UNITED STATES OF AMERI CA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

WASHI NGTON, DC

Regulatory

Docket No. _______________

**IN THE MATTER OF THE PETITION FOR EXEMPTION OF:** 

**Maverick Drone Systems 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 BLADE 350QX AP AND**  **DJI INSPIRE 1 UNMANNED AIRCRAFT SYSTEMS**  **PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012** 

**(PUBLIC LAW 112 -**  **95)**

Submitted on December 1 , 2015 Maverick Drone S ys tems 12931 Eagle Creek Parkway Savage, MN 55378 Tel: ( 612 ) 554

- 47052 **TABLE OF CONTENTS** Page GLOSSARY OF ABBREVIATIONS...................................................................................3 SUMMARY...................................................................................................................... .....4 IN TRODUCTION AND INTERESTS OF PETITIONER....................................................4 BACKGROUND...................................................................................................................

. 5 BASI S FOR PETITION.........................................................................................................5 NAME AND ADDRESS OF PETITIONER.............................. ...............................8 THE SPECIFI C SECTIONS OF 14 C.F.R. FROM WHI CH MAVERICK DRONE SYSTEMS SEEKS EXEMPTI ON................................................................

........... . 9 THE EXTENT OF RELIEF MAVERICK DRONE SYSTEMS SEEKS AND THE REASON MAVERI CK DRONE SYSTEMS SEEKS THE RELIEF ................12 THE REASONS WHY GRANTING MAVERI CK DRONE SYSTEMS ’S REQUEST WOULD BE IN THE PUBLIC INTEREST ......................................17 THE REASONS WHY GRANTING THE EXEMPTI ON WOULD NOT ADVERSELY AFFECT SAFETY............................................ ..............................20 SUMMARY THAT CAN BE PUBLISHED INTHE FEDERAL REGI STER......35 ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT MAVERI CK DRONE SYSTEMS ’S REQUEST...36 CONCLUSION...................................................................................... ..............................36 APPENDI CES

........................ ................................................................383 **GLOSSARY OF ABBREVIATIONS** AGL Above Ground Level AOI Area of Interest ATC Air Traffic Control ATO Air Traffic Organization AV Aerial Vehicle CFR Code of Federal Regulations COA Certificate of Authorization FAA Federal Aviation Administration FAR Federal Aviation Regulation GCS Ground Control Station GPS Global Positioning Sy stem LOL Loss of Link NAS National Airspace Sy stem NOTAM Notice to Airman PI C Pilot In Command Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333 SO Safety Observer SOP Standard Operating Procedures UA Unmanned Aircraft UAS Unmanned Aircraft Sy stem VFR Visual Flight Rules VLOS Visual L ine of Site VMC Visual Meteorologic al Conditions VTOL Vertical Takeoff and Landing

**SUMMARY**4 MAVERI CK DRONE SYSTEMS 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 o perate an Unmanned Aircraft Sy stem pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit MAVERI CK DRONE SYSTEMS to operate an Unmanned Aircraft Sy stem (UAS) for the commercial purpose of conducting aerial video and photography of construction sites, real estate, special events, and landscape over certain areas of the United States. **INTRODUCTION AND INTERESTS OF THE PETITIONER** MAVERI CK DRONE SYSTEMS provides its clients with expertise and knowledge in advanced technologies and solutions to increase efficiency , productivity and effectiveness. MAVERICK DRONE SYSTEMS also provides its clients with the highest quality digital content for use in their commercial, personal, and non

- profit multimedia projects. MAVERICK DRONE SYSTEMS has over 1 5 years of professional experience in In formation Technology

and is recognized as an expert in netw ork infrastructure, computer sy stems, and multimedia content creation

. The company has over 11 years of RC model aviation including helicopters and fixed wing aircraft in addition to recreational/hobby experience in aerial video and photograph y. The objective of MAVERICK DRONE SYSTEMS ’s aerial video and photograph y operati on s is to provide high quality imaging and editing (under 400 ft) for all purposes of real estate, golf courses, marinas, agriculture, search and rescue applications, mapping and thermal imaging, bridge and highway inspections, construction/engineering projects , and recreational markets in Minnesota and5

the surrounding states as well as special events. They also provide sales, service and training of drone use for customers.
**BACKGROUND** Unmanned Aircraft Sy stems: Phantom 3 Professional, Inspire 1, DJ I s1000, and Actiondrone AD1 MAVERI CK DRONE SYSTEMS seeks an exemption to operate DJ I and Actiondrone sy stems for compensation or hire within the NAS. The Phantom 3 Professional; Inspire 1; DJIs1000; and Actiondrone AD1 are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone sy stems . The Phantom 3 Professional has weighs 35.5 oz, and can travel 16 m/s. The DJ I Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of approximately 42 knots. The DJIS1000 weighs 4.2 kg and is 386 mm in length. The Actiondrone is 4.8 lbs, is 17.13 inches wide, and has a maximum speed of 17.9 mph. The Phantom 3 Professional; Inspire 1; DJIs1000; and Actiondrone AD1 UAs are equipped with four main rotors; driven by L ithium Poly

mer battery

powered electric motors.The Phantom 3 Professional; Inspire 1; DJ I s1000 ; and Actiondrone AD1 UAs that will be operated b y MAVERI CK DRONE SYSTEMS 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

