any altitude information concerning UASoperations be re ported to air traffic control (ATC) in feet above ground level (AGL),

Sunshine Yachts, LLC seeks the requested relief because the DJI Phantom 2 Vision+ and
DJI Inspire 1 UA V altimeter may be set on the ground to zero feet AGL, rather than the

local bar ometric pressure or field altitude, before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR
91.121 is sought to the extent necessary to comply with the applicable conditions and

limitations stated below. As mor e fully set forth herein, an equivalent level of safety will
be maintained since the DJI Phantom 2 Vision+ and DJI Inspire 1 UA V are equipped
with a barometric pressure sensor and GPS equipment, which automatically ensures that
a ground level pressure sett ing will be established prior to each flight, and provides the

PIC with altitude information of the UA S on the heads

- up display of the GCS.

4. Extent Of Relief Sunshine Yachts, LLC seeks and the Reason Sunshine Yachts, LLC seeks Relief from Section 91.15 1(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 powered DJI
Phantom 2 Vision+ and DJI Inspire 1 UA V during daylight hours in visual

meteorolo gical conditions (VMC), under visual flight rules (VFR), for a total duration of

13.5 minutes each to the first point of intended landing and, assuming normal cruising
speed, to fly after that for at least 4.5 minutes. Sunshine Yachts, LLC seeks the reques ted
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 UA V will severely
constrain the practicality of any aerial video or still photo flight operations that S unshine

Yachts, LLC proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the DJI Phantom 2V ision+ and DJI Inspire 1 UAS , the DJI Phantom 2 Vision+ and DJI Inspire 1 operating

documents, and Su nshine Yachts, LLC proposed operating limitations, ensure that

Sunshine Yachts, LLC will safely operate the battery powered DJI Phantom 2 Vision +
and DJI Inspire 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 Sunshine Yachts, LLC seeks and the Reason Sunshine Yachts, 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, Sunshine Yachts, LLC
requests relief from these Sections because the DJI Phantom 2 Vision + and DJI Inspire 1

UAS do not require airworthiness certificates. As set forth more fully below, the DJI

Phantom 2 Vision+ and DJI Inspire 1 UAS meet th e conditions of FMRA Section 333 for
operation without an airworthiness certificate. Accordingly, Sunshine Yachts, LLC will
use trained technicians to perform maintenance, alterations, or preve ntive maintenance on

the UAS using the methods, techniques, and practices prescribed in the UAS operating
documents (i.e., the A erial Operations Manual, Maintenance Log, and DJI Phantom 2
Vision+ and DJI Inspire 1 Instruction Manual). Furthermore, Sunshine Yachts, LLC will

document and maintain all maintenance records for the DJI Phantom 2 Vision+ and DJI
Inspire 1 UAS

.

D. The Reasons Why Granting Sunshine Yachts, LLC Request w ould be in the Public Interest; that is, how it would benefit the Public as a Whole.

Granting the present Petition will further the public i nterest by allowing Sunshine

Yachts, LLC to safely, efficiently, and economically perform aerial video andphotography of marine vessels, real estate, construction sites and landscape over certain

areas of the United States for the public at a lower cost t han the use of manned aircraft to

do the same

.

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

The DJI Phantom 2 Vision+ and DJI Inspire 1 UA V are battery powered and

serve as a safe, efficient, and economical alternative to the manne d 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 UAV would reduce the amount of manned ai rcraft 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 caused by arrivin g and departing aircraft will be reduced. The

DJI Phantom 2 Vision + and DJI Inspire 1 UA S 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 aircraf t that must be handled by air traffic control during
the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. The Publ ic Will Benefit From The Safety a nd Efficiency Of The DJI Phantom 2 Vision+ and DJI Inspire 1 UAS

.

