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

Regulatory Docket No. FAA-2007-0001

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

DR AGO ENTERTAINMENT INC. Federal Employer ID #: 20-2189152

FOR AN EXEMPTION SEEKING RELIEF FROM 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 a) DJI PHANTOM 2 and b) DJI INSPIRE 1 UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA

MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Submitted on August 2 , 2015

DR AGO ENTERTAINMENT INC. Joe Drago , President 630 Oldstone Place SimiValley Ca, 93065 818-419-1940 joe@drago-ent.com2 TABLE OF CONTENTS

Page

GLOSSARY OF ABBREVIATIONS ...............................................................................3

SUMMARY ............................................................................................................ ............4

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

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

BASIS FOR PETITION .....................................................................................................5

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

TH E SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH D RAGO ENTERTAINMENT INC , INC. SEEKS EXEMPTION ....................................................................................... 7
THE EXTENT OF RELIEF D RAGO ENTERTAINMENT INC. SEEKS AND THE REASON DRAGO ENTERTAINMENT INC. SEEKS THE RELIEF........................................................................................................10

THE REASONS WHY GRANTING DR AGO ENTERTAINMENT INC.’S REQUEST W OULD BE IN THE PUBLIC INTEREST ...................................

..... .. .. .. .1 3

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY............................................................................................................ 16

CONCLUSION.................................................................................................................323 GLOSSARY OF ABBREVIATIONS

AGL
AOI
ATC
ATO
AV
CFR
COA
FAA
FAR
GCS
GPS
LOL
NAS
NOTAM
PIC
Section 333
V O
SOP
UA
UAS
VFR
VLOS
VMC
VTOL Above Ground Level

Area of Interest
Air Traffic Control Air Traffic Organization
Aerial Vehicle Code of Federal Regulations
Certificate of Authorization
Federal Aviation Administration Federal Aviation Regulation
Ground Control Station Global Positioning System
Loss of Link National Airspace System
Notice to Airman
Pilot In Command FAA Modernization and Reform Act of 2012 (FMRA)
Visual Observer Standard Operating Procedures
Unmanned Aircraft Unmanned Aircraft System Visual Flight Rules
Visual Line of Site Visual Meteorological Conditions Vertical Takeoff and Landing4 SUMMARY DRAGO ENTERTAINMENT , Inc. seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit DRAGO ENTERTAINMENT, Inc. to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography for real estate photography, wedding videography, special events, film sets and landscape over certain areas of the United S tates.

INTRODUCTION AND INTERESTS OF THE PETITIONER My name is Joseph C. Drago , Owner/President of DRAGO ENTERTAINMENT, Inc. a Federally recognized Incorporation

. It is my mission to provide my clients with expertise and knowledge in all aspects of picture, video & audio production, as well as provide them with advanced technologies & solutions that will increase

effi ciency, productivity and effectiveness. DRAGO ENTERTAINMENT, Inc . also provides clients with the highest quality digital content for use in their commercial, personal, and non-profit multimedia projects. DRAGO ENTERTAINMENT Inc . ha s 8 years of professional experience in photography and videography and has become recognized as an expert in this field. DRAGO ENTERTAINMENT Inc. has 3 years of recreational/hobby experience in all aspects of aerial video and photography. The objective of DRAGO ENTERTAINMENT Inc. aerial video and photography operations is to provide high quality imaging for a variety of commercial, public, and residential uses, specifically targeting:

• Real Estate Videography and Photography • Wedding Videography and Photography • Land survey & appraisals • Equipment Inspections • Roof Inspections
• Construction sites before & after • Precision Agriculture • Creation of commercial messages for Television.

• Search and Rescue Operations • Motion Picture Filming

• Increase public knowledge of UAS and promote safe UAS operations.5 BACKGROUND Unmanned Aircraft Systems: DJI Phantom 2, and DJI Inspire 1 UASs

DRAGO ENTERTAINMENT Inc. seeks an exemption to operate DJI systems for compensation or hire within the NAS. The DJI Phantom 2 and DJI Inspire 1 are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The DJI Phantom has a maximum gross weight of approximately 2 pounds 11 ounces, while having a length of 16 inches width of 16 inches, height of 8 inches, and a maximum speed of approximately 29 knots. The DJI Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum spee d of approximately 42 knots. The DJI Phantom 2 and DJI Inspire 1 UAs are equipped with four main rotors; driven by Lithium Polymer battery powered electric motors.

The DJI Phantom 2 and DJI Inspire 1 UAs that will be operated by DRAGO ENTERTAINMENT Inc. 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 Petitio ner, DRAGO ENTERTAINMENT Inc. , 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, DJI Inspire 1 UASs in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, DRAGO ENTERTAINMENT Inc. operation of DJI Phantom 2 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. Accordingly, DRAGO ENTERTAINMENT Inc. 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. DRAGO ENTERTAINMENT Inc. submits that the requested relief is proper since an equivalent level of safety will be ensured. DRAGO ENTERTAINMENT Inc. will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 and DJI Inspire 1 Instruction Manual). Furthermore, DRAGO ENTERTAINMENT Inc. will document and maintain all maintenance records for the DJI Phantom 2 and DJI Inspire 1 UASs.6 Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command , is requested by DRAGO ENTERTAINMENT Inc. t o the extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an airman medical certificate, and who has demonstrated, by meeting minimum flight- hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 2 and DJI Inspire 1 UASs in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

DRAGO ENTERTAINMENT Inc. seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness , because the DJI Phantom 2 and DJI Inspire 1 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, DRAGO ENTERTAINMENT Inc. submits that they will ensure that the DJI Phantom 2 and DJI Inspire 1 UASs are in an airworthy condition, prior to every flight, by determining that the UASs are in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 and DJI Inspire 1 Instruction Manual), and that the aircraft are in a condition for safe flight.

DRAGO ENTERTAINMENT Inc. also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , as the DJI Phantom 2 Vision+ and DJI Inspire 1 UAs will not have a typical barometric altimeter onboard. However, altitude information of the DJI Phantom 2 and DJI Inspire 1UAs will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with DRAGO ENTERTAINMENT Inc. ’s operation of the DJI Phantom 2 and DJI Inspire 1 UASs within visual line of sight, at or below 4 00 feet AGL, will ensure a level of safety equivalent to Section 91.121. Additionally, DRAGO ENTERTAINMENT Inc. seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. DRAGO ENTERTAINMENT Inc. submits that safety will not be affected by operation of the DJI Phantom 2 and DJI Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration of approximately 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. In accordance with 14 C.F.R. § 11.81, DRAGO ENTERTAINMENT Inc. provides the following information in support of its petition for exemption:

A. Name And Address Of The Petitioner. The name and address of the Petitioner and point of contact is: Joe Drago c/o Drago Entertainment Inc. 630 Oldstone Place Ca, 93065 818-419-1940 joe@drago-ent.com7

B. The Specific Sections Of 14 C.F.R. From Wh ich DRAGO ENTERTAINMENT Inc. Seeks Exemption.

1. DRAGO ENTERTAINMENT Inc. Seeks Exemption From The Requirements Of Section Part 21, Subpart H 14 C.F.R. Part 21, Subpart H, establishes the procedural requirements for the issuance of airworthiness certificates as required by 14 C.F.R. §91.203(a)(1)

2. DRAGO ENTERTAINMENT Inc. Seeks Exemption From The Requirements Of Section 61.113(a) And (b).

Se ction 61.113, entitled Private pilot privileges and limitations: Pilot in command , subsections (a) and (b) prescribe the following, in relevant part: (a) No person who holds a private pilot certificate may act as a pilot in command

(PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PIC of an aircraft. (b) A private pilot may, for compensation or hire, act as PIC of an aircraft in

connection with any business or employment if— (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire.

3. DRAGO ENTERTAINMENT Inc. Seeks Exemption From The Requirements Of Section 91.7(a).
Section 91.7, entitled Civil aircraft airworthiness , subsection (a), states the following: (a) No person may operate a civil aircraft unless it is in an airworthy condition.

4. DRAGO ENTERTAINMENT Inc. Seeks 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 setting 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; or8 (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.

5. DRAGO ENTERTAINMENT Inc. Seeks Exemption From The Requirements Of Section 91.151(b). Section 91.151, entitled Fuel requirements for flight in VFR conditions , subsection (b), states the following: (b) No person may begin a flight in a rotorcraft under VFR conditions 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.

6. DRAGO ENTERTAINMENT Inc. Seeks Exemption From The Requirement Of Section 91.405(a).
Section 91.405, entitled Maintenance required , subsection (a), states the following: Each owner or operator of an aircraft— (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.]

7. DRAGO ENTERTAINMENT Inc. Seeks 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-- (1) It has been approved for return to service by a person authorized under § 43.7 of this chapter[.]

8. DRAGO ENTERTAINMENT Inc. 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 section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had -- (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by § 43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.9 9. DRAGO ENTERTAINMENT Inc. Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b). Section 91.417, entitled Maintenance records , subsections (a) and (b), state the following: (a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preventive maintenance, and alteration and records of the 100-hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (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) of the work performed; and (ii) The date of completion of the work performed; and (iii) The signature, and certificate number of the person approving the aircraft for return to service. (2) Records containing the following information: (i) The total time in service of the airframe, each engine, each propeller, and each rotor. (ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the 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 section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold. (3) A list of 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.10

C. The Extent Of Relief DRAGO ENTERTAINMENT Inc. Seeks And The Reason DRAGO ENTERTAINMENT Inc. Seeks The Relief.

1. DRAGO ENTERTAINMENT Inc. Seeks Exemption From The Requirements Of Section Part 21, Subpart H

Given the size and limited operating area associated with the UAS to be utilized by DRAGO ENTERTAINMENT Inc. , an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§ 44701(f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional rotorcraft operating with an airworthiness certificate without the restrictions and conditions of the proposed UAS operations.

2. Extent Of Relief DRAGO ENTERTAINMENT Inc. Seeks And The Reason DRAGO ENTERTAINMENT Inc. Seeks Relief From Section 61.113(a) And (b).
Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command , is requested to the extent necessary to allow a PIC holding a private pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met certain flight-hour and currency requirements, to conduct the proposed UAS flight operations for compensation or hire. This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire.

As set forth more fully below, DRAGO ENTERTAINMENT Inc. submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the DJI Phantom 2 UAS or DJI Inspire 1 UAS unless that PIC has met certain flighthour and currency requirements, demonstrating that the PIC is able to safely operate either the DJI Phantom 2 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 structures.11

Further, DRAGO ENTERTAINMENT Inc. submits that all flights of the DJI Phantom 2 and DJI Inspire 1 UASs, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to DRAGO ENTERTAINMENT Inc. ' business; and (2) will not carry passengers or property for compensation or hire.

3. Extent Of Relief DRAGO ENTERTAINMENT Inc. Seeks And The Reason DRAGO ENTERTAINMENT Inc. Seeks Relief From Section 91.7(a)

.
Relief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to the extent required to allow DRAGO ENTERTAINMENT Inc. to determine that the DJI Phantom 2 and DJI Inspire 1 U ASs are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., the DRAGO ENTERTAINMENT Inc. Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 and DJI Inspire 1 Instruction Manual).

DRAGO ENTERTAINMENT Inc. seeks the requested relief because the DJI Phantom 2 and DJI Inspire 1 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, DRAGO ENTERTAINMENT Inc. will ensure that the DJI Phantom 2 and DJI Inspire 1 UASs are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 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.

4. Extent Of Relief DRAGO ENTERTAINMENT Inc. Seeks And The Reason DRAGO ENTERTAINMENT Inc. Seeks Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings , may be required to allow flight operations of the DJI Phantom 2 and DJI Inspire 1 UASs, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), DRAGO ENTERTAINMENT Inc. seeks the requested relief because the DJI Phantom 2 and DJI Inspire 1 UA’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight. Considering the l imited altitude of t he propos ed operations, relief f rom 14 CFR 91.121 is sought t o the e xtent ne cessary to comply with the a pplicable c onditions a nd limitations stated below. As more fully set forth herein, an equivalent level of safety will be maintained since the DJI Phantom 2 and DJI Inspire 1 UAs are equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pre ssure s etting will be e stablished prior to each flight, and provides t he P IC with altitude i nformation of t he U A on the h eads-up display of t he G CS.12 5. Extent Of Relief DRAGO ENTERTAINMENT Inc Seeks And The Reason DRAGO ENTERTAINMENT Inc. Seeks R elief From Section 91.151(b ).

Relief f rom S ection 91.151(b) entitle d Fuel r equirements for flight i n VFR conditions, is requested to the extent required to allow flights of the battery powered DJI Phantom 2 and DJI Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. DRAGO ENTERTAINMENT Inc. seeks the requested relief because without
an exemption from Section 91.151(b), the flight time duration of the battery powered DJI Phantom 2 and DJI Inspire 1 UAs will severely constrain the practicality of any aerial video or still photo flight operations that DRAGO ENTERTAINMENT Inc. proposes to conduct pursuant to this Petition. Significantly, as set forth below, the technical specifications of the DJI Phantom 2 and DJI Inspire 1 UASs, the DJI Phantom 2 and DJI Inspire 1 operating documents, and DRAGO ENTERTAINMENT Inc. ’s proposed operating limitations, ensure that DRAGO ENTERTAINMENT Inc. will safely operate the battery powered DJI Phantom 2 and DJI Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

6. Extent Of Relief DRAGO ENTERTAINMENT Inc. Seeks And The Reason DRAGO ENTERTAINMENT Inc. 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, DRAGO ENTERTAINMENT Inc. requests relief from these Sections because the DJI Phantom 2 and DJI Inspire 1 UASs do not require airworthiness certificates. As set forth more fully below, the DJI Phantom 2 and DJI Inspire 1 UASs meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, DRAGO ENTERTAINMENT Inc. will
use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the DRAGO ENTERTAINMENT Inc. Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 and DJI Inspire 1 Instruction Manual). Furthermore, DRAGO ENTERTAINMENT Inc. will document and maintain all maintenance records for the DJI Phantom 2 and DJI Inspire 1 UASs.13

D. The Reasons Why Granting DRAGO ENTERTAINMENT Inc. Request Would Be In The Public Interest; That Is, How It Would Benefit The Public As A Whole. Granting the present Petition will further the public interest by allowing DRAGO ENTERTAINMENT Inc. to safely, efficiently, and economically perform aerial video and photography of, real estate, wedding films, special events, precision agriculture, land survey & appraisal, construction sites, equipment & roof inspections, film sets and landscape over certain areas of the United States. Additionally, use of the DJI Phantom 2 and DJI Inspire 1 UASs will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of DRAGO ENTERTAINMENT Inc. ’s proposed operation of the DJI Phantom 2 and DJI Inspire 1 UASs will be realized without implicating any privacy issues. 1. The Publ ic Will Benefit From Decreased Congestion Of The NAS.

The DJI Phantom 2 and DJI Inspire 1 UAs are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJI Phantom 2 or DJI Inspire 1 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground.

Furthermore, by reducing the num ber of m anned aircraft ope rating in the N AS, congestion around airports caused by arriving and departing aircraft will be reduced. The DJI Phantom 2 and DJI Inspire 1 UAs do not require an airport to takeoff or land.

Likewise, a reduction of manned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handled by air traffic control during the ground, t akeoff, departure, arrival, and landing phases of flight operations.
2. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 2 and DJI Inspire 1 UASs. Conducting aerial acquisitions with the DJI Phantom 2 and DJI Inspire 1 UAS ’s, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, the DJI Phantom 2 and DJI Inspire 1 UASs 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 20-30 gallons per hour of leaded aviation fuel. The DJI Phantom 2 and DJI Inspire 1 UAs, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAs are propelled by battery powered electric motors, rather than an internal combustion engine.14

By using the DJI Phantom 2 and DJI Inspire 1 UAS’s to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI Phantom and DJI Inspire 1 UAs (weighing approximately 2 pounds 11 ounces and 6 pounds 7.5 ounces respectively, at their maximum gross weights with lengths of 16 inches and 17.3 inches respectively, widths of 16 inches and 17.7 inches respectively, and with no fuel on board), has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing 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 Video and Photography Operations With The DJI Phantom 2 and DJI Inspire 1 UASs Will Benefit The Economy. In addition to being safe and efficient, the DJI Phantom 2 and DJI Inspire 1 UASs are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom 2 and DJI Inspire 1 UASs will allow United States based companies, like DRAGO ENTERTAINMENT Inc. , to remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery powered DJI Phantom 2 and DJI Inspire 1 UASs 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 and DJI Inspire 1 UASs, companies such as DRAGO ENTERTAINMENT Inc. , 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 commercial use of the DJI Phantom 2 and DJI Inspire 1 UASs, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the United States and abroad.
4. There Are No Privacy Issues.

Si milar to the manned aerial acquisition flight operations that have been conducted for decades, DRAGO ENTERTAINMENT Inc. ’s proposed operation of the DJI Phantom 2 and DJI Inspire 1 UASs will not implicate any privacy issues. Specifically, the DJI Phantom 2 and DJI Inspire 1 UASs will be operated only in compliance with operating documents (i.e., the DRAGO ENTERTAINMENT Inc. Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 and DJI Inspire 1 Instruction Manual) which requires15 property o wner 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. § 91.119.16

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which DRAGO ENTERTAINMENT Inc. Seeks Exemption. 1. Reasons Why The DJI Phantom 2 and DJI Inspire 1 UAs Meet The Conditions Of The FAA Modernizati on 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 operation, DRAGO ENTERTAINMENT Inc. s operation of the DJI Phantom 2 and DJI Inspire 1 UAS’s meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part: (a) In General.

-- Notwithstanding any other requirement of thi s 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 systems may operate safely in the national airspace system before completion of the plan and rulem aking 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 determination under subsection (a), the Secretary shall determine, at a minimum

-- (1) which types of unmann ed 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 publ ic 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 ide ntified 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

sa

fe operation of such aircraft systems in the national airspace system. In seeking this exemption, DRAGO ENTERTAINMENT Inc. submits that the DJI Phantom 2 and DJI Inspire 1 UASs can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI Phantom 2 and DJI Inspire 1 UASs; (b) the pilot certification requirement; and (c) the specific operating limitations.17 a. The Specifications Of The DJI Phantom 2 and DJI Inspire 1 UASs Demonstrate Its Saf e Characteristics.

The DJI Phantom 2 and DJI Inspire 1 UASs do not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability.

i. Technical Specifications Of The DJI Phantom 2 and DJI Inspire 1 UASs. The technical specifications of the DJI Phantom 2 and DJI Inspire 1 UASs are set forth by the DJI Phantom 2 and DJI Inspire 1 Specifications and Data Sheet, attached hereto
as Exhibit A and B

. ii. The DJI Phantom 2 and DJI Inspire 1 UASs Autonomous Flight And Navigation M odes En able Th e U ASs To Remain W ithin A D efined O perational Area. The DJI Phantom 2 and DJI Inspire 1 UASs may be operated in both manual and fully autonomous flight modes. A complete description of the flight and navigational modes of the DJI Phantom 2 and DJI Inspire 1 UASs are provided at pages 23- 41 of the DJI Phantom 2; and pages 12-18 and 45-52 of the DJI Inspire 1 User Manuals, attached hereto
as Exhibit C and D.

iii. The DJI Phantom 2 and DJI Inspire 1 UASs Are Designed For Automatic R eturn To Home P oint Or H over I n Th e Eve nt Of Loss O f The C ontrol Link Or Navigation. When the Control Link is lost, the DJI Phantom 2 and DJI Inspire 1 UAs will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 2 and DJI Inspire 1 UAs do not reacquire control link data from the GCS, the UAs will assume that the Control Link is lost and the UAs will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown. A complete description of the Failsafe Functions for the DJI Phantom 2 UAS are set forth at pages 32 through 34 of the DJI Phantom 2 User Manual; and for the DJI Inspire 1 at pages 13 through 15 of the DJI Inspire 1 User Manual, attached hereto as Exhibit C and D.

iv. The DJI Phantom 2 and DJI Inspire 1 GCS And Its Operation. A complete description of the operation and specifications of the DJI Phantom 2 and DJI Inspire 1 GCS and flight control software is provided at pages 7 through 17 of the DJI Phantom 2 User Manual; and pages 24 through 34 of the DJI Inspire 1 User Manual. DJI Phantom 2 and DJI Inspire 1 User Manuals are attached hereto a s Exhibits C and D.

b. Flight Operations Of DJI Phantom 2 and DJI Inspire 1 UASs Are Limited To The Li ne O f Sight Of A C ertificated P ilot in C ommand With A S afety Observer. DRAGO ENTERTAINMENT Inc. will only utilize certificated pilots who possess a current and valid18

airman medical certificate to act as a pilot in command (PIC) of the DJI Phantom 2 and DJI Inspire 1 UASs. Additionally, a visual observer will assist all pilots during flight time.

c. Flights Of DJI Phantom 2 and DJI Inspire 1 UASs Will Be Conducted Pursuant To Specific Operating Limitations. In seeking this exemption, DRAGO ENTERTAINMENT Inc. proposes to commercially operate DJI Phantom 2 and DJI Inspire 1 UASs 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 operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: DJI Phantom 2 and DJI Inspire 1 Unmanned Aircraft Systems. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant

. 2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photography. 3. The UAs may not be flown at an indicated airspeed exceeding 20 knots.

4. The UA must be operated at an altitude of no more than 4 00 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved by ATC. All altitudes reported to ATC must be in feet AGL. 5. The UAs must be operated within vi sual 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 airman medical certificate. 6. The use of first person view (F PV) by the PIC or safety observer (SO) is not permitted.

7. All operations must utilize a safety observer ( V O). The V O may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The V O and PIC must be a ble t o communicate ve rbally at a ll t imes. Electronic m essaging or texting is not pe rmitted during flight ope rations. The PIC must be de signated before t he f light a nd cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the V O can perform the functions prescribed in the operating documents.