.6 **BASIS FOR PETITION** Petitioner, MAVERI CK DRONE SYSTEMS , 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, Speci al Rules for Certain Unmanned Aircraft Systems , hereb y petitions the Administrator to commercially operate the Phantom 3 Professional; Inspire 1; DJ I s1000; and Actiondrone AD1 UASs in the National Airspace Sy stem (NAS), and for an exemption from the requ irements 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, MAVERI CK DRONE SYSTEMS ’s operation of Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone AD1 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. Accordingl y, MAVERICK DRONE SYSTEMS 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 airworthine ss certificate. MAVERI CK DRONE SYSTEMS submits that the requested relief is proper since an equivalent level of safety will be ensured. MAVERI CK DRONE SYSTEMS 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 all user instruction manuals). Furthermore, MAVERICK DRONE SYSTEMS will document and maintain all7

maintenance re cords for the Phantom 3 Professional; Inspire 1; DJ I s1000; and Actiondrone AD1 UASs. Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested by MAVERICK DRONE SYSTEM S to the extent necessary to allow a Pilot in Command (PI C) holding a private pilot or higher level certificate, as well as an airman medical certificate, and who has demonstrated, b y meeting minimum flight

- hour and currency requirements, that the PI C is able to safel y operate the Phantom 3 Professional; Inspire 1; DJ I s1000; and Actiondrone AD1 UASs in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. MAVERI CK DRONE SYSTEMS seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness , because the Phantom 3 Professional; Inspire 1; DJ I s1000; and Actiondrone AD1 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, MAVERICK DRONE SYSTEMS submits that he will ensure that the Phantom 3 Professional; Inspire 1; DJIs1000; and Actiondrone AD1 UASs are in an airworth y condition, prior to every flight, by determining that the UASs are in compliance with the operating documents (i.e., Monthly Maintenance Log, and Phantom 3 Professional; Inspire 1; DJIs1000; and Actiondrone AD1 Instruction Manual s ), and that the aircraf

t are in a condition for safe flight. MAVERI CK DRONE SYSTEMS also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , as the Phantom 3 Professional; Inspire 1; DJ I s1000; and Actiondrone AD1 UAs will not have a ty pical barometric altimeter onboard.8

However, altitude information of the Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone AD1 UAs will be provided to the PI C via Global Positioning Sy stem (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with MAVERI CK DRONE SYSTEMS ’s operation of the Phantom 3 Professional; Inspire 1; DJIs1000; and Actiondrone AD1 UASs within visual line o f sight, at or below 4 00 feet AGL, will ensure a level of safet y equivalent to Section 91.121. Additionally , MAVERICK DRONE SYSTEMS seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions

. MAVERI CK DRONE SYSTEMS submits that safety will not be affected by

operation of the Phantom 3 Professional; Inspire 1; DJ I s1000; and Actiondrone AD1 UAs during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery

power to fl y for a total duration of approximately 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fl y after that for at least 4.5 minutes. In accordance with 14 C.F.R. § 11.81, MAVERICK DRONE SYS TEMS 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: MAVERI CK DRONE SYSTEMS 12931 Eagle Creek Parkway Savage, MN 5 5 378 Tel: ( 612 ) 554

- 4705 Email: Tom.shaw@maverickdrone.com9

**B. The Spec ific Sections Of 14 C.F.R. From**  **Which MAVERICK DRONE SYSTEMS**  **Seeks Exemption. 1.**  **MAVERICK DRONE SYSTEMS Seeks Exemption From The**  **Requirements Of Section 61.113(a) And (b).**  Section 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 (PI C) of an aircraft that is carrying passengers or propert y for compensation or hire; nor may

that person, for compensation or hire, act as PIC of an aircraft. (b) A privat e pilot may , for compensation or hire, act as PIC of an aircraft in connection with an y business or emplo ym ent if

— (1) The flight is only

incidental to that business or employ ment; and (2) The aircraft does not carry passengers or property

for compensati on or hire.
**2. MAVERICK DRONE SYSTEMS**  **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. **3. MAVERICK DRONE SYSTEMS**  **Seeks Exemption From The Requirements Of Section 91.121.**  Section 91.121, entitled Altimeter settings , subsection (a), states the following, in p art: (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, b y reference to an altimeter that is set, when operating

-- (1) Below 18,000 feet MSL , to
-- (i) The current reported alt imeter setting of a station along the route and within 100 nautical miles of the aircraft;10 (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 st ation; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure. **4. MAVERICK DRONE SYSTEMS**  **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. **5. MAVERICK DRONE SYSTEMS**  **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[.] **6. MAVERICK DRONE SYSTEMS**  **Seeks Exem ption 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 b y a person authorized under § 43.7 of this chapter[.] **7. MAVERICK DRONE SYST**  **EMS Seeks Exemption From The**  **Requirements Of Sections 91.409(a)(1) And 91.409(a)(2).**11 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 un less, 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 b y a person authorized by § 43.7 of this chapter; or (2) An inspection for the is suance of an airworthiness certificate in accordance with part 21 of this chapter. **8. MAVERICK DRONE SYSTEMS**  **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) Reco rds 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 a ppliance 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.12 (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 safet y directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms pre scribed b y § 43.9(d) of this chapter for each major alteration to the airframe and currentl y installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed: (1) The records s pecified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded b y other work or for 1 ye ar after the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retained and transferre d 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. **C. The Extent Of Relief MAVERICK DRONE SYSTEMS**  **Seeks And The Reason MAVERICK DRONE SYSTEMS**  **Seeks The Relief. 1. Extent Of Relief**  **MAVERICK DRONE SYSTEMS Seeks And The Reason**  **MAVERICK DRONE SYSTEMS Seeks Relief From Section 61.113(a) And**  **(b).** Relief from S ection 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command, is requested to the extent necessary to allow a PI C holding a private pilot or higher level certificate, as well as a current and valid airman medical13

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 PI C of an aircraft in connection with an y business or emplo ym ent if: (1) The flight is only incidental to that business or employ

ment; and (2) The aircraft does not carry passengers or propert y for compensation or hire. As set forth more full y below, MAVERICK DRONE SYSTEMS submits that an equivalent level of safety will be maintained because no PI C will be allowed to operate the Phantom 3 Professional, Inspire 1, DJ I s1000, and Actiondrone AD1 UAS unless that PI C has met ce rtain flight

- hour and currency requirements, demonstrating that the PI C is able to safel y operate the Phantom 3 Professional, Inspire 1, DJ I s1000, and Actiondrone AD1 UAS in a manner consistent with the operations specifications as described in this exemp tion, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures. Further, MAVERICK DRONE SYSTEMS submits that all flights of the Phantom 3 Professional; Inspire 1; DJIs1000; and A ctiondrone AD1 UASs, conducted by the PI C pursuant to the grant of this Petition: (1) will be incidental to MAVERI CK DRONE SYSTEMS ’s business; and (2) will not carry passengers or propert y for compensation or hire. **2. Extent Of Relief MAVERICK DRONE**  **SYSTEMS Seeks And The Reason** 

**MAVERICK DRONE SYSTEMS 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 MAVERI CK DRONE SYSTEMS to determine that the Phantom14

3 Professional; Inspire 1; DJIs1000; and Actiondrone AD1 UASs are in airworthy condition prior to every

flight by ensuring that the UAS is in compliance with the operating documents (i.e., the MAVERI CK DRONE SYSTEMS Aerial Operations Manual, Monthly

Mainten ance Log, and Phantom 3 Professional; Inspire 1; DJIs1000; and Actiondrone AD1 In struction Manual s ). MAVERI CK DRONE SYSTEMS seeks the requested relief because the Phantom 3 Professional; Inspire 1; DJIs1000; and Actiondrone AD1 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, MAVERI CK DRONE SYSTEMS will ensure that the Phantom 3 Professional; Inspire 1; DJIs1000; and Actiondrone AD1 UASs are in airworthy condition base d upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and Phantom 3 Professional; Inspire 1; DJIs1000; and Actiondrone AD1 Instruction Manual) prior to every flight, and further, determine that the aircraft are in condition fo r safe flight, as stated in the conditions and limitations below. **3. Extent Of Relief MAVERICK DRONE SYSTEMS**  **Seeks And The Reason MAVERICK DRONE SYSTEMS**  **Seeks Relief From Section 91.121.** Relief from Section 91.121, entitled Altimeter settings , may be required to allow flight operations of the Phantom 3 Professional; Inspire 1; DJ I s1000; and Actiondrone AD1 UASs, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude infor mation from the UA to the PI C 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), MAVERICK DRONE SYSTEMS seeks the re quested relief because the Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone AD1 UA’s15

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 limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply

with the applicable conditions and limitations stated below. As more full y set forth herein, an equivalent level of safety will be maintained since the Phantom 3 Professional; Inspire 1; DJ I s1000; and Actiondrone AD1 UAs are equip ped with a barometric pressure sensor and GPS equipment, which automatically

ensures that a ground level pressure setting will be established prior to each flight, and provi des the PIC with altitude information of the UA on the heads

- up display of the GCS. **4. Extent Of Relief MAVERICK DRONE SYSTEMS**  **Seeks And The Reason MAVERICK DRONE SYSTEMS**  **Seeks Relief From Section 91.151(b).** Relief from Section 91.151(b) entitled Fuel r equirements for flight in VFR conditions , is requested to the extent required to allow flights of the battery powered Phantom 3 Professional; Inspire 1; DJ I s1000; and Actiondrone AD1 UAs during daylight hours i n visual meteorological conditions (VMC), und er 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 fl y after that for at least 4.5 minutes. MAVERI CK DRONE SYSTEMS seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered Phantom 3 Professional; Inspire 1; DJ I s1000; and Actiondrone AD1 UAs will severel y constrain the practicality of any aerial vi deo or still photo flight operations that MAVERI CK DRONE SYSTEMS proposes to conduct pursuant to this Petition.16 Significantl y, as set forth below, the technical specifications and operating documents of the Phantom 3 Professional; Inspire 1; DJIs1000; an d Actiondrone AD1 UASs, and MAVERICK DRONE SYSTEMS ’s proposed operating limitations , ensure that MAVERI CK DRONE SYSTEMS will safely operate the battery

powered Phantom 3 Professional; Inspire 1; DJIs1000; and Actiondrone AD1 UAs during daylight h ours in

v isual 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
. **5. Extent Of Relief MAVERICK DRONE SYSTEMS**  **Seeks And The Reason MAVERICK DRONE SYSTEMS**  **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), an d 91.417(a) & (b) only appl y to aircraft with an airworthiness certificate, MAVERICK DRONE SYSTEMS requests relief from these Sections because the Phantom 3 Professional; Inspire 1; DJ I s1000; and Actiondrone AD1 UASs do not require airworthiness certificates. As set forth more fully

below, the Phantom 3 Professional; Inspire 1; DJ I s1000; and Actiondrone AD1 UASs meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. According ly , MAVERI CK DRONE SYSTEMS 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 MAVERI CK DRONE SYSTEMS Aeri al Operations Manual, Monthly Maintenance Log, and Phantom 3 Professional; Inspire 1; DJ I s1000; and Actiondrone AD1 In struction Manual s ). Furthermore, MAVERI CK DRONE SYSTEMS will document and maintain all maintenance records for the Phantom 3 Professional ; Inspire 1; DJ I s1000; and Actiondrone AD1 UASs.17

**D. The Reasons Why Granting MAVERICK DRONE SYSTEMS**  **’s 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 b y allowing MAVERI CK DRONE SYSTEMS to safely , efficiently , and economically perform aerial video and photograph y of construction sites, real estate, special events, film sets, and landscape over certain areas of the United States. Additionally , use of the Phantom 3 Professional; Inspire 1; DJ I s1000; and Actiondrone AD1 UASs will de crease congestion of the NAS, reduce pollution, and provide significant benefits to the economy . Notably , the benefits of MAVERI CK DRONE SYSTEMS ’s proposed operation of th e Phantom 3 Professional; Inspire 1; DJIs1000; and Actiondrone AD1 UASs will be realized without implicating an y privacy issues. **1. The Public Will Benefit From Decreased Congestion Of The NAS.** The Phantom 3 Professional; Inspire 1; DJ I s1000; and Actiondrone AD1 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 e xemption allowing the use of a Phantom 3 Professional, Inspire 1, DJIs1000, and Actiondrone AD1 UAS wo uld reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and propert y in the air and o n the ground. Furthermore, b y reducing the number of manned aircraft operating in the NAS, congestion around airports caused b y arriving and departing aircraft will be reduced. The Phantom 3 Professional; Inspire 1; DJ I s1000; and Actiondrone AD1 UAs do not requi re an airport to takeoff or land. L ikewise, a reduction of manned aircraft conducting aerial video and photograph y missions would result in fewer aircraft that must be handled b y air18

traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations. **2. The Public Will Benefit From The Safety And Efficiency Of The Phantom 3**  **Professional; Inspire 1; DJI s1000; and Actiondrone AD1 UASs.**  Conducting aerial acquisitions with the Phantom 3 Professional; Insp ire 1; DJI s1000; and Actiondrone AD1 UASs, i nstead of manned aircraft, will greatly benefit the public by drasticall y reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By

usin g battery

power and electric motors , the Phantom 3 Professional; Inspire 1; DJ I s1000; and Actiondrone AD1 UASs produce no air pollution, and is the most viable environmentall y conscious alternative to the cabin class, six cylinder internal combustion engi ne aircraft that are ty picall y utilized for aerial video and photograph y, while burning approximately 20

- 30 gallons per hour of leaded aviation fuel . The Phantom 3 Professional; Inspire 1; DJ I s1000; and Actiondrone AD1 UAs, while reducing the carbon footp rint of aerial acquisitions, also eliminates noise pollution, as the UAs are propelled by battery powered electric motors, rather than an internal combustion engine. By using the Phantom 3 Professional; Inspire 1; DJIs1000; and Actiondrone AD1 UASs to pe rform 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 compl etely

eliminated. Aside from the lack o f flight crew members located onboard the aircraft , the Phantom 3 Professional; Inspire 1; DJIs1000; and Actiondrone AD1 UAs have less phy sical potential for collateral damage to life and property

on the ground, and in the air, compared to the manned aircraft that19

ty picall y conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 fee t, and a fuel capacity of 180 gallons). **3. Performing Aerial Video and Photography Operations With The Phantom 3**  **Professional; Inspire 1; DJI s1000; and Actiondrone AD1 UASs Will Benefit**  **The Economy.** In addition to being safe and efficient , the Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone AD1 UASs are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the Phantom 3 Professional; Inspire 1; DJIs1000; and Actiondrone AD1 UAS s will allow United States based companies, like MAVERI CK DRONE SYSTEMS , to remain competitive and contribute to growth of the U.S. econom y. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory

acti ons 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 Phantom 3 Professional; Inspire 1; DJIs1000; and Actiondrone AD1 UASs is one s u ch 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 Phantom 3 Professional; Inspire 1 ; DJIs1000; and Actiondrone AD1 UASs, companies such as MAVERICK DRONE SYSTEMS , 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 Phantom 3 Professional; Inspire 1; DJ I s1000; and Actiondrone AD1 UASs, provide s a stable workforce that20

increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order t o remain competitive both in the United States and abroad. **4. There Are No Privacy Issues.** Similar to the manned aerial acquisition flight operations that have been conducted for decades, MAVERICK DRONE SYSTEMS ’s proposed operation of the Phantom 3 Profe ssional; Inspire 1; DJIs1000; and Actiondrone AD1 UASs will not implicate any privacy issues. Specifically , the Phantom 3 Professional; Inspire 1; DJ I s1000; and Actiondrone AD1 UASs will be operated onl y in compliance with operating documents , the MAVERI CK DRONE SYSTEMS Aerial Operations Manual, Monthly Maintenance Lo g , and Phantom 3 Professional; Inspire 1; DJ I s1000; and Actiondrone AD1 Instruction Manual s ) which requires property owner involvement as well as local law enforcement notification, and in a ccordance 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 By The Rule From Which**  **MAVERICK DRONE SYSTEMS Seeks**  **Exemption. 1. Reasons Why The**  **Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone AD1**  **UAs Meet The Conditions Of The FAA Modernization**  **and Reform Act of 2012 (FMRA) Section 333.** In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, MAVERI CK DRONE SYSTEMS ’s operation o f the Phantom 3 Professional; Inspire 1; DJIs1000; and Actiondrone AD1 UASs 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.21 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. Specificall y, FMRA Section 333 states the f ollowing, in part: (a ) In General.

--Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act. (b ) Assessment of Unmanned Aircraft Systems.

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

-- (1 ) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security; and (2 ) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1). (c) Requirements for Safe Operation.

--If the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the na tional airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system. In seeking this exemption, MAVERI CK DRONE SYSTEMS submits that the Phantom 3 Professional; Inspire 1; DJ I s1000; and Actiondrone AD1 UASs can operate safel y in the NAS pursuant to FMRA Section 333, as demonstrated b y: (a) the characteristics of the Phantom 3 Professional; Inspire 1; DJ I s1000; and Actiondrone AD1 UASs; (b ) the pilot certification requirement; and (c) the specific operating limitations.

**a. The Specifications Of The**  **Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone AD1**  **UASs Demonstrate Its Safe Characteristics.**22 The Phantom 3 Professional; Inspi re 1; DJ I s1000; and Actiondrone AD1 UASs do not create a hazard to users of the NAS or the public, or otherwise pose a threat to national securit y considering its size, weight, speed, and operational capability.

**i. Technical Specifications Of The**  **Phantom 3 Professional; Inspire 1;**  **DJI s1000; and Actiondrone AD1 UASs.**  The technical specifications of the Phantom 3 Professional; Inspire 1; DJ I s1000; and Actiondrone AD1 UASs are attache d hereto as Exhibit s A , B, C and D.
.

**ii. The Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone**  **AD1 UASs Autonomous Flight And Navigation Modes Enable The**  **UASs To Remain Within A Defined Operational Area.**  The Phantom 3 Professional; Inspire 1; DJ I s1000; and Actiondrone AD1 UASs may be operated in both manual and full y autonomous flight modes . A complete description of the flight and navigational modes of the Phantom 3 Professional; Inspire 1; DJIs1000; and Actiondrone AD1 UASs is provid ed in the user manuals.

**iii. The**  **Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone**  **AD1 UASs Are Designed For Automatic**  **Return To Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation.**  When the Control Li nk is lost, the Phantom 3 Professional; Inspire 1; DJ I s1000; and Actiondrone AD1 UAs will remain stationary , in flight, for 3 seconds or more. If, after 3 seconds , the Phantom 3 Professional; Inspire 1; DJIs1000; and Actiondrone AD1 UAs do not reacquire control link dat a 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.

**iv. The**  **Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone**  **AD1 GCS And Its Operation.** 23 A complete description of the operation and specifications of the Phantom 3 Professional; Inspire 1; DJIs1000; and Actiondrone AD1 GCS and flight control software is provided in each individual user manuals.

**b . Flight Operations Of**  **Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone AD1**  **UASs Are Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer.**  MAVERI CK DRONE SYSTEMS will only utilize certificated pilots who pos sess a current and valid airman medical certificate to act as a pilot in command (PIC) of the Phantom 3 Professional; Inspire 1; DJ I s1000; and Actiondrone AD1 UASs. Additionally , a safet y observer will assist all pilots during flight time.

**c. Flights Of**  **Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone AD1**  **UASs Will Be Conducted Pursuant To Specific Operating Limitations.**  In seeking this exemption, MAVERI CK DRONE SYSTEMS proposes to commerciall y operate Phantom 3 Professional; Inspire 1; DJ I s1000; and Actiondrone AD1 UASs for the special purpose of conducting aerial video and photograph y over certain areas of United States, pursuant to the following specific operating limitations: 1. Operations authorize d 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: Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone AD1 Unmanned Aircr aft Sy stems. Proposed operations of an y 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 photograph y. 3. The UAs may

not be flown at an indicated airspeed exceeding 20 knots. 4. The UA must be operated at an altitude of no more than 500 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special reques t is made and approved by ATC. All altitudes reported to ATC must be in feet AGL.24 5. The UAs must be operated within visual line of sight (VLOS) of the PI C at all times. This requires the PIC to be able to use human vision unaided by an y device other than corrective lenses, as specified on the PI C’s FAA

- issued airman medical certificate. 6. The use of first person view (FPV) b y the PI C or safet y observer (SO) is not permitted. 7. All operations must utilize a safety observer (SO). The SO may be used t o satisfy the VLOS requirement as long as the PIC alway s maintains VL OS capability

. The SO and PI C must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated befo re the flight and cannot transfer his or her designation for the duration of the flight. The PI C must ensure that the SO can perform the functions prescribed in the operating documents. 8. The SO must not perform any other duties beyond assisting the PI C with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is not permitted to operate the camera or other instruments. 9. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a 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 operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such re visions 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 revi sions to the operating documents. 10. Prior to each flight the PI C must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed 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 properl y documented in the aircraft records. 11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical25 component, must undergo a functional test flight. The PI C who conducts the fun ctional test flight must make an entry in the aircraft records. 12. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections of the operating doc uments. 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 parts must be noted in the aircraf t 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 manufacturer Safety Bulletins. 16. T he authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections. 17. The PI C must possess at least a private pilot certificate and at least a current third

- class medical certificate. 18. The operator may

not permit any

PIC to operate unless the PI C meets the operator’s qualification criteria and demonstrates the ability to safel y operate the UAS in a manner consistent with how the 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 tr aining 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 f light operations are considered nonparticipants, and the PI C 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. Al l operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not a

uthorized. 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 of26 agreement with that airport’s management is obtained, and the operation is conducted i n 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 500 feet below or less than 2,000 feet horizontally

from a cloud or when visibility is less than 3 statute miles from the PI C. 22. If the UA loses communications or loses its GPS signal, it must return to a pre

d etermined location within the planned operating area and land or be recovered in accordance with the operating documents. 23. The PI C must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents. 24. The PI C is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 25% battery power remaining. 25. The ope rator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting an y 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 transponder requirements

. 26. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (N

- Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable. 27. Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS an y time the UAS is operating. These documents must be made available to the Administrator or an y law enforcement official upon request. 29. The UA must rem ain clear and yield the right of way to all manned aviation operations and activities at all times. 30. The UAS may

not be operated b y the PIC from any moving device or vehicle.27 31. Flight operations must be conducted at least 500 feet from all nonparti cipating persons (persons other than the PI C, 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 of the UA, flight operations must cease immediate ly

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 PI C has made a safet y assessment of the risk of operating closer to those object s and determined that it does not present an undue hazard, and; c. Operations nearer to the PI C, SO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a). 32. All operations shall be conducted over priv ate 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 be conducted. 33. Any incident, accident , or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents must be reported to the National Tr ansportation Safet y 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.**  MAVERI CK DRONE SYSTEMS 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 Phantom 3 Professional; Inspire 1; DJ I s1000; and Actiondrone AD1 UASs unless that PIC has demonstrated, b y meeting minimum flight

- hour and currency requirements, that the PI C is able to safely operate the Phantom 3 Professional, Inspire 1, DJ I s1000, and Actiondrone AD1 UAS in a manner consistent with the28

exemption, inc luding evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering MAVERICK DRONE SYSTEMS ’s proposed area of operations, and the operating limitations set forth

- above; the parallel natur e 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 Phantom 3 Professional, Inspire 1, DJ I s1000, and the Actiondrone AD1 UAS, MAVERI CK DRONE SYSTEMS submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for MAVERI CK DRONE SYSTEMS ’s specific proposed flight operations. The FAA has prev iously

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, 111 50, 11153, 11156, 11158, 11159, 11160, 11161). MAVERI CK DRONE SYSTEMS will not allow any PIC to operate the Phantom 3 Professional, Inspire 1, DJIs1000, or the Actiondrone AD1 UAS unless that PI C has demonstrated, b y meeting m inimum flight

- hour requireme nts, that the PIC is able to safel y operate the Phantom 3 Professional, Inspire 1, DJ I s1000, or the Actiondrone AD1 UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people , vessels, vehicles and structures. Specificall y, the PI C 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 operati ng the same make and model of29

UAS to be used for operations under the exemption). In addition to the hour requirements, the PI C must accomplish 3 takeoffs and landings in the preceding 90 day s (for currency purposes). As in Exemption Nos. 11062, 11138, an d 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during MAVERI CK DRONE SYSTEMS ’s proposed operations. The Administrator has held that prior documented flight e xperience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows: In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi

- rotor UAS. Prior to operations under Exemption N o. 11062, the PI C must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be i nclusive 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 PI C must accomplish 3 takeoffs and landings in the preceding 90 day s (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. Training, proficiency , and experience

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

- building flights the PI C is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119. Exemption No. 11 138 at page 15. Accordingl y, MAVERICK DRONE SYSTEMS will ensure safe operations by not allowing an y P IC to operate the Phantom 3 Professional, Inspire 1, DJ I s1000, or the Actiondrone AD1 UAS unless that PI C has demonstrated, by meeting minimum flight

hour and currency

requirements, that the PI C is able to safel y operate the Phantom 330

Professional, Inspire 1, DJIs1000, or the Actiondrone AD1 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 sa fet y established b y Section 91.7(a) will be maintained because prior to every

flight, MAVERICK DRONE SYSTEMS will ensure that the Phantom 3 Professional, Inspire 1, DJ I s1000, or the Actiondrone AD1 UAS i s in an airworth y 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 h erein (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 b y Section 91.121 will be maintained because the altitude information of the Phantom 3 Professional; Inspire 1; DJIs1000; and Actiondrone AD1 UAs will be provided to the PI C via GPS equipment an d 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 MAVERI CK DRONE SYSTEMS ’s operation of the Phantom 3 Professional; Inspire 1 ; DJIs1000; and Actiondrone AD1 UAs within visual line of sight, at or below 500 feet AGL, will ensure a level of safet y equivalent to Section 91.121. The altitude information31

will be generated b y GPS equipment installed onboard the aircraft. Prior to eac h 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 Phantom 3 Professional; Inspire 1; DJIs1000; and Actiondrone AD1 UASs; (2) the limitatio ns on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingl y, MAVERICK DRONE SYSTEMS will ensure that it will safely operate the battery powered Phantom 3 Professional; Inspire 1; DJIs1000; and Actiondrone AD1 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 fl y after that for at least 4.5 minutes. Here, as in Exemptio n No. 11109, the technical specifications of the Phantom 3 Professional; Inspire 1; DJIs1000; and Actiondrone AD1 UASs; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safe ty established by

14 C.F.R. Section 91.151(b). Furthermore, safet y will be ensured as the Phantom 3 Professional; Inspire 1; DJ I s1000; and Actiondrone AD1 UASs provide audible and visual warnings to the PI C at the GCS when the UAs experiences low battery voltage, the first warning occurring at approximately 33%32

remaining battery

power, and again at approximately 10% remaining battery

power. At the critically low battery

level, the DJ I Phantom Vision+ and DJ I Inspire 1 UASs will descend and land automatical ly