Conduct ing aerial acquisitions with the DJI Phantom 2 Vision + and DJI Inspire 1

UAS , instead of manned aircraft, will greatly benefit the public by drastically reducing
the levels of air and noise pollution generated during traditional aerial video and stillpho tography flight operations. By using battery power and electric motors, the DJI

Phantom 2 Vision + and DJI Inspire 1 UAS produce no air pollution, and is the most
viable environmentally conscious alternative to the cabin class, six cylinder internal

combus tion 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 of aerial

a cquisitions, also elimin ates noise pollution, as the UAS are propelled by battery powered
electric motors, rather than an internal combustion engine.

By using the DJI Phantom 2 Vision + and DJI Inspire 1 UAS to perform aerial
acquisitions, the substantia l 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

onboard the aircraft, the DJI Phantom 2 Vision + and DJI Inspire 1 UA V (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
approximately 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 Vi deo and Photography Operations with t he DJI Phantom 2 Vision+ and DJI Inspire 1 UAS w ill Benefit The Economy.In addit ion to being safe and efficient, the DJI Phantom 2 Vision + and DJI
Inspire 1 UAS 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 UAS will allow United States based companies, like Sunshine Yachts, 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 phasi ng 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 UAS is one such technology
that not only allows companies greater operational flexibility compared to manned
aircraft, but provides such flexibility without the high operational cost of a traditional

manned aircraft.

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

as Sun shine Yachts, 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,
through c ommercial use of the DJI Phantom 2 Vision + and DJI Inspire 1 UAS , 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, Sunshine Yachts, LLC proposed operation of the DJI Phantom 2 Vision+ andDJI Inspire 1 UAS would not implicate any privacy issues. Specifically, the DJI Phantom

2 Vision+ and DJI Inspire 1 UAS will be operated only in compliance with operating
documents (i.e., the Aerial Operatio ns Manual, Maintenance Log, and DJI Phantom 2

Vis ion+ and DJI Inspire 1 Instruction Manual) which requires property owner

involvement as well as local law enforcement notification, and in accordance with the
Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R.

§ 91.119.

E. The Reasons Wh y Granting The Exemption w ould not adversely a ffect the Safety, or how t he Exemption W ould Provide a Level Of Safety at least equal t o t hat Provided By The Rule from w hich Sunshine Yachts, LLC s eeks Exemption.

1. Reasons Why The DJI P hantom 2 Vision + and DJI Inspire 1 UA S 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 unmanned aircraft and its operati on, Sunshine Yachts, LLC operation of the DJI

Phantom 2 Vision+ and DJ I Inspire 1 UAS meet the conditions of FMRA Section 333,
and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21,
Subpart H.

Section 333 provides authori ty 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 security.

Specifically, FMRA Section 333 states the following, in part:

(a) In General

. - - Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft sys tems may operate safely in the national airspace system before completion of the planand rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act.

(b) Assessment of Unmanned Aircraft Systems

. - - In making the det ermination 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 certification 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, Sunshine Yachts, LLC submits that the DJI Phantom 2

Vision + and DJI Inspire 1 UAS 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 UAS ; (b) the pilot certification requirement; and (c) the speci fic
operating limitations.

a. The Specifications Of The DJI Phantom 2 Vision + and DJI Inspire 1 UAS Demonstrate Its Safe Characteristics.

The DJI Phantom 2 Vision + and DJI Inspire 1 UAS do not create a hazard to
users of the NAS or the public, or othe rwise 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 UAS

.

The technical specifications of the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS
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 UAS Autonomous Flight And Navigation Modes Enable The UAS To Remain Within A Defined Operational Area.

The DJI Phantom 2 Vision+ and DJI Inspire 1 UAS 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 D JI Inspire 1 UAS is provided in

the User Manuals.

iii. The DJI Phantom 2 Vision + and DJI Inspire 1 UAS Are Designed For Automatic Return To Home 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 UA V will assume that the Contr ol Link is lost and the UA V will return to the
home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and

shutdown.
A complete description of the Failsafe Functions of the DJI Phantom 2 Vision +

UAS are set forth in the User Manuals.

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 32
through 43 of the DJI Phantom 2 Vision+ User Manual and pages 40 through 47 of the
DJI Inspire 1 User Manual s

.b. Flight Operations Of DJI Phantom 2 Vision + and DJI Inspire 1 UAS Are Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safe ty Observer.

