January 10, 2016

Attn: U.S Dept ofTransformation Docket Operations. WestBuildingGround Floor, Room w 12-140 1200 NewJerseyAve, SE Washington DC 20590

RE: Information Exchange Service .**~** i _., .i '_:.**~: ~**  '

'' l**(~** '



## .

RequestAn Exemption From The Requirements ofTitle 14ofthe Code ofFederal Regulations Section 61.113(a) & (b),91.7,91.121,91.151(b),91.405(a),91.407((a)(1),91.409(a)(1) & . ·'·

(a)(2), and 91.417(a) &(b) ConcerningCommercial OperationofD}l Phonation 3 UnmannedAircraft Systems Pursuantto Section 333 ofthe FAA Modernization and Reform actof2012 (Public Law 112-95

William CPrice Company owner Information Exchange Service 355 LangAve PassChristian Ms. 39571 985 285 2597 bcp175@yahoo.com

1

### SUMMARY Information Exchange Service seeks exemption from the requirements of 14 

### C.F.R §§ 61.113(a) 

### &(b), 

### 91.7(a), 91.121, 91.151(b), 91.405{a), 91.407(a)(l), 91.409(a)(l) 

### &(a)(2), and 91.417(a) & 

### (b), to operate an Unmanned Aircraft System (Dil Phantom 3) pursuant to Section 333 ofthe FAA 

### Modernization and Reform Act of2012 (FMRA). 

### This exemption will permit Information Exchange Service to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial photography of Insurance Underwriting Inspection sites , construction sites, residential and commercial real estate, civil landscapes and events over certain areas ofthe United States. 

### INTRODUCIIQN 

## AND INTER£STS OF THE PETITIONER Information Exchange Service has for overthirty-five years providedtheir clients with insurance inspection service. The objective ofInformation Exchange Service and our Unmanned Aircraft System (Dil Phantom 3) aerial photography operations is to provide a more affordable, highquality aerial photographs for ourInsurance Underwriterclients.
Mystaffhassafelyflown smallRC electricquadcopters recreationallyforapproximately 1.5 years without incident. BACKGROUND Unmanned Aircraft Systems: DnPhantom 3, UAS Information Exchange Service seeks an exemption to operate Dll Phantom 3 system for compensation or hire within the NAS. The Dll Phantom 3 is vertical takeoff and landing 

### {VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The Dll Phantom 3 has a maximum gross weight of approximately 2.8 lb. while having a diagonal dimension of 23.2", a maximum speed of approximately 16.4'fps and a maximum flying height of 1000'. The 

### Dn Phantom 3 is equipped with four main rotors; driven by Lithium Polymerbatterypoweredelectric motors.

2The Phantom 3 that will be operated by Information Exchange Service will be registered in accordance with 49 V.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.



## BASISfOR PETITION Petitioner ,1nfi:m:nation Exchange Service, pursuant to the provisions ofthe Federal Aviation Regulations (14C.F.R. 

### § 11.61)andtheFAAModernization andReform Actof2012(FMRA), Section 333,

### SpecialRules for Certain UnmannedAircraftSystems, hereby petitionsthe AdministratortocommerciallyoperatetheDilPhantom 3,VASintheNationalAirspace System (NAS),andforanexemption fromtherequirements of 14C.F.R

### §§ 6l.l13(a)&(b),91.7(a), 91.121, 91.15l(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and91.417(a) & (b).
In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, The ALTEK MEDIA GROUP operation ofDJI Phantom 3 VAS meets the conditions ofFMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.P.R. Part21, SubpartH. Accordingly, The ALTEK MEDIA GROUP requests relief from Sections 91.405(a), 91.407(a)(l), 9 J.409(a)(l) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate. TheInformation Exchange Service submits that the requested reliefis proper since an equivalent level ofsafety will 

### be ensured. Information Exchange Service will use experienced personnel or technicians to perform maintenance, alterations, orpreventive maintenance on the UAS usingthe methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual). Furthermore, Information Exchange Service will document and maintain a11 maintenance records for the Dil Phantom 3 UAS. Relieffrom certain requirements of Section 61.113(a) and (b), entitled 

### Privatepilotprivileges andlimitations: Pilot in command, is requested by Information Exchange Service to the extent necessary to allow a Pilot in Command (PIC) holding a private pilot orhigher level certificate, as well as an airman medical certificate, and who has demonstrated, by meeting minimum flighthour and currency requirements, that the PIC is able to safely operate the Dil Phantom UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. The Information Exchange Service seeks relief from Section 91.7(a), entitled 

### Civil aircraft airworthiness, because the Dn Phantom 3 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, The Information Exchange Service submits that they will ensure that the Dil Phantom 3 UAS is in an airworthy condition, prior to every flight, by determining that the UAS are in compliance with the operating documents (i.e., Montly Maintenance Log, and on Phantom 3 Instruction Manual), and that the aircraft are in a condition for safe flight.