. Significantl y, previous exemptions granted b y the FAA concerning Section 91.151 establish that safety is not adversel y 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 respe cts, 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 Requi rements 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, MAVERI CK DRONE SYSTEMS submits that the equivalent level of safety with regard to the regulatory mainten ance and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because MAVERICK DRONE SYSTEMS will use trained technicians to perform maintenance, alterations, or preventive maintena nce on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., the MAVERI CK DRONE SYSTEMS Aerial Operations Manual, Monthly Maintenance Lo g, and Phantom 3 Professional; Inspire 1; DJ I s1000; and Actiondrone AD1 In struction Manual s ). Furthermore, MAVERI CK DRONE SYSTEMS will document and maintain all33

maintenance records for the Phantom 3 Professional; Inspire 1; DJ I s1000; and Actiondrone AD1 UASs. Since the Phantom 3 Professional; Inspire 1; DJ I s1000; and Actiondr one AD1 UASs will be inspected as prescribed b y the operating documents, MAVERI CK DRONE SYSTEMS will maintain the equivalent level of safety established b y Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A cop y of the Phantom 3 Professional; Inspire 1; DJ I s1000; and Actiondrone AD1 User Manuals are attached hereto as Exhibit C and D; a copy of the Phantom 3 Professional; Inspire 1; DJ I s1000; and Actiondrone AD1 UAS Maintenance LOG is attached hereto as Exhibit C

. Lik ewise, the exemption sought will not adversel y affect safety because MAVERI CK DRONE SYSTEMS will use trained technicians to perform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed b y the operating documents. Furthermore, the exemption sought would maintain an equivalent level of safety established by

Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the Phantom 3 Professional; Inspire 1; DJ I s1000; and Actiondrone AD1 UASs will be performed b y trained technicians. Maintenance will be documented and maintained utilizing the monthly

maintenance log. Significantl y, previous exemptions granted b y 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 adversel y affected when the technical characteristics and operating limitations of the UAS are considered.34 In consideration of MAVERI CK DRONE SYSTEMS ’s proposed operating limitations, the operating documents , and the technical aspects of the Phantom 3 Professional; Inspire 1; DJIs1000; and Actiondrone AD1 UASs, MAVERI CK DRONE SYSTEMS submits that safet y 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, 111 10, 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. § 21.1 6 entitled Special Conditions , MAVERI CK DRONE SYSTEMS requests that the FAA prescribe special conditions for the intended operation of the Phantom 3 Professional; Inspire 1; DJ I s1000; and Actiondrone AD1 UASs, which contain such safety

standards that the Administrator finds necessary to establish a level of safet y equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAs for the 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 such35

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 Phantom 3 Professional; Inspire 1; DJ I s1000; and Actiondrone AD1 UASs, sinc e 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 the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safet y standards for an aircraft, aircraft engine, or propeller because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he presc ribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety

standards for the aircraft, aircraft engine or propeller as the FAA finds necessary

to est ablish a level of safety equivalent to that established in the regulations. See 14 C.F.R. § 21.16. Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for L eading Edge’s intended operation of the Phantom 3 Professional; Inspire 1; DJIs1000; and Actiondrone AD1 UASs, which contain such safet y 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 MAVERICK DRONE SYSTEMS**  **Seeks Exemption:** MAVERICK DRONE SYSTEMS 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).36 **A Brief Description Of The Nature Of The Exemption MAVERICK**  **DRONE SYSTEMS**  **Seeks:** This exemption will permit MAVERICK DRONE SYSTEMS to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States. **G. Any Additional Informat**  **ion, Views, Or Arguments Available To Support MAVERICK DRONE SYSTEMS**  **’s Request.**  This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely

in the NAS. As such, MAVERI CK DRONE SYSTEMS ’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 securit y; and further, provides the authority for such UAS to operate without airworth iness certification. As discussed in detail above, MAVERICK DRONE SYSTEMS will operate the Phantom 3 Professional; Inspire 1; DJ I s1000; and Actiondrone AD1 UASs safel y in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security. **CONCLUSION** As set forth herein, MAVERI CK DRONE SYSTEMS seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the Phantom 3 Professional; Inspire 1; DJ I s1000; and Actiondrone AD1 UASs commercially , without an airworthiness certificate, for37

the limited purpose of conducting 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 MAVERI CK DRONE SYSTEMS to safel y, efficientl y, and economically operate the Phantom 3 Professional; Inspire 1; DJ I s1000; and Actiondrone AD1 UASs commercially within the NAS. **WHEREFORE** , in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, MAVERI CK DRONE SYSTEMS respec tfull y requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Leading Edge to operate the Phantom 3 Professional; Inspire 1; DJ I s1000; and Actiondrone AD1 UASs commerciall y for the purpose of conducting aerial video and photograph y over certain areas of the United States. Date d: December 1, 2015

Respectfully submitte d, MAVERI CK DRONE SYSTEMS

_________________________ MAVERI CK DRONE SYSTEMS 12931 Eagle Creek Parkway Savage, MN 55378 Tel: ( 612 ) 554

- 470538

Appendic es : A

– Phantom 3 Professional Specifications Data Sheet B

– DJ I Inspire 1 Specifications Data Sheet C

– DJIs1000 Specifications Data Sheet D
- Actiondrone AD1 Specifications Data Sheet E
- Monthly

Maintenance L og39 **APPENDIX A DJI PHANTOM 3 PROFESSIONAL**  **SPECIFICATIONS Maverick Drone Systems**  onl y utilizes safe and reliable UASs. DJ I Phantom 3 Pro is an industry leader in small UAS production. DJ I Phantom 3 Pro 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, DJIsoftware provides real

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

. Aircraft Supported Battery

– 3000mAh 3S 11.1V 20C Li
- Po Battery Weight (Battery

& Propellers Included)

– 35.5 oz (1280 g) Hover Accuracy

(Ready to Fly)

– Vertical: .5m; Horizontal: 1.5m Max Yaw Angular Velocity

- 200 0 /s Max Tilt Angel

- 35 0 Max Ascent Speed

– 5m/s Max Descent Speed

– 3m/s Max Flight Speed

– 16m/s (NOT RECOMMENDED), no wind Camera Video Resolution: Up to 4K @ 30 fps Photo Resolution: 12 Megapixal Video Format: MP4 or MOV Photo Format: Adobe DNG RAW and JPEG Features: Adjustable White Balance, ISO, Exposure, Shutter Speed and color filters Gimbal Controllable range: Pitch

- 90 to +30 degrees40 

### APPENDIX

**– B**  **DJI INSPIRE 1/ DJI Inspire 1 Pro** Maverick Drone S ys tems o nly utilizes safe and reliable UASs. DJ I is an industry leader in small UAS production. DJIUASs 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 f l ight to a predetermined and set distance. In addition, DJIsoftware provides real

- time altitude and location information to the PI C via the linked monitor (smart phone/tablet devices) DJI Inspire 1/Inspire 1 Pro **AIRCRAFT** Model
– T600 Weight (Battery Included)
– 6lbs 7.5291oz (2935g) Hovering Accuracy (GPS Mode)
– Vertical: 0.5m; Horizontal: 2.5m Max Angular Velocity
– Pitch: 300 0/s; Yaw: 1500/s Max Tilt Angle

- 35 0 Max Ascent Speed
– 5m/s Max Descent Speed
– 4m/s Max Speed
– 22m/s (ATTI mode, no wind

– NOT RECOMMENDED) Max Flight Altitude
– 4500m Max Wind Resistance
– 10m/s Max Flight Time
– Approximately 18 minutes Motor Model
– DJI 3510 Propeller Model
– DJI 1345 Operating Temperature Range
– 14 0F to 1040F (

- 10 0C to 400C) Dimensions
– 17 1⁄4” x 17 3⁄4” x 12” **GIMBAL** Model
– ZENMUSE X3 Output Power (with camera)
– Static: 9W; In Motion: 11W Opera ting Current
– Static: 750mA; In Motion: 900mA Angular Vibration Range

- ±0.03 0 Mounting
– Detachable Controllable Range
– Pitch:

- 90 0 to +300; Pan: ±3200 Mechanical Range
– Pitch:

- 125 0 to 450; Pan: ±3300 Max Controllable Speed
– Pitch: 120 0/s; Pan: 1800/ s **CAMERA** Name
– X3 (Zenmuse X5 for Inspire 1 Pro) Model
– FC35041 **APPENDIX B -**  **PAGE 2** Total Pixels
– 12.76M (16 mp for Inspire 1 Pro) HD Video Recording
– UHD(4K) Operating Temperature Range
- 32 0F

- 104 0F (00C

- 40 0C) **TRANSMITTER** Name
– C1 Operating Frequency
– 5.728
- 5.850GHz; 2.400
- 2.483GHz Communicating Distance (unobstructed)
– 2000m Output Power
– 9W Operating Temperature Range
- 14 0F to 1040F (

- 10 0C to 400C) Battery
– 600mAh LiPo 2S42 

### APPENDIX C **DJI S1000 SPECIFICATION SHEET WEIGHT**  **AND SIZE:** Frame Arm Length : 386mm Frame Arm Weight (with Motor, ESC, Propeller ) : 325g Center Frame Diameter : 332mm Center Frame Weight(with L anding Gear Mounting Base, Servos) : 330g Landing Gear Size : 460mm(L ength)X511mm(Width)X350mm(Height) (Top width: 15 5 mm) **MOTOR:** Stator Size : 41x14mm KV : 400rpm/V Max Power : 500W Weight(with Cooling Fan) : 158g **FLIGHT PARAMETERS** : Takeoff Weight : 6.0kg~11.0kg Total Weight: 4.2Kg Power Battery : LiPo (6S 、 10000mAh~20000mAh 、 (Min)15C) Max Power Consumption : 4000W Hovering Power Consumption:1500W (@9.5Kg Takeoff Weight) Hover Time : 15min (@15000mAh & Takeoff Weight 9.5Kg) **FOLDABLE PROPELLER:** Material : High strength performance engineered plastics Size : 15x5.2 inch Weight : 13g43 

### APPENDIX D **ACTIONDRONE AD1**
**SIZE 17.13 in (435**  **mm) WEIGHT**  **4.8 lbs (2.18 kg) CRUISING SPEED:**  **17.9 mph (8 m/s) FLIGHT ENDURANCE:**  **20 Minutes BATTERY:**  **1 LiPo MODES:**  **Autonomous GPS, Manual, Attitude ACRES COVERED:**  **100 sq.m in 7 mins (10km/sec) T**  **ELEMETRY RANGE: 1 mi (1.6 km)**  **W IND TOLERANCE:**  **2 0 mph (72 km/h)** 44 APPENDIX

– E

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