Sunshine Yachts, LLC will only utilize certificated pilots who possess a current
and valid airman medical certificate to act as a pilot in command (PIC) of the DJI

Phantom 2 Vision + and DJI In spire 1 UAS . Additionally, a safety observer wil l assist all
pilots during flight time.

c. Flights Of DJI Phantom 2 Vision + and DJI Inspire 1 UAS Will Be Conducted Pursuant To Specific Operating Limitations.

In seeking this exemption, Sunshine Yachts, LLC proposes to commercially
operate DJI Phant om 2 Vision + and DJI Inspire 1 UAS for the special purpose of
conducting aerial video and photography over certain areas of United States, pursuant to
the following specific operating limitations:

1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the oper ating documents, rotorcraft UAS 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 87 knots.

4. The UA S 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 UA S must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued air man medical certificate.
6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted.7. All operations may utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC always maint ains VLOS capability. The SO and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for t he duration of the flight. The PIC must ensure that the SO can perform the functions prescribed in the operating documents.
8. The SO may not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground ba sed obstacles/obstructions and is not permitted to operate the camera or other instruments.
9. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepa ncy 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 of 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 revisions and present updated and revised documents to the Admini strator 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 or revision would affect the basis upon which the FAA grante d the exemption, then the operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operating documents.
10. Prior to each flight th e 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 operating until the necessary maintenance has been performed a nd 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 aircraft records.
11. Any UAS that has undergone mainten ance 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 flight 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 operator must follow the UAS manufacturer’s a ircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements.
14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, 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 accomplished, and the signature of the authorized personreturning the UAS to service.

15. E ach 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.
18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to s afely 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 qualification flight hou rs 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 sessio ns. 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 with 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 unless 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 u pon 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 ret urn to a pre

- 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 operati ng documents.
24. The 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 obtain 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 (N OTAM) 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 transpond er requirements.
26. All aircraft 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 practicable.
27. Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight age ncy requirements.
28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS 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 must remain clear and yield the right of way to all manned aviation operations and activities at all times.
30. The UAS may not be operated by the PIC from any moving device or vehicle.
31. Flight operatio ns must be conducted at least 500 feet from all nonparticipating 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

n onparticipating 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 50 0 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 as sessment 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 PIC, SO, operator trainees 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 controlled

- access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for e ach 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.

Sunshine Yachts, LLC submits that 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 DJ I 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.

Considering Sunshine Yachts, LLC 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 ( See Exemption No. 11062); and
the airmanship skills necessary to safely operate the DJI Phantom 2 Vision + or DJI
Inspire 1 UAS, Sunshine Yachts, LLC submits that the additiona l manned airmanship
experience of a commercially certificated pilot would not correlate to the airmanship
skills necessary for Sunshine Yachts, LLC 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 those 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).Suns hine Yachts, LLC will not allow any PIC to operate the DJI Phantom 2

Vision + 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 requir ements, 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 st ructures.

Specifically, 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 mode l of
UAS to be used for operations under the exemption). In addition to the hour
requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days
(for currency purposes).

As in Exemption Nos. 11062, 11138, and 11153, prior documente d flight
experience that was obtained in compliance with applicable regulations will ensure an
equivalent level of safety during Sunshine Yachts, 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 operating the same make and model of UAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than additi ve; i.e. 5 hours make and model time may be included in the 10 hours of multi

- rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding90 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 opera tions. 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 ex emption to accomplish the required flight time. During training, proficiency, 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 on page 15.

Accordin gly, Sunshine Yachts, 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 saf ely 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 Exempt ion From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.7(a) will be maintained
because prior to every flight, Sunshine Yachts, LLC will ensure that the DJI Phantom 2

Vision + or DJI Inspire 1 UAV is in an airworth y condition based upon the UAS
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 UA S, 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 w hy An Exemption From The Requirements Of Section 91.121Would 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 telemetry
data link, which downlinks from the UA to the GCS for active monitoring of the flight
path and altitude. This altitude information, combined with Sunshine Yachts, LLC

op eration of the DJI Phantom 2 Vision + and DJI Inspire 1 UAS within visual line 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. Prior to each flight, a zero altitude initiation point is autom atically
established by the UAS at ground level.

The FAA has previously granted relief from Section 91.121 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, 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 equivalent 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 UAS; (2) the limi tations on the proposed flight
operations; and (3) the location of the proposed flight operations. Accordingly, Sunshine

Yachts, LLC will ensure that it will safely operate the battery powered DJI Phantom 2
Vision+ and DJI Inspire 1 UAS during daylight hou rs 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 techn ical specifications of the DJI Phantom

2 Vision + and DJI Inspire 1 UAS ; the limitations on the proposed flight operations; and
the location of the proposed operations, will ensure an equivalent level of safety
established by 14 C.F.R. Section 91.151(b). F urthermore, safety will be ensured as the

DJI Phantom 2 Vision + and DJI Inspire 1 UAS 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 batter y power, and again at approximately
10% remaining battery power. At the critically low battery level, the DJI Phanto m
Vision+ and DJI Inspire 1 UAS will descend and land automatically.

Significantly, previous exemptions granted by the FAA concerning Sect ion
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 previously granted
relief from Section 91.151 specific to UAS, in circumstances similar, in all material
respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11 042,

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 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 9 1.417(a) & (b) Would Not Adversely Affect Safety.

In seeking this exemption, Sunshine Yachts, LLC submits that the equivalent
level of safety with regard to the regulatory maintenance and alteration requirements
established by Sections 91.405(a), 91.407( a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) &
(b) will be met because Sunshine Yachts, LLC will use trained technicians to performmaintenance, alterations, or preventive maintenance on the UAS using the methods,
techniques, and practices prescribed in the operating documents (i.e., the Sunshine

Yachts, LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2

Vision + and DJI Inspire 1 Instruction Manual). Furthermore, Sunshine Yachts, LLC will

document and maintain all maintenance records f or the DJI Phantom 2 Vision + and DJI
Inspire 1 UAS.

Since the DJI Phantom 2 Vision + and DJI Inspire 1 UAS will be inspected as
prescribed by the operating documents, Sunshine Yachts, LLC will maintain the
equivalent level of safety established by Secti ons 91.405(a), 91.409(a)(1), and
91.409(a)(2). A copy of the DJI 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 Exhi bit E.

Likewise, the exemption sought will not adversely affect safety because Sunshine

Yachts, LLC use trained technicians to perform maintenance, alterations or preventive
maintenance on the UAS using the methods, techniques, and practices prescribed b y the
operating documents.

Furthermore, the exemption sought 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 UAS will be performe d 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) e stablish that safety
is not adversely affected when the technical characteristics and operating limitations ofthe UAS are considered.

In consideration of Sunshine Yachts, LLC proposed operating limitations, the
operating documents, and the technical asp ects of the DJI Phantom 2 Vision + and DJI
Inspire 1 UAS, Sunshine Yachts, 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 Prescribe 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

, Sunshine Yachts, L LC
requests that the FAA prescribe special conditions for the intended operation of the DJI

Phantom 2 Vision + and DJI Inspire 1 UAS , which contain such safety standards that the
Administrator finds necessary to establish a level of safety equivalent to th at established
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 limit ed
purpose of conducting aerial video and photography 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

ot herwise pose a threat to national security; and further, provides the authority for such
UAS to operate without airworthiness certification in accordance with any requirementsthat must be established for the safe operation of the UAS in the NAS.

Likewis e, the Administrator may prescribe special c onditions pursuant to 14

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

, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or
appropriate safety s tandards, due to the novel or unusual design features 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 propeller because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain 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 UAS , which contain such safety standards that the

Admi nistrator 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).

• A Summary That Can Be Published in t he Federal Register, stating: the rules from w hich Sunshine Yachts, LLC seeks e xemption:

Sunshine Yachts, 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 e xemption Sunshine Yachts, LLC

s eeks:This exemption will permit Sunshine Yachts, 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.

• Any additional information, views, or arguments available to s upport Sunshine Yachts, LLC can be by r equest.

This Petition is made pursuant to the FAA Modernizat ion and Reform Act of

2012.

( FMRA) Section 333, which direct the Secretary of Transportation to determine if certain
UAS may operate safely in the NAS. As such, Sunshine Yachts, LLC request for
exemption may be granted pursuant to the authority of FMRA Se ction 333 and 14 C.F.R.

Part 11, as set forth above.

FMRA Section 333 sets forth the requirements for considering whether a UAS
will create a hazard to users of the NAS or the public, or otherwise pose a threat to
national security; and further, provides the authority for such UAS to operate without

airworthiness certification.

As discussed in detail above, Sunshine Yachts, LLC will operate the DJI Phantom
2 Vision+ and DJI Inspire 1 UAS safely in the NAS, without creating a hazard to users of

the NAS, or the public, or otherwise pose a threat to national security.CONCLUSION

As set forth herein, Sunshine Yachts, 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), whi ch will permit safe operation of the DJI Phantom 2 Vision + and DJI Inspire
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 t his Petition, the FAA Administrator will be fulfilling the Congressional
mandate of the FAA Modernization and Reform Act of 2012, while also advancing the
interests of the public, by allowing M Sunshine Yachts, LLC to safely, efficiently, and
economically operate the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS commercially

within the NAS.

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

Modernization and Reform Act of 2012, Section 333, Sunshine Yachts, LLC respectfully

requests that the Administrator grant this Petition for an exemption from the requirements
of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a),
91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Leading Edge 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.Dated: June 30 , 2015

Respectfully submitted,

Sunshine Yachts, LLC

_________________________ 12130 Sugarloaf Key Street #101 Tampa, FL 33626 239

- 404

- 8662
ssymorris@gmail.com

Appendices :

A

– DJI Phantom 2 Vision+ Specifications Data Sheet B

– DJI Inspire 1 Specifications Data Sh eetAPPENDIX

– A
DJI PHANTOM 2 VISION + TECHNICAL SPECIFICATIONS

Sunshine Yachts, LLC only utilizes safe and reliable UAS . DJI is an industry leader i n small UAS production. DJI, UAS are loaded with ground breaking software ena bling 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, D JI software provides real

time altitude and 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 & Prop ellers Included)

– 2lbs 11.810oz (1242g) 1.1.1.3 Hover Accuracy (Ready to Fly)

– Vertical: .8m; Horizontal: 2.5m 1.1.1.4 Max Yaw Angular Velocity

- 200 /s 1.1.1.5 Max Tilt Angel

- 35 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 1.1 .2.3 Controllable Range

– Pitch:

- 90

- 0 1.1.2.4 Maximum Angular Speed

– Pitch: 90 /s

1.1.3 Camera 1.1.3.1 Operating Temperature Range

- 32 F

- 104 F (0 C

- 40 C) 1.1.3.2 Sensor Size

– 1/2.3” 1.1.3.3 Effective Pixels

– 14M 1.1.3.4 Resolution

– 4384x3288 4.1.3.5 HD Video Recording

– 1080p30 & 720p 4.1.3.6 Recording Field of View

- 110 /85

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: 100mW1.1.4.5 Working Voltage

– 120mA@3.7V
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

– 20dB m 1.1.5.4 Power Consumption

– 2W

APPENDIX

– B
DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

Sunshine Yachts, LLC only utilizes safe and reliable UAS . DJI is an industry leader i n small UAS production. DJI, UAS 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, DJI so ftware 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	Ac curacy	(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	Ascent	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:	750m A;	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	Camera2.2.3.1	Name

– X3 2.2.3.2	Model

– FC350 2.2.3.3	Total	Pixels

– 12.76M 2.2.3.4	Effective	Pixels

– 12.4M 2.2.3.5	Image	Max	Size

– 4000x3000 2.2.3.6	ISO	Range

– 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	Oper ating	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	2S