8. The V O must not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is not permitted to operate th e camera or other instruments. 9. The operating documents and the grant of exemption must be accessible during UAS19 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 of exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its o perating 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 a nd 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. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition f or safe flight. If the inspection reveals a condition that 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 Gr ound 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 maintenance or alterations that affect the UAS operation or flight chara cteristics, 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 di screpancies, 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 aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. 14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component part s must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature of the authorized person returning the UAS to service. 15. Each UASs operated under this exemption must comply with all manufactu rer 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 ce rtificate and at least a cu rrent third

class medical certificate.20 18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates 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. § 61.51(b). Flights for the purposes of training the operator’s PICs are permitted under the terms of the exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and 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 flig ht 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 upon request.
21. The UA may not be operated less than 4 00 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in accordance with the operating documents. 23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents. 24. 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.21

2 5

. Before conducting operations, t he radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.

2 6

. The documents required fewer than 14 C.F.R. 91.9 and 91.20 3 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.

2 7

. The UA must remain clear and yield the rig ht of way to all manned aviation operations and activities at all times.

28

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

29

. Flight operations must be conducted at least 4 00 feet from all nonparticipating persons (persons other than the PIC, VO , operator trainees or essential persons), vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons from the U A a nd/or debris i n the e vent of a n accident. The ope rator must e nsure t hat nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 4 00 feet of the UA, flight operations m ust c ease i mmediately and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does no t present an undue hazard, and;
c. Operations nearer to the PIC, V O, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a).

3 0

. All operations shall be conducted over private or controlled

- access property w ith permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted.

3 1

. Any incident, accident, or flight operation that transgres ses 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.

DRAGO ENTERTAINMENT Inc. 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 and DJI Inspire 1 UASs unless that PIC has demonstrated, by22

meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 2 or DJI Inspire 1 UAS in a manner consistent with the exemption, including evasive a nd emergency maneuvers a nd maintaining appropriate distances f

rom pe ople, vessels, vehicles a nd structures. Considering DRAGO ENTERTAINMENT Inc. ’s proposed area of operations, and the operating limitations set forth-above; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI Phantom 2 or DJI Inspire 1 UAS, DRAGO ENTERTAINMENT Inc. submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for DRAGO ENTERTAINMENT Inc. ’s specific proposed flight operations. The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 110 62, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

DRAGO ENTERTAINMENT Inc. will not allow any PIC to operate the DJI Phantom 2 or DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight-hour requirements or the DJI Phantom 2 or DJI Inspire 1 UAS training and currency requirements, that the PIC is able to safely operate the DJI Phantom 2 or DJI Inspire 1 UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exem ption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes).

As i n 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 during DRAGO ENTERTAINMENT Inc. ’ 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 th at 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, the23 FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours 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 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 satis fy this requirement. Training, proficiency, and experience

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

- building flights the PIC is required to oper ate the UA with appropriate distances in accordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15. Accordingly, DRAGO ENTERTAINMENT Inc. will ensure safe operations by not allowing any PIC to operate the DJI Phantom 2 or DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 2 or DJI Inspire 1 UAS in a
manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.
3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.7(a) will be maintained because prior to every flight, DRAGO ENTERTAINMENT Inc. will ensure that the DJI Phantom 2 or DJI Inspire 1 UAS is in an airworthy condition based upon the UAS’s compliance with its operating documents and as stated in the conditions and limitations herein. Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).
4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained because the altitude information of the DJI Phantom 2 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 DRAGO ENTERTAINMENT Inc. ’ operation of the DJI Phantom 2 and DJI Inspire 1 UAs within visual line of sight, at or below 40 0 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft.24 Prior to each flight, a zero altitude initiation point is automatically established by the UASs at ground level. The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 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 and DJI Inspire 1 UASs; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, DRAGO ENTERTAINMENT Inc. will ensure that it will safely operate the battery powered DJI Phantom 2 and DJI Inspire 1 UAs during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 2 and DJI Inspire 1 UASs; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Phantom 2 and DJI Inspire 1 UASs provide audible and visual warnings to the PIC at the GCS when the UAs experiences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery power. At the critically low battery level, the DJI Phantom Vision+ and DJI Inspire 1 UASs will descend and land automatically. Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has 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)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety. In seeking this exemption, DRAGO ENTERTAINMENT Inc. submits that the equivalent level of safety with regard to the regulatory maintenance and alteration requirements established25

by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because DRAGO ENTERTAINMENT Inc. will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., the DRAGO ENTERTAINMENT Inc. Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 and DJI Inspire 1 Instruction Manual). Furthermore, DRAGO ENTERTAINMENT Inc. will document and maintain all maintenance records for the DJI Phantom 2 and DJI Inspire 1 UASs. Since the DJI Phantom 2and DJI Inspire 1 UASs will be inspected as prescribed by the operating documents, DRAGO ENTERTAINMENT Inc. will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a) (2). A copy of the DJI Phantom 2 and DJI Inspire 1 User Manuals are attached hereto as Exhibit C and D ; a copy of the DJI Phantom 2 and DJI Inspire 1 UA S Maintenance LOG is attached hereto as Exhibit E

. Likewise, the exemption sought will not adversely affect safety because DRAGO ENTERTAINMENT Inc. will use trained technicians to perform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed by the operating documents.
Furthermore, the e xemption sought w ould maintain an equivalent l evel of s afety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI Phantom 2 and DJI Inspire 1 UASs will be performed by trained technicians. Maintenance w ill be doc umented and maintained utilizing the monthly maintenance l og. Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 91 .409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered.
In consideration of DRAGO ENTERTAINMENT Inc. proposed operating limitations, the operating documents, and the technical aspects of the DJI Phantom 2 and DJI Inspire 1 UAS’s, DRAGO ENTERTAINMENT Inc. 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, DRAGO ENTERTAINMENT Inc. requests that the FAA prescribe special conditions for the intended operation of the DJI Phantom 2 and DJI Inspire 1 UASs, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established26 by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAs for the limited purpose of conducting aerial video and 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 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 of the UAS in the NAS.
Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of the DJI Phantom 2 and DJI Inspire 1 UASs, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special Conditions , states the following: If t he F AA f

inds t hat t he a irworthiness re gulations of t his s ubchapter do not contain adequate or appropriate s afety standards f or an aircraft, aircraft e ngine, or propeller because of a nove l or unusual de sign feature of t he a ircraft, aircraft engine or propeller, he pre scribes s pecial c onditions a nd amendments t hereto for the produc t. The s pecial conditions a re i ssued in accordance w ith Part 11 of t his chapter and contain such safety standards f

or the a ircraft, aircraft e ngine or propeller as t he F AA f inds ne cessary to establish a l evel of s afety equivalent t o that e stablished in the re gulations.

See 14 C.F.R. § 21.16. Therefore, in accordance w ith FMRA S ection 333 and 14 C.F.R. § 21.16, the FAA m ay prescribe special conditions for Leading Edge’s intended operation of the DJI Phantom 2 and DJI Inspire 1 UASs, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

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

The Rules From Which DRAGO ENTERTAINMENT Inc. Seeks Exemption:

DRAGO ENTERTAINMENT Inc. seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a) (1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).
A Brief Description Of The Nature Of The Exemption DRAGO ENTERTAINMENT Inc. S eeks:

This exemption will permit DRAGO ENTERTAINMENT Inc. to commercially operate
an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States.27

Any Additional Information, Views, Or Arguments Available To Support DRAGO ENTERTAINMENT Inc.'s Request.

This P etition is m ade purs uant t o the F AA M odernization and Reform A ct of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. As such, DRAGO ENTERTAINMENT Inc. ’s request for exemption may be granted pursuant to the authority of FMRA 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 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, DRAGO ENTERTAINMENT Inc. will operate the DJI Phantom 2 and DJI Inspire 1 UASs safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.28

Conclusion As set forth herein, DRAGO ENTERTAINMENT INC. seeks an exemption pursuant to14 C.F.R. 11.61 and section 333 of the FAA Modernazation and Reform Act of 2012 (FMRA), which will permit the safe operation of the DJI Phantom 2 and the DJI Inspire 1 comercially, without an airwrthiness certificate, for the limited purpose of conducting aerial photography and videography over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA (FRMA) of 2012 while also advancing the interests of the public, by allowing DRAGO ENTERTAINMENT INC. to safely, efficiently and economically operate comercially within the United States NAS. Wherefore, in accordance with the Federal Avaiation Regulations and the FAA Modernization Act of 2012, Section 333, DRAGO ENTERTAINMENT Inc. respectively requests that the Adminsitrator grants 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), 91.417(a)(1) & (2), and 91.417(a) & (b), and permit DRAGO ENTETAINMENT Inc. to operate commercially for the purpose of conducting aerial video and photography over certain areas of the United States.

Dated: August 2, 2015

Respectfully sumitted,

DRAGO ENTERTAINMENT INC.

___________________________

Joseph C. Drago Drago Entertainment Inc. 630 Oldstone Place Simi Valley, CA 93065 818-419-1940

Appendices: A – DJI Phantom 2 Specifications Data Sheet B – DJI Inspire 1 Specifications Sheet C – DJI Phantom 2 Manufacturer’s User Manual D – DJI Inspire 1 Manufacturer’s User Manual E – Monthly Maintenance Log29 APPENDIX

– A

DJI PHANTOM 2 TECHNICAL SPECIFICATIONS

DRAGO ENTERTAINMENT Inc. only utilizes safe and reliable UASs. DJI is an industry leader in small UAS production. DJI UASs are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJI software provides real-t ime altitude and location information to the PIC via the linked monitor (smart phone/tablet devices)

1.1 DJI Phantom 2

1.1.1 Aircraft 1.1.1.1 Supported Battery

– DJI 5200mAH LiPo Battery 1.1.1.2 Weight (Battery & Propel lers 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 0 /s 1.1.1.5 Max Tilt Angel

- 35 0 1.1.1.6 Max Ascent Speed

– 6m/s 1.1.1.7 Max Descent Speed

– 2m/s 1.1.1.8 Max Flight Speed

– 15m/s (NOT RECOMMENDED)

1.1.2 Gimbal 1.1.2.1 Working Current

– Static: 750mA; Dynamic: 900mA 1.1.2.2 Control Accuracy

- ±0.03 0 1. 1.2.3 Controllable Range

– Pitch:

- 90 0

- 0 0 1.1.2.4 Maximum Angular Speed

– Pitch: 90 0 /s

1.1.3 Camera 1.1.3.1 Operating Temperature Range

- 32 0 F

- 104 0 F (0 0 C

- 40 0 C) 1.1.3.2 Sensor Size

– 1/2.3” 1.1.3.3 Effective Pixels

– 14M 1.1.3.4 Resolution

– 4384x32 88 1 .1.3.5 HD Video Recording

– 1080p30 & 720p 1 .1.3.6 Recording Field of View

- 110 0 /85 0

1.1.4 Transmitter 1.1.4.1 Operating Frequency

– 5.728GHz

– 5.85GHz 1.1.4.2 Communication Distance (unobstructed)

– FCC Compliance: 800m 1.1.4.3 Receiver Sensitivity (1%PER)

- - 93dBm 1.1.4.4 Transmitter Power

– FCC Compliance: 100mW 1.1.4.5 Working Voltage

– 120mA@3.7V30 1.1.5 Range Extender 1.1.5.1 Operating Frequency

– 2412

- 2462MHz 1.1.5.2 Communication Distance (unobstructed)

– 500

- 700m 1.1.5.3 Transmitter Power

– 20dBm 1.1.5.4 Power Consumption

– 2W31 APPENDIX

– B

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

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

– 6 lbs 7.5291oz (2935g) 2.2.1.3 Hovering Accuracy (GPS Mode)

– Vertical: 0.5m; Horizontal: 2.5m 2.2.1.4 Max Angular Velocity

– Pitch: 3000/s; Yaw: 1500/s 2.2.1.5 Max Tilt Angle

- 350 2.2.1.6 Max 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: 750mA; I n 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; P an: 1800/s

2.2.3 Camera 2.2.3.1 Name

– X3 2.2.3.2 Model

– FC350 2.2.3.3 Total Pixels

– 12.76M32 2.2.3.4 Effective Pixels

– 12.4M 2.2.3.5 Image Max Size

– 4000x3000 2.2.3.6 ISO 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 Record ing

– UHD(4K):

4096x2160p24/25, 3840x2160p24/25/30; FH D: 1920x1080p24/25/30/48/50/60; HD: 1280x720p24/25/30/48/50/60 2.2.3.10 Operating Temperature Range

- 320F

- 1040F (00C

- 400C)

2.2.4 Transmitter 2.2.4.1 Name

– C1 2.2.4.2 Operating Frequency

– 5.728

- 5.850GHz; 2.400

- 2.483GHz 2.2.4.3 Communicating Distance (unobstructed)

– 2000m 2.2.4.4 Output Power

– 9W 2.2.4.5 Operating Temperature Range

- 140F to 1040F (

- 100C to 400C) 2.2.4.6 Battery

– 600mAh LiPo 2S33 APPENDIX - C


### DJI PHANTOM 2 Manufa cturer’s User Manual

User manual can be found at: http://www.dji.com/product/phantom

- 2

- vision/download

APPENDIX

- D 

### DJI Inspire 1 Manufacturer’s User Manual

User manual can be found at: http://www.dji.com/product/inspire

- 1/download34 APPENDIX

- E

MONTHLY(MAINTENANCE(LOG

month:'__________''year:''_________

UAS(#:(______________ Date'Issue' Discovered Date'Issue' Addressed

Software'Updates

Airframe

Engines

Propellers

Camera'Gimbal

Landing'Gear

Vibration'Dampening

Other: Maintenance'Performed'by:'''''''''''''' Print'&'Sign Issue''Description'&'Maintenance'Conducted