UNITED STATES OF AMERICA DEPARTMENT

OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

VIDEO TECHNOLOGY

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), 91.103(b)(2), 91.105, 91.109,

91.119 (b) (c) (d)

, 91.121, 91.151 (b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.4 17(a) & (b) CONCERNING COMMERCIAL OPERATION OF A DJI PHANTOM QUADCOPTER

, A DJI

PHANTOM II VISION PLUS QUADCOPTER, A DJI INSPIRE

- 1 PRO QUADCOPTER UNMANNED

AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)



## Submitted on 12/16/2015

Video Technology Randal Schildmeyer Owner/Founder 235 Boyson Rd. NE Cedar Rapids, IA 52402

319 377

- 4542 rschildmeyer@mchsi.com

CDL Hazmet2 GLOSSARY OF ABBREVIATIONS

AGL

AOI

ATC

ATO

AV

CFR

COA

FAA

FAR

FLIR

GCS

GPS

LOL

NAS

NOTAM

PIC

Section 333

SO

SOP

UA

UAS

UAV

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 Forward looking infrared Radiometer

Station Global Positioning System

Loss of Link National Airspace System

Notice to Airman

Pilot in Command FAA Modernization and Reform Act of 2012 (FMRA) Section 333 Safety

Observer Standard Operating Procedures

Unmanned Aircraft Unmanned Aircraft System

Unmanned Aerial Vehicle Visual Flight Rules

Visual Line of Site

Visual Meteorolo gical Conditions Vertical Takeoff and Landing3 SUMMARY

Video Technology seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a)

, 91.103(b)(2), 91.105, 91.109, 91.119 (b) (c) (d) , 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 Video Technology to operate Unmanned Aircraft Systems, small (UASs) for the commercial purpose of conducting aerial video and photography of construction sites, real estate, sporting events, construction site, farm surveys, low

- profile

news events, landscape , inspections of equipment and power line systems using normal and

FLIR cameras within the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Video Technology provides its clients with expertise and knowledge in advanced technologies and solutions to increase efficiency, productivity and effectiveness. Randal Schildmeyer , founder of Video Technology has had over 40

- years’ experience in the television industry in all aspects of

it video and photography, engineering , and has over 3 00 hours of flight time on various sizes of

Unmanned Aerial V ehicles (UAV). The objective of Video Technology doing aerial video and photography operations is to provide high quality imaging for a variety of commercial, sports, public, residential, low priority news stories and governmental uses, specifically targeting the following :

 Construction sites before

, during and after

 Events public and private

 Real

- estate marketing

 Aerial acquisitions used for inspections of public and private structures.

 Farm Land inspections

 DNR, County Parks projects and promotions

 Search and Rescue operations

 Commercial

, Sports

, low priority news production

 Power line inspections using FLIR cameras to inspect lines and insulators for heat and possible points of failure.

BACKGROUND

Unmanned Aircraft Systems: DJI Phant om II quadcopter, DJI Phantom II Vison + quadcopter and

DJI Inspire quadcopter UAVs Video Technology seeks an exemption to operate UASs for compensation or hire within the NAS. The DJI Phantom II quadcopter , DJI Phantom II Vison+ quadcopter and DJI Inspire

- 1 pro quadcopter are vertical takeoff and landing (VTOL) Unmanned Aerial Vehicle (UAV) with a Ground Control Station (GCS) utilizing electronic tablet or laptop.

1. The DJI Phantom

- II quadcopter has a maximum gross weight of approximately 3 pounds, while having a length of 17 inches width of 17 inches (propeller tip to propeller tip) , height of 8 inches, and a maximum speed of approximately 3 0 knots The DJI Phantom quadcopter UAV is equipped with four main rotors; driven by a DJI 5200mAh

LiP o Battery to power four electric motors and on board electronics

.
2. The DJI Phantom II vision + quadcopter has a maximum gross weight of approximately

3 pounds, a length of 17 inches, width of 17 inches (propeller tip to propeller tip) , height4 of 8

- inches, and a maximum speed of approximately 30 knots. The DJI Phantom II

Vision+ quadcopter is equipped with four main rotors; driven by a DJI 5200mAh LiPo Battery to power four electric motors and on board electronics

.
3. The DJI Inspire

- 1 Pro quadcopter has a maximum gross weight of approximately 6.5 pounds, a length of 17 .75 inches, width of 17 .5 inches (propeller tip to propeller tip)

, height of 12

- inches, and a maximum speed of approximately 42 knots., and the DJI

Phantom II Vision+ quadcopter is equi pped with four main rotors; driven by a DJI

5700mAh LiPo

- 6S Battery to power four electric motors and on board electronics

.
The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and DJI Inspire

- 1 Pro quadcopter UAVs that will be operated by Video Technology 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 Registra tion Marking

.