3Information Exchange Service also seeks an exemption from therequirements ofSection 91.121, entitled Altimeter Settings, as the 

# on Phantom 3 UAS will not have a typical barometric altimeteronboard. However, altitude information ofthe

## on Phantom 3 UAS will 

### be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring ofthe flight path. This altitude information, combined with Information exchange Services operation of the 

# on Phantom 3 UAS within visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalentto Section 91.121. Additionally, Information Exchange Service seeks an exemption from the requirements of Section 91.15l(b), entitled Fuelrequirementslor flight in VFR conditions. InformationExchange Service submits that safety will not be affected by operation ofthe 

## on Phantom 3 UAS during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration of approximately 23 minutes. Battery power indicators are also able to show exactly how much battery power is left, as well as how much time is needed to return safelybacktopointoftake off.
In accordance with 14 C.F.R. 

### § 11.81, InformationExchange Service providesthe following information in support ofits petitionforexemption:

A. NameAnd AddressOfThePetitioner. The name and address ofthe Petitionerand point ofcontact is:
William C Price Owner Information Exchange Service 355 LangAve PassChristianMs. 39571 985 285 2597 bcp175@yahoo.com

4B. The Specific Sections Of 14C.F.RFrom Which Information Exchange Service Seeks Exemption. 

### 1. Information Exchange Service Seeks Exemption From The Requirements OfSection 61.113(a)And(b). Section 61.113, entitled Private pilot privileges and limitations: 

### Pilot in command, subsections (a) and (b) prescribethe following, 

### in relevant part: (a) No person who holds aprivate pilot certificate may act as a pilot 

### in command (PIC) ofan aircraft that is carrying passengers or property for compensation or hire;
normay thatperson, for compensation orhire, act as PIC ofan aircraft. (b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connectionwithanybusinessoremployment

### if- ( I) The flight is only incidentaltothatbusiness oremployment; and (2) The aircraft does notcarry passengers orproperty for compensation or hire. 

### 2 Information Exchange Service Seeks Exemption From The Requirements OfSection 91.7(a).Section 91.7, entitled 

### Civilaircraftairworthiness, subsection (a), states the following: (a)Noperson may operate a civil aircraftunless it is in an airworthy condition. Information Exchange Service Seeks Exemption From The Requirements OfSection 91.121. Section 91.121, entitledAltimeter settings, subsection (a), statesthe 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-- (I) Below 18,000 feet MSL, to-- (i) The current reported altimeter setting of a station along the route and within 100 nautical miles ofthe aircraft; (ii) 

### If there is no station within the area prescribed in paragraph (a)(l)(i) of this section, the current reported altimeter setting ofan appropriate available station; or (iii) In the case ofan aircraft not equipped with a radio, the elevation ofthe departure airport or an appropriate altimeter setting available before departure.

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### 4. Information Exchange Service Seeks Exemption From The Requirements OfSection 9LISI(b).
Section 91.151, entitled

### Fuel requirements for flight in VFRconditions, subsection (b), statesthe following: {b) 

### No person may begin aflight in a rotorcraft under VFR conditions unless (considering wind and 

### forecast weather conditions) there is enoughfuel to fly to the firstpoint of intendedlanding and, assuming normal cruisingspeed, to fly after that foratleast20 minutes. 

### 5. Information Exchange Service Seeks Exemption From The Requirement OfSection 91.40S(a). Section91.405,entitled

### Maintenance required, subsection(a), statesthefollowing: Each
owner oroperatorofan 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 part43 ofthis chapter[.] 

### 6. InformationExchange service SeeksExemption From The Requirements Of Section 91.407(a)(l) Section 91.407, entitled 

### Operation after maintenance, preventive maintenance, rebuilding, oralteration, subsection (a){l), states the following: (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, oralteration unless-- (1) Ithas been approved for return to service by a person authorized under§ 43.7 ofthis chapter[.] 

### 7. Information Exchange Service Seeks Exemption From The Requirements OfSections 91.409(a)(l)And91.409(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, ithas had

- (I) Anannual inspectionin accordance with part43 ofthis chapterandhas been approved for return to serviceby a person authorized by § 43.7 ofthischapter; or (2) An inspection forthe issuanceofan airworthiness certificate in accordance with part 21 ofthis chapter.

68. InformationExchange Service SeeksExemptionFromThe Requirements OfSections 91.417(a)And 91.417(b). Section 91.417, entitledMaintenance records, subsections (a) and (b), state the following: (a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner oroperator shall keep the following records for the periods specified in paragraph (b) ofthis section : 

### (I) ) Records of the maintenance, preventive maintenance , and alteration and records of the 100-hour, annual, progressive, and other required or approved inspections-, as appropriate, for each aircraft (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 Administrator) ofthe workperformed; and (ii) Thedate ofcompletion ofthe workperformed ;and (iii)The signature, and certificate number ofthe person approving the aircraft forreturn to service. (2)Recordscontainingthe following information: (i) The total time in service ofthe airframe, each engine, each propeller, and eachrotor.