BASIS FOR PETITION

Petitioner, Video Technology, 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 Aircr aft Systems , hereby petitions the Administrator to commercially operate The DJI Phantom II quadcopter , DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter 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. 1 03(b)(2), 91.105 (a) , 91.109 (a)1 & (a)(2) , 91.119 (b)(c)(d)

, 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, Video Technology operation of The DJI Phantom II quadcopter, DJI Phantom II Vision+ and the DJI Inspire

- 1 Pro quadcopter UAVs m eets 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, Video Technology 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.

Video Technology submits that the requested relief is proper since an equivalent level of safety will be ensured. Video Technology 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, an d Instruction Manuals). Furthermore, Video Technology will document and maintain all maintenance

records for The DJI Phantom II quadcopter, DJI Phantom II Vision+ and the DJI Inspire

- 1 Pro quadcopter UAVs.

Relief from certain requirements of Section 61.113 (a) and (b), entitled Private pilot privileges and limitations: Pilot in command , is requested by Video Technology to the extent necessary to allow a Pilot in Command (PIC) who is able to safely operate The DJI Phantom II quadcopter, DJI Phantom II Vision+ and the DJI Inspire

- 1 Pro quadcopter UAVs in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.5

Video Technology seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness

, because The DJI Phantom II quadcopter, DJI Phantom II Vision+ and the DJI Inspire

- 1 Pro quadcopter UAVs do not require an airworthiness certificate in accordance wit h 14 C.F.R. Part 21, Subpart H. As such, Video Technology submits that it will ensure that The DJI Phantom II quadcopter, DJI Phantom II Vision+ and the DJI Inspire

- 1 Pro quadcopter are in an airworthy condition, prior to every flight, by determining t hat the UAVs are in compliance with the operating

documents (i.e., Monthly Maintenance Log, Instruction Manuals), and that the aircraft are in a condition for safe flight.

Video Technology also seeks an exemption from the requirements of Section 91.121, entitl ed Altimeter Settings , as The DJI Phantom II quadcopter, DJI Phantom II Vision+ and the DJI Inspire

1 Pro quadcopter UAVs will not have a typical barometric altimeter onboard. However, altitude
information of The DJI Phantom II quadcopter, DJI Phantom II Vision+ and the DJI Inspire

- 1 Pro quadcopter UAVs will be provided to the PIC via Global Positioning System (GPS) equipment, and radio communications telemetry data link, which downlinks from the UAVs to the GCS for active monitoring of the flight path. Th is altitude information, combined with Video Technology’ operation

of The DJI Phantom II quadcopter, DJI Phantom II Vision+ and the DJI Inspire

- 1 Pro quadcopter UAVs within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equiv alent to
Section 91.121.

Additionally, Video Technology seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions . Video Technology submits that safety will not be affected by operation of The DJ I Phantom II quadcopter, DJI Phantom II Vision+ and the DJI Inspire

- 1 Pro quadcopter UAVs during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration of approximatel y 25 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 5 minutes.

In accordance with 14 C.F.R. § 11.81, Video Technology provides the following information in support of its petition for exe mption:

A. Name and Address of the Petitioner. The name and address of the Petitioner and point of

contact is: Video Technology

Randal H Schildmeyer , owner/founder 235 Boyson Rd N.E. Cedar Rapids, IA 52402

321

- 228

- 7714 rschildmeyer@mchsi.com

B. The Specific Sections of 14 C.F.R. From Which Video Technology Seeks Exemption.

1. Video Technology Seeks Exemption from the Requirements of Section 61.113(a) and (b).

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

, subsec tions (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 aircraft6 (b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if

— (a) The flight is only incidental to that business or employment; and

(b) The aircraft does not carry passengers or property for compensation or hire.

2. Video Technology Seeks Exemption From The Requirements Of Section 91.7(a).

Section 91.7, entitled Civil A ircraft airworthiness , subsection (a), states the following:

(a) No person may operate a civ il aircraft unless it is in an airworthy condition.

3. Video Technology Seeks Exemption From The Requirements Of Section 91.103(b) (2).

Section 91.103 (b) (2) Pre

- Flight action

(b) For any flight, runway lengths at airports of intended use, and the

following takeoff and landing distance information:

( 2 ) For civil aircraft other than those specified in paragraph (b)(1) of

this section, other reliable information appropriate to the aircraft, relating to aircraft performance under expected values of ai rport elevation and runway slope, aircraft gross weight, and wind and temperature.

4. Video Technology Seeks Exemption From The Requirements Of Section

91.105.

Section 91.105 Flight crewmembers at stations.

(a) During takeoff and landing, and while in route, each required flight

crewmember shall

—

(1) Be at the crewmember station unless the absence is necessary

to perform duties in connection with the operation of the
aircraft or in connection with physiological needs; and

(2) Keep the safety belt fastened whil e at the crewmember

station.

(b) Each required flight crewmember of a U.S.

- registered civil aircraft

shall, during takeoff and landing, keep his or her shoulder harness
fastened while at his or her assigned duty station. This paragraph
does not apply if

—

(1) The seat at the crewmember's station is not equipped with a

shoulder harness; or

(2) The crewmember would be unable to perform required duties

with the shoulder harness fastened.7

5. Video Technology Seeks Exemption From The Requirements Of Section

91.109.

Section 91.109 Flight instruction

Simulated instrument flight and certain flight tests.

(a) No person may operate a civil aircraft (except a manned free balloon)

that is being used for flight instruction unless that aircraft has fully
functioning dual controls. However, instrument flight instruction may
be given in an airplane that is equipped with a sing le, functioning

throw

- over control wheel that controls the elevator and ailerons, in
place of fixed, dual controls, when

—

(1) The instructor has determined that the flight can be conducted

safely; and

(2) The person manipulating the controls has at least a priva te

pilot certificate with appropriate category and class ratings.

(b) An airplane equipped with a single, functioning throw

- over control

wheel that controls the elevator and ailerons, in place of fixed, dual
controls may be used for flight instruction to co nduct a flight review
required by§ 61.56 of this chapter, or to obtain recent flight
experience or an instrument proficiency check required by § 61.57

when

—

(1) The airplane is equipped with operable rudder pedals at both

pilot stations;

(2) The pilot manipulating the controls is qualified to serve and

serves as pilot in command during the entire flight;

(3) The instructor is current and qualified to serve as pilot in

command of the airplane, meets the requirements of§
61.195(b) , and has logged at least 25 hours of pilot

- in

command flight t ime in the make and model of airplane; and

(4) The pilot in command and the instructor have determined the

flight can be conducted safely.

(c) No person may operate a civil aircraft in simulated instrument flight

unless

—

(1) The other control seat is occupied by a safety pilot who

possesses at least a private pilot certificate with category and
class ratings appropriate to the aircraft being flown.

(2) The safety pilot has adequate vision forward and to each side

of the aircraft, or a competent observer in the aircra ft
adequately supplements the vision of the safety pilot; and

(3) Except in the case of lighter

- than

- air aircraft, that aircraft is

equipped with fully functioning dual controls. However,
simulated instrument flight may be conducted in a single

engine airplan e, equipped with a single, functioning, throw

-8 over control wheel, in place of fixed, dual controls of the
elevator and ailerons, when

—
(i) The safety pilot has determined that the flight can be
conducted safely; and

(ii) The person manipulating the controls has a t least a private
pilot certificate with appropriate category and class ratings.

(d) No person may operate a civil aircraft that is being used for a flight

test for an airline transport pilot certificate or a class or type rating on
that certificate, or for apart 121 profic iency flight test, unless the pilot
seated at the controls, other than the pilot being checked, is fully
qualified to act as pilot in command of the aircraft.