(ii) The current status oflife-limited parts ofeach airframe, engine, propeller, rotor, and appliance.

(iii) The time since last overhaul ofall items installed on the aircraft which
arerequired tobeoverhauled on a specified time basis. (iv) The current inspection status ofthe aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action,thetime and date whenthenext 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.

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### (b) The owneroroperator shall retain the following records forthe periods prescribed: (1) The records specified in paragraph (a)(I) ofthis section shaJJ be retained until the work is repeated or superseded by other work or for I year after the work is performed. (2) The records specified in paragraph (a)(2) ofthis section shaH be retained and transferred with the aircraftatthe timethe aircraftissold. (3) A list ofdefects furnished to a registered owner oroperator under§ 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved forreturn toservice.



### C. The Extent OfRelief Seeks And The Reason The Information Exchange Service Seeks TheRelief. 

### 1. Extent OfReliefInformation Exchange Service Seeks And The Reason Information ExchangeSeeksReliefFromSection61.113( a)And

### (b). Relieffrom Section 61.1 13(a) and (b) entitled Privatepilotprivileges andlimitations: Pilot in command, is requested to the extent necessary to a11ow 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, toconductthe proposedUAS flight operations for compensation orhire. This reliefis requested since the limitations set forth in Section 6Ll13(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business oremployment if: (1)The flight is only incidental to that business oremployment; and (2)Theaircraft doesnotcarrypassengers orproperty forcompensation orhire. As set forth more fruly below, Information Exchan_.ge Service submits that an**~uivalent** level ofsafety will be maintained because no PIC wilrbe allowed to operate the DJi Phantom 3 UAS unless that PIC has met certain flig4t-hour and currency requirements, demonstrating that the PIC is able to safely operate eitherthe dji Phantom 3 OAS 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 structures. Further, Information Exchange Service submits that all flights of the Dji Phantom 3 UAS, conducted by the PIC pursuanttothe grant ofthis Petition: (I)will be incidental to Information Exchange Service's business; and (2) will not carry passengers orproperty for compensation or hire. ti

82. Extent Of Relief Information Exchange Service Seeks And The Reason Information Exchange Service SeeksReliefFrom Section 91.7(a). Relief from Section 91.7(a) entitled 

### Civil aircraft air-worthiness, is requested to the extent requiredto allow TheInformation Exchange Service to determine thatthe DJI Phantom 3 UAS are 

### in airworthy condition prior to every flight by ensuring that the DAS is in compliance with the operating documents (i.e., Information Exchange Service Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual). The Information Exchange Service seeks the requested reliefbecause the DJI Phantom 3 

### VAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Information Exchange Service will ensure that the DJI Phantom 3 DAS are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, andDJI Phantom 3)priorto every flight, and further, determine thatthe aircraft
are in condition for safeflight, as stated 

### in the conditions and limitations below.

3. Extent Of Relief Information Exchange Service Seeks And The Reason Information Exchange Service Seeks ReliefFrom Section 91.121. Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the DJI Phantom 3 UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), Information Exchange Service seeks the requested reliefbecause the Dji Phantom 3 UA's altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure orfield altitude, before each flight. Considering the limited altitude ofthe proposed operations, relieffrom 14 CFR 91.121 is sought to the extent necessary to comply with the applicable conditions and limitations stated below. As
more fully set forth herein, an equivalent level of safety will be maintained since the DJI Phantom 3 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, andprovidesthe PIC with altitude information ofthe UA ontheheads-up display ofthe GCS.

4. Extent Of Relief Information Exchange Service Seeks And The Reason Information Exchange Service Seeks ReliefFrom Section 9LISJ(b). Relieffrom Section91.15l(b) entitled Fuel requirements for flight in VFRconditions, is requested to the extent requiredto allow flights ofthe battery powered on Phantom 3 UAS during daylighthours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of23 minutes. Information Exchange Service seeksthe requested relief because without an exemption from Section 91.15l(b), the flight time duration of the

9battery powered Phantom 3 UAS will severely constrain the practicality ofany aerial video or still photo flight operations that Information Exchange Service proposes to conduct pursuant to this Petition. Significantly, as set forth below, the technical specifications ofthe DJIPhantom 3 UAS, the DH Phantom 3 operating documents, and Information Exchange Service proposed operating limitations, ensure that Information Exchange Service will safely operate the battery powered DJI Phantom 3 UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery powertofly fora total duration of23 minutes.

5. Extent OfReliefInformation Exchange Service Seeks And The Reason we seeks Relief From Sections 9l.405(a), 91.407(a)(l), 9l.409(a)(l) 

### & (a)(2), And 9L417(a)

### &(b). Since Sections 91.405(a), 91.407(a)(l ), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, We request relief from these Sections because the DJI Phantom 3 UAS do not require airworthiness certificates. As set forth more fully below, the DJI Phantom 3 UAS meetthe conditions ofFMRA Section 333 for operation without an airworthiness certificate. Accordingly, We will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the , Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual). Furthermore, wewill document and maintain all maintenance records forthe DJIPhantom 3 UAS.

D. The Reasons Why Granting Information Exchange Service's Request Would Be 

### In The Public Interest; That Is, HowIt Would BenefitThePublicAs A Whole. Granting the present Petition will further the public interest by allowing Information Exchange Service to safely, efficiently, and economically perform aerial photography of Insurance Underwriting Inspections Sites, construction sites, real estate, events and civic landscape over certainareas ofthe United States. Additionally, use of the Dji Phantom 3 UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits ofInformation Exchange Severice proposed operation of the DJI Phantom 3 UAS will be realized without implicatingany privacy issues.



### 1. The Public Will BenefitFromDecreased Congestion OfThe NAS. The DJI Phantom 3 UAS are batterypoweredand serve as a safe, efficient, and economical alternativetothe manned aircrafttraditionally utilized to obtain aerial imagery. Byreducing the

10amount ofmanned aircraft needed to perform aerial acquisitions, an exemption allowing the use ofa DJI Phantom 

### 3 UAS would reduce the amount ofmanned aircraft in the NAS, reduce noise and airpollution, as well as increase the safety oflife 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 arriving and departing aircraft will be reduced. The Djl Phantom 3 DAS do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. ThePublicWillBenefitFromTheSafetyAnd Efficiency OfTheDJIPhantom3UAS. Conducting aerial acquisitions with the 

### Dji Phantom 3 UAS, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels ofair and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, the Dji Phantom 3 UAS produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically utilized for aerial video and photography, while burning approximately 2030 gallons per hour of leaded aviation fuel. The Dji Phantom 3 UAS, while reducing the carbon footprint ofaerial acquisitions, also eliminates noise pollution, as the UAS are propelled bybatterypowered electric motors, ratherthan an internal combustion engine. By using the Dji Phantom 

### 3 UAS to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated

. Aside from the lack of flight crew members located onboard the aircraft, the DJI Phantom 3 UAS (weighing approximately 2.8 pounds at their maximum gross weight with diagonal dimension of 23.2 inches, and with no fuel on board), has less physical potential for co11ateral 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 ofapproximately 42 feet, a length of34 feet, and a fuel capacity of 180 gallons). 3. PerformingAerial VideoandPhotography Operations With TheDJIPhantom 3UAS Will BenefitTheEconomy. Inaddition tobeing safe and efficient, the DJIPhantom 3 UAS are also an economical alternative to usingmanned aircraft to conduct similar aerial operations. As such, operation of the Dji Phantom 3 UAS will allow United States based companies, like Information Exchange Service, to remain competitive and contributeto growth ofthe U.S. economy. Specifically, with the rising costofaviation fuel and the Environmental Protection Agency ("EPA") regulatory actionsphasing outleaded aviation fuels, U.S. owned and operated companies must adoptnew and alternative technology in ordertoremain competitive. Operatingthe batterypowered DTI Phantom 3 UAS is one such technology that not only allows companies greater operational

11flexibility compared to manned aircraft, but provides such flexibility without the high operational costofatraditional mannedaircraft. By operating the DJI Phantom 3 UAS, companies such as Information Exchange Service, can remain competitive and profitable, and therefore, provide greaterjob stability to employees and contractors, which will ultimately contributetogrowth ofthe U.S. economy. Improved financial performance ofU.S. companies, through commercial use ofthe DJI Phantom 3 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 competitiveboth intheUnited Statesand abroad.

4. ThereAreNoPrivacyIssues. Similarto the manned aerial acquisition flight operations that have been conducted for decades, Information Exchange Services proposed operation of the DJI Phantom 3 UAS will not implicate any privacy issues. Specifically, the DJI Phantom 3 UAS will be operated only in compliance with operating documents (i.e., Aerial Operations Manual, Monthly Maintenance Log, and DJIPhantom 3 Instruction Manual) which requires property owner involvement as wll
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 Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided ByTheRuleFrom Which Information Exchange Service SeeksExemption.
I. Reasons Why The DJI Phantom 3 UAS Meet The Conditions Of The FAA Modernization andReformActof2012(FMRA) Section 333. In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, Information Exchange Service 's operation of the 

## on Phantom 3 UAS meettheconditions ofFMRA Section 333,and will notrequire an airworthiness certificateinaccordance with 14C.F.R.Part21, SubpartH. Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements forconsidering whether aUAS will create ahazard to users oftheNAS orthe public, orotherwisepose a threatto national security. Specifically, FMRA Section 333 statesthe following, inpart: (a) In General.--Notwithstandingany other requirement of this subtitle, andnotlater than 180days afterthe date of enactment of thisAct, the Secretary of Transportation shall determine 

### if certain unmanned aircraft systems may operate safely in the nationalairspace system before completion of theplan and rulemaking required by section 332ofthisActortheguidance requiredbysection 334of thisAct.

12(b) 

### Assessment ofUnmannedAircraft Systems.--ln making the determination under subsection (a), the Secretaryshalldetermine, ata minimum-- 

## OJ which types ofunmannedaircraft systems, 

### if any, as a result of their size, weight, speed, operational capability, proximity to airports andpopulated areas, andoperation within visual line of sight do not create a hazardto users ofthe national airspace system or the public orpose a threat to national security; and 

### (2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 oftitle 49, United States Code, is requiredfor the operation ofunmanned aircraft systems identified underparagraph (1). (c) Requirementsfor Safe Operation.--lfthe 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 ofsuch aircraft5ystems in the nationalairspace system. In seeking this exemption, Infonnation Exchange Service submits that the DJI Phantom 3 UAS
can operate safely 

### in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics ofthe DJI Phantom 3 UAS; (b) the pilot certification requirement ; and (c) the

. specific operating limitations.

a.TheSpecifications OfTheDnPhantom3UASDemonstrateItsSafeCharacteristics. The DJI Phantom 3 UAS does not create a hazard to users ofthe NAS orthe public, orotherwise pose athreatto national security considering its size, weight, speed, and operational capability. 

### i. Technical SpecificationsOfTheDJIPhantom3UAS. The technical specifications ofthe OJI Phantom 3 UAS are set forth by the DJI Phantom 3 User Manual, attached hereto as Appendix A. ii.TheDJIPhantom3UASGlobal PositioningModesEnableTheUASToRemain WithinA De:fmed OperationalArea. The DJI Phantom 3 UAS may be operated in both manual and global positioning flight modes. A complete description ofthe flight and navigational modes ofthe DJI Phantom 3 UAS is provided at pages 11 ofthe DJI Phantom 3 UserManual attached hereto as Appendix A. 

### iii.TheDJIPhantom 3UASAreDesigned ForAutomaticReturn ToHomePoint OrHoverInTheEvent OfLossOfTheControlLinkOrNavigation. When the Control Link is Jost, the DJI Phantom 3 UAS will remain stationary, in flight, for 3 secondsormore. If,

### after 3 seconds,theDJIPhantom 3UAS doesnotreacquire control linkdata from the GCS,theUAS will assumethatthe Control Link islostandthe will 

### return tothehome position (i.e.,failsafemode)viaGPS,andwilldescendto

### thetakeoffpositionandshutdown.

13A complete description ofthe Failsafe Functions ofthe DTI Phantom 3 UAS are set forth at pages 12 through 14 ofthe DJI Phantom 3 User Manual. iv. The DJIPhantom 3 GCS And ItsOperation. A complete description ofthe operation and specifications ofthe DTI Phantom 3 GCS and flight control software is provided at pages 23 through 29 of the DJI Phantom 3 User Manual. DJI Phantom 3 UserManual is attached hereto as Appendix A.
b. Flight Operations OfDJI Phantom 3 UAS Is Limited ToTheLine OfSight OfA Certificated Pilot in CommandWith A Safety Observer. Information Exchange Services staffwill be the only persons to act as a pilot in command (PIC) ofthe DJI Phantom 3 UAS. Additionally, a safety observer will assist him at all times during flight time.

c. Flights OfDJIPhantom 3 UAS Will Be Conducted Pursuant To Specific Operating Limitations.
In seeking this exemption, Information Exchange Service proposes to commercially operate DJI Phantom 3 UAS for the special purpose ofconducting aerial photography over certain areas of United States, pursuantto the following specific operating limitations. 

### 1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UAS weighing less than 55 pounds maximum gross weight: DJI Phantom 3 Unmanned Aircraft Systems. Proposed operations of any other aircraft will require a new petition or a petition to amendthis grant

2. UAS operations under this exemption will be limited to conducting operations for the purpose ofaerial photography. 3.The UAS may not be flown at an indicated airspeed exceeding20 knots. 4. The UA must be operated at an altitude ofno more than 800 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 feetAGL. 5. The UAS must be operated within visual line of sight (VLOS) ofthe 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** airman medical certificate. 6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted.

147. All operations must utilize a safety observer (SO). The SO may be used to satisfY the VLOS requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration ofthe flight. The PIC must ensure that the SO can perform the functions prescribed in the operating documents. 8. The SO must not perform any otherduties beyond assistingthe PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is not permittedto operate the camera orother 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 limitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant ofexemption 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 Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. 

### If the operator determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its grant of exemption. The FAA's UAS Integration Office (AFS-80) may 

### be contacted if questions arise regarding updates or revisions to the operating documents.

10.Priorto each flight the PIC must inspectthe 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 and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must 

### be properly documented in the aircraftrecords.

11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry inthe 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 ofthe operatingdocuments. 13. The operator r,nust follow the UAS manufacturer 's aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements.

1514. The operator must cany out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status ofreplacement/overhaul component parts must 

### be noted in the aircraft records, including total time in service, description ofwork accomplished, and the signature ofthe authorized person returningthe UAS to service. 15. Each UAS operated under this exemption must comply with all manufacturer SafetyBulletins. 16. The authorized person must make an entry in the aircraft record ofthe corrective action taken against discrepancies discoveredbetween inspections. 17. The operator may not permit any PIC to operate unless the PIC meets the operator's qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. 

### § 6l.S l(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**experience~building** flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operatethe UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. 

### § 91.119. 18. UAS operations may not be conducted during night, as defmed 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 ofoperations. Flights under special visual flight rules (SVFR) are not authorized. 19. The UA may not operate within 5 nautical miles ofan 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 upon request. 20. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud orwhen visibility is less than 3 statute miles from the PIC. 21. Ifthe UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in accordance with the operating documents.

16

### 22.ThePIC must abortthe flight in theevent ofunpredictedobstacles oremergencies in accordance with the operating documents. 23. 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 landingpointand land the UA with 25% batterypower remaining. 24. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) priorto conducting any operations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted 

### in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponderrequirements. 25. 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 beas large as practicable. 26. Before conducting operations, the radio frequency spectrum used for operation and control ofthe UA must comply with the Federal Communications Commission (FCC) orotherappropriate government oversight agency requirements. 27. 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 ofthe UAS any time the UAS is operating. These documents must be made available to the Administrator or any law enforcementofficialupon request. 28. The UA must remain clear and yield the right of way to all manned aviation operations and activities atall times. 29. TheUAS may notbe operatedbythe PIC from any moving device or vehicle. 30. 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, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection

. If 

### a situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe UA, flight operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/controller ofsuch vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does notpresentanundue hazard, and;

17c. Operations nearerto the PIC, SO, operatortrainees oressential persons do notpresentanundue hazardtothose persons per §91.119(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 each flight to beconducted. 33. Any incident, accident, or flight operation that transgresses the lateral orvertical boundaries ofthe operational areaasdefmed by the applicable COAmust 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 ontheNTSB Web site:www.ntsb.gov.

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) WouldNotAdversely Affect Safety. Information Exchange Service submits thatthe equivalent level ofsafety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowedto operatethe DJI Phantom 3 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 3 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriatedistancesfrom people, vessels, vehicles and structures. Considering The Information Exchange Service proposed area ofoperations, and the operating limitations set forth-above; the parallel nature of private pilot aeronautical knowledge requirements to those ofcommercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI Phantom 3 UAS, Information Exchange Service submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary 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). Information Exchange Service will not allow any PICto operate the DJI Phantom 3 UAS unless that PIC has demonstrated, by meeting minimum flight-hour requirements orthe DJI Phantom 3 UAS training and currency requirements, thatthe PIC is ableto safelyoperatethe DJI Phantom 3 UAS in a manner consistent with this exemption, including evasive and emergency maneuvers andmaintaining appropriate distances frompeople, vessels, vehicles and structures.

Specifically, the PIC musthave accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours oftotal time as a UAS rotorcraft pilot (with a minimum of5 hours ofthose

18hours as a UAS pilot opemtingthe same make and model ofUAS to be used for opemtions under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding90 days (for currency purposes). As in Exemption Nos. 11062, 

### 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety duringInformation Exchange Services proposed operations. The Administratorhas held thatprior documented flight experience that was obtained in compliance with applicable regulations would
ensure safe opemtions, stating as follows: In Exemption No. 11062, the FAA required that prior to conducting opemtions for the purpose ofmotion picture filming (or similar opemtions), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.5l(b), 25 hours oftotal time as a UAS rotorcmft 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 opemting the same make and model ofUAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours ofmulti-rotortime and the 10 hours may be included in the total 25 hours ofUAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight-hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the petitioner's proposed operations. The FAA also finds that prior documented flight experience that was obtained 

### in compliance with applicable regulations would satisfy this requirement. Tmining, proficiency, and experience-building flights can also be conducted under the gmnt of exemption to accomplish the required flight time. During tmining, proficiency, and experience-building flights the PIC is required to operate the UA with appropriate distances in accordance with 14C.F.R 91.119.

ExemptionNo. 11138 atpage 15. Accordingly, Information Exchange Service will ensure safe operations by not allowing any PIC to operate the DllPhantom 3 UAS unlessthatPIC bas demonstrated, by meeting minimum flighthour and currency requirements, thatthe PIC is able to safely operate the Dil Phantom 3 UAS ina manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distancesfrom people,vessels, vehicles and structures.



### 3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not AdverselyAffect Safety.

19The equivalent level ofsafety established by Section 91.7(a) will be maintained because prior to every flight, Information Exchange Service will ensure that the DJI Phantom 3 

### VAS is in an airworthy condition based upon the 

### VAS's compliance with its operating documents and as stated in the conditions and limitations herein. Additionally, the FAA has previously granted relief from Section 91.7(a) specific to 

### VAS, 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, t 1136, 11138, 11150, 11153,11156,11157,11158,11159,11160, 11161).

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety. The equivalent level of safety established by Section 91.121 will be maintained because the altitude information ofthe DJI Phantom 3 

### VAS will be provided to the PIC via GPS equipment and a radio communications telemetry data link, which downlinks from the 

### VA to the GCS for active monitoring of the flight path and altitude. This altitude information, combined with Information Exchange Service's operation ofthe DJI Phantom 3 

### VAS within visual line ofsight, at or below 500 feet AGL, will ensure a level ofsafety 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 automatically established by the 

### VAS atground level, The FAA has previously granted relief from Section 91.121 specific to 

### VAS, in circumstances similar, in all material respects, to those 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 OfSection 91.1Sl(b) Would Not AdverselyAffect Safety. A grant ofthis exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 91.15l(b) as a result of(1) the technical specifications ofthe DJI Phantom 3 

### VAS; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, Information Exchange Service will ensure that it will safely operate the battery powered DJI Phantom 3 

### VAS during daylight hours in VFR conditions, with enough battery powerto fly for atotal duration of23 minutes. Here, as in ExemptionNo. 11109, thetechnical specifications ofthe Dll Phantom 3 

### VAS; the limitations onthe proposed flight operations; and the location ofthe proposed operations, will
ensure an equivalent level ofsafetyestablished by 14 C.F.R. Section 91.15l(b). Furthermore, safety will be ensured as the DJI Phantom 3 

### VAS provide audible and visual warnings tothe PIC atthe GCS whenthe 

### VAS experiences lowbatteryvoltage, the first warning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery

20

### power. At the critically low battery level, the Dil Phantom 3 UAS will descend and land automatically. Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations ofthe 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, 11042, 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)(l), 91.409(a)(l) & 

### (a)(2), And 91.417(a) & 

### (b) Would Not Adversely AffectSafety. In seeking this exemption, Information Exchange Service submits that the equivalent level of safety with regard to the regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(aXl), 91.409(a)(l) & 

### (a)(2), and 91.417(a) & 

### (b) will be met because Information Exchange Service will use trained technicians to perform maintenance, alterations,
orpreventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., Aerial Operations Manual, Monthly Maintenance Log, and Phantom 3 Instruction Manual). Furthermore, Information Exchange Service will document and maintain all maintenance records for the 

## on Phantom 3 UAS. Since the DJI Phantom 3 UAS will be inspected as prescribed by the operating document Information Exchange Service will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(aXl), and 91.409(a)(2). Likewise, the exemption sought will not adversely affect safety because Information Exchange Service will use trained technicians to perform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed by the operatingdocuments. Furthermore, the exemption sought would maintain an equivalent level ofsafety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance ofthe DJI Phantom 3 UAS will be performed by trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log. Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(l ), 91.409(a)(l) & 

### (a)(2), and 91.417(a) & 

### (b) establish that safety is not adversely affected when the technical characteristics and operating limitations ofthe UAS are considered.

21

### In consideration ofInformation Exchange Service proposed operating limitations, the operating documents, and the technical aspects ofthe DJI Phantom 3 UAS, The AL TEK MEDIA GROUP submits that safety will not be 

### adversely affected by granting exemption from 14 C.F.R Sections 91.405(a), 91.407(a)(l) 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, Il067, I1080, 11109, 11I10, 11112, 11136, 11138, 11150, 11153, 11156, 11I57, 11158, 11I59, Ill60, I1161). 7.TheFAAMayPrescribe Any OtherConditionsFor SafeOperation. In accordance with Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA) and I4 C.F.R § 21. I6 entitled Special Conditions, Information Exchange Service requests that the FAA prescribe special conditions for the intended operation ofthe Dji Phantom 3 UAS, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by I4 C.F.R Part 21, Subpart H, and I4 C.F.R §§ 61.113(a) & 

### (b), 91.7 (a), 91.12I, 91.15l(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & 

### (a)(2), and 91.4I7(a) & 

### (b). Such special conditions will permit safe operation ofthe UAS for the limited 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 ofthe NAS orthe public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification in accordance with any requirements that must be established for the safe operation ofthe UAS in the NAS. Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 2I.16, for operation ofthe Dji Phantom 3 VAS, since the airworthiness regulations of I4 C.F.R Part 2I do not contain adequate or appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 2I.I6, 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 ofa novel or unusual design feature ofthe aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part II ofthis chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level ofsafety equivalenttothat established in the regulations. See I4 C.F.R. §21.16. Therefore, in accordance withFMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for LeadingEdge's intended operation oftheDjl Phantom 3 VAS, which contain such safety standards thatthe Administratorfinds necessaryto establish a level of safety equivalent to that established by I4 C.F.R. Part 2I, Subpart 

### H, and I4 C.F.R Sections



### 22

### 61.113(a) & 

### (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & 

### (a)(2),and 91.417(a) & 

### (b).

• A SummaryThat Can BePublished In 

### The Federal Register, stating: The Rules From Which Information Exchange Service Seeks Exemption:



### Information Exchange Service seeks exemptionfrom the requirements of14 C.F.R Sections 61.113(a)&(b), 91. 7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) 

### & (a)(2), and91.417(a) & 

### (b).
A BriefDescription OfTheNature OfThe Exemption Information Exchange Service Seeks: 

### This exemption will

### permit The ALTEKMEDIA GROUP to commercially operate an Unmanned Aircraft System (UAS) for the purpose ofconducting aerial video and photography overcertainareasof the UnitedStates.

• Any Additional Information, Views, Or Arguments Available To Support TheALTEKMEDIA GROUP'sRequest.

This Petition is made pursuantto the FAA Modernization and Reform Actof 2012 (FMRA) Section 333, which directs the Secretary ofTransportation to determine 

### if certain UAS may operate safely in the NAS. As such, Information Exchange Service request for exemption may be granted pursuant to the authority ofFMRA Section 333 and 14 C.F.R. Part 11, as set forth above. FMRA Section 333 sets forth the requirements for considering whether a UAS wiU create a hazard to users ofthe NAS or the public, or otherwise pose a threat to national security; and further, providesthe authority for such UAS to operate without airworthiness certification. As discussed in detail above, Information Exchange Service will operate the djl Phantom 3 UAS safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose athreat to national security. CQNCLUSION As set forth herein, Information Exchange Service seeks an exemption pursuantto 14 C.F.R. § 11.61 and Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA), which will permit safe operation of the Djl Phantom 3 UAS commercially, without an airworthiness certificate, for the limited purpose ofconducting aerial video and photography over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing The ALTEK MEDIA GROUP to safely, efficiently, and economically operatethe DllPhantom 3 UAS commercially within the NAS.

23--- 

# ------------------------------------------------

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2),and 91.417(a) & (b).

• A Summary That CanBePublished In The Federal Register, stating: The Rules From Which Information Exchange Service Seeks Exemption:



### Information Exchange Service seeks exemptionfrom the requirements of14 C.F.R Sections 61.113(a)&(b), 91. 7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(/), 91.409(a)(l) & (a)(2), and91.417(a) & 

### (b).
A BriefDescription OfTheNature OfThe Exemption Information Exchange Service Seeks: 

### This exemption willpermit The ALTEKMEDIA GROUP to commercially operate an Unmanned Aircraft System (UAS) for the purpose ofconducting aerial video and photographyovercertainareasoft he UnitedStates.

• Any Additional Information, Views, Or Arguments Available To Support TheALTEKMEDIAGROUP'sRequest.

This Petition is made pursuantto the FAAModernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary ofTransportation to determine 

### if certain UAS may operate safely in the NAS. As such, Information Exchange Service request for exemption may be granted pursuant to the authority ofFMRA Section 333 and 14 C.F.R. Part 11, as set forth above. FMRA Section 333 sets forth the requirements for considering whether a UAS wiU create a hazard to users ofthe 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, Information Exchange Service will operate the djl Phantom 3 UAS safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threatto national security. CQNCLUSION As set forth herein, Information Exchange Service seeks an exemption pursuantto 14 C.F.R. 

### § 11.61 and Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA), which will permit safe operation of the Djl Phantom 3 UAS commercially, without an airworthiness certificate, for the limited purpose ofconducting aerial video and photography overcertain areas of the United States. By granting this Petition, the FAA Administrator will 

### be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing Information Exchange Service to safely, efficiently, and economically operate the DllPhantom 3 UAS commerciallywithin the NAS.

23AGL AOI ATC ATO AV CFR COA FAA 

### FAR GCS GPS LOL NAS NOT AM PIC Section 333 

## so SOP UA UAS VFR VLOS VMC VTOL GLOSSARY OF ABDBEVIATIONS Above Ground Level Area ofInterest AirTraffic Control AirTraffic Organization Aerial Vehicle Code ofFederal Regulations Certificate ofAuthorization Federal Aviation Administration Federal Aviation Regulation Ground Control Station Global Positioning System Loss ofLink National Airspace System Notice to Airman PilotIn Command FAAModernization and Reform Act of2012 (FMRA) Safety Observer Standard Operating Procedures Unmanned Aircraft Unmanned Aircraft System Visual Flight Rules Visual Line of Site Visual Meteorological Conditions Vertical Takeoffand Landing



### 24