6. Video Technology Seeks Exemption From The Requirements Of Section

91. 119

.
Section 91.119 Minimum safe altitudes: General.

Except when necessary for takeoff or landing, no person may operate an
aircraft below the following altitudes:

(a) Anywhere

. An altitude allowing, if a power unit fails, an emergency

landing without undue hazard to persons or prop erty on the surface.

(b) Over congested areas. Over any congested area of a city, town, or

settlement, or over any open air assembly of persons, an altitude of
1,000 feet above the highest obstacle within a horizontal radius of
2,000 feet of the aircraft.

(c) Over other than congested areas. An altitude of 500 feet above the

surface, except over open water or sparsely populated areas. In those
cases, the aircraft may not be operated closer than 500 feet to any
person, vessel, vehicle, or structure.

(d) [ Helicopte rs, powered parachutes, and weight

- shift

- control aircraft. If
the operation is conducted without hazard to persons or property on the

surface

—

(1) A helicopter may be operated at less than the minimums

prescribed in paragraph (b) or (c) of this section, provid ed each
person operating the helicopter complies with any routes or
altitudes specifically prescribed for helicopters by the FAA; and

(2) A powered parachute or weight

- shift

- control aircraft may be

operated at less than the minimums prescribed in paragraph
(c) of this section. 

### ]

.

7. Video Technology 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 or9 flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

--
(2) 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; 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.

8. Video Technology Seeks Exemption From The Requirements Of Section 91.151(b).

Section 91.151, entitled Fuel requir ements 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

.10

9. Video Technology 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[.]

10. Video Technology Seek s 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. I t has been approved for return to service by a person authorized under § 43.7 of this chapter.

11. Video Technology 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. A n annu al 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 chap ter11

12. Video Technology 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 a nd 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 descriptio n (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 involv es 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.12

(b) The owne r 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 r ecords 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 t he defects are repaired and the aircraft is approved

for return to service.

C. The Extent Of Relief Video Technology Seeks And The Reason Video Technology Seeks
The Relief.

1. Extent Of Relief Video Technology Seeks And The Reason Video Technology 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 UAVs flight operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.11 3(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 passeng ers or property for compensation or hire.

As set forth more fully below, Video Technology submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate The DJI Phantom II quadcopter, DJI

Phantom II Vision+ and the DJI Inspire

- 1 Pro quadcopter UAVs unless that PIC has met

certain flight

- hour and currency requirements, demonstrating that the PIC is able to safely operate either The DJI Phantom II quadcopter, DJI Phantom II Vision+ and the DJI Inspire

- 1 Pro quadcopter UAVs in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures.

Further, Video Technology submits that all flights of The DJI Phantom II quadcopter, DJI

Phantom II Vision+ and the DJI Inspire

- 1 Pro quadcopter UAVs, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to Video Technology business; and (2) will not carry passengers or property for compensation or hire.13

2. Extent Of Relief Video Technology Seeks And The Reason Video Technology Seeks Relief From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the exten t required to allow Video Technology to determine The DJI Phantom II quadcopter, DJI

Phantom II Vision+ and the DJI Inspire

- 1 Pro quadcopter UAVs are in airworthy condition prior to every flight by ensuring that the UAVs is in compliance with the operating documents (i.e., the Video Technology Aerial Operations Manual, Flight log, Monthly Maintenance Log, and Instruction Manuals).

Video Technology seeks the requested relief because The DJI Phantom II quadcopter, DJI

Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Video Technology will ensure that t he DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and Instruction Manuals) prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated in the conditions and limitations below.

3. Extent Of Relief Video Technology Seeks And The Reason Video Technology Seeks Relief From Section 91.103(b) (2)

Relief from Section 91.103(b)

- (2) Preflight action, is requested because Video Technology

has no inten t ion of flying the DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs in or into a controlled air space such as an airport or no fly zone. The DJI Phanto m II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter are VTO L (Vertical Takeoff & Landing) UAVs that do not require the use or need of an airport. The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the D JI Inspire

- 1 Pro quadcopter UAVs are not permitted to fly in controlled airspace . T he manufacture r has programmed The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs not to fly at some airport s and con trol areas. Also the requirement for reliable aircraft performance base on values of airport elevation and runway slop, aircraft gross weight and wind and temperature is

ir relevant to Video technology use of the DJI Phantom II quadcopter, DJI Phantom II Vi sion+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs because they are not permitted to operate near airport s but Video Technology would abide to weather conditions at the location

the UAV is to used and not exceed the capabilities the DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAV’s set by the

manufacturer. Video Technology will also monitor for NOTAM s using a UAV app on a mobile

device

4. Extent Of Relief Video Technology Seeks And The Reason Video Technology Seeks Relief From Section 91.105)

Relief from Section 91.105 Flight crewmembers at stations is requested because the DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter are UA (U nmanned Aircraft) and do not have crewmembers or work stations on

board . Video Technol o gy s seeks relief Section 91.10514

5. Extent Of Relief Video Technology Seeks And The Reason Video Technology Seeks
Relief From Section 91.10 9 )

Relief from Section 91.109 Flight Instruction because Section 91.109 references to equipment not on board the DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs . The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs fall s under qualifications

covered Section 333 and H.R. 658

- 62 Subtitle B Section 331, Section 332, Section 333, Section 334, Section 335, Section 336. Video Technology is seeking relief 61.113 which is

associated with asking for relief from this Section 91.109.

6. Extent Of Relief Video Technology Seeks And The Reason Video Technology Seeks
Relief From Section 91.1 1 9 (b ) (c) (d)

Relief from Section 91.119 Minimum safe altitudes Video Technology will comply with the

rules set in section 333 were the maximum altitude of 400

- feet above terrain and line of sigh of the DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs. Video Technology seeks relief form Section 91. 119 which requires Minimum altitudes used by general manned aviation which exceeds the 400 foot limit above

terrain tha t is allowed for The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs which these a ircraft fall under in Section 333

.

7. Extent Of Relief Video Technology Seeks And The Reason Video Technology Seeks
Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of The DJI Pha ntom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry datalink to downlink altitude information from the UA to

the PI C at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAVs operations be reported to air traffic control (ATC) in feet above ground level (AGL), Video Technology seeks the requested relief because The DJI Ph antom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs 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 fully set forth herein, an equivalent level of safety wi ll be maintained since The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter` UAVs are equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure se tting will be established prior to each flight, and provides the PIC with altitude information of the UAVs on the heads

- up display of the GCS.15

8. Extent Of Relief Video Technology Seeks And The Reason Video Technology Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to allow flights of the battery powered The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro qu adcopter UAVs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 25 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 5

- minutes. Video Technology seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs will severely constrain the practicality of any aerial video or still photo flight operations that Video Technology proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of The DJI Phantom II

qu adcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs operating documents, and Video Technology' proposed operating

l imitations, ensure that Video Technology will safely operate the battery powered The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs during daylight hours in visual meteorological conditions (VMC), und er visual flight rules (VFR), with enough battery power to fly for a total duration of 25 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at

least 5 minutes.

9. Extent Of Relief Video Technology Seeks And The Reason Video Technology 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, Video Technology requests relief from these

Sections because The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs do not require airworthiness certificates. As set forth more fully below, T he DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs meet the conditions of FMRA Section 333 for operation

without an airworthiness certificate.

Accordingly, Video Technology will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the UASs operating documents ( i.e., the Video Technology Aerial Operations Manual, Monthly Maintenance Log, and Instruction Manuals). Furthermore, Video Technology will document and maintain all maintenance records for The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopte r UAVs.16

D. The Reasons Why Granting Video Technology 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 Video Technology to safely, effici ently, and economically perform aerial video and photography of construction sites, real estate, events and landscape over certain areas of the United States.

Additionally, use of The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and

the DJI Inspire

- 1 Pro quadcopter UAVs will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of Video Technology' proposed operation of The DJI Phantom II quadcopter, DJI Phantom II Vision+

qu adcopter and the DJI Inspire

- 1 Pro quadcopter UAVs will be realized without implicating any privacy issues. `

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

. The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs 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 The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs would reduce the amount of manned aircraft in the NAS, reduce noise and air pollutio n, as well as increase the safety of life and property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. The Public will benefit from the Safety and Efficiency of the DJI Phantom II quadcopter, DJI

Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs

. Conducting aerial acquisitions with The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs, instead of manned aircraft, will greatly benefit the publ ic 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 II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs 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 photogra phy, while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The DJI Phantom II quadcopter,

DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs, while reducing the carbon footprint of aerial acquisitions, also el iminates noise pollution, as the UAVs are propelled by battery powered electric motors, rather than an internal combustion engine.

By using The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs to perfor m aerial acquisitions, the substantial risk to life and17

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 fl ight crew members located onboard the aircraft, The DJI Phantom II quadcopter,

DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs (weighing approximately 3 pounds

, 3 pounds , 6.5

- pounds respectively, at their maximum gross weights

w ith lengths of 17

- inches , 17

- inches and 17.75 inches respectively, widths of 17 inches

, 17inches and 17.75 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 II quadcopter,

DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs Will Benefit

the Economy.

In addition to being safe and efficient, The DJI Phantom II quadcopter, DJI Phantom II

Vision+ quadcopter a nd the DJI Inspire

- 1 Pro quadcopter UAVs are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quad copter UAVs will allow United States based companies, like Video Technology, 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 The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJ I Inspire

- 1 Pro quadcopter UAVs 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 operatin g The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs, companies such as Video Technology, 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 II quadcopter,

DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs, provides a stable workforce that increases consumer spending; improves local, state, and federal tax

revenu es; and allows companies to invest in research and development in order to remain competitive both in the United States and abroad.

4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for

decades , Video Technology' proposed operation of The DJI Phantom II quadcopter, DJI

Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs will not implicate any privacy issues. Specifically, The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs will be operated only in compliance with operating documents (i.e., the Video Technology Aerial Operations Manual, Monthly Maintenance Log, and Instruction Manuals) which requires property owner involvem ent as well as local law enforcement notification, and in accordance with the Federal Aviation18

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 Video Technology Seeks Exemption.

1. Reasons Why the DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs Me et 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, Video Technology' operation of The DJI Ph antom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs 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 provide s authority for a UAVs to operate without airworthiness certification and sets forth requirements for considering whether a UAVs will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Sec tion 333 states the following, in part:

(a) In General.

-- Notwithstanding any other requirement of this subtitle, and not

later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft 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 dete rmination

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

withi n 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 4470 4 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 oper ate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system.

In seeking this exemption, Video Technology submits that The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs; (b) the pilot certification19

requirement; and (c) the specific operating limitations.

a. The Specifications of the DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs Demonst rate Its Safe

Characteristics.

The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs 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 technical specifications of the The DJI Phantom II quadcopter, DJI

Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs are set forth by the Specifications and Data Sheet, attached hereto as Exhibit A ,B

and C

.
ii. The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadc opter and the DJI Inspire

- 1 Pro quadcopter UAVs Autonomous Flight And Navigation Modes Enable The UAVs To Remain Within A Defined Operational Area.

The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs m ay be operated in both manual and fully autonomous flight modes. A complete description of the flight and navigational

modes ` of the DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs is provided at pages of the 3DRobotics APM2.6 User Manual, attached hereto as Exhibit C.20 iii. The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs Are Designed For

Automatic Return To Home Point Or Hover In The Event Of Loss Of

The Control Link Or Navigation.

When the Control Link is lost, The DJI Phantom II quadcopter, DJI Phantom

II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs do not reacquire control link data from the GCS, the UAVs will as sume that the Control Link is lost and the UAVs will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown.

A complete description of the Failsafe Functions of the The DJI Phantom II quadcopter, DJ I Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs are set forth on pages of the 3DRobotics APM2.6 User Manual, attached hereto as Exhibit C.

iv. The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs GCS and Its Operation.

A complete description of the operation and specifications of The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs GCS and flight control software is provided

at pages of the User Manual. User Manuals are attached hereto as Exhibits
C.

b. Flight Operations of the DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs1 UASs Are Limited to the Line Of Sight of a Certificated Pilot in Command with a Safety Observer.

Video Technology will only utilize certificated pilots to act as a pilot in command (PIC) of The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs. Additionally, a safety observer will assist all pilots during flight time.

c. Flights of the DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs Will Be Conducted Pursuant To Specific Operating Limitations.

I n seeking this exemption, Video Technology proposes to commercially operate The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs for the special purpose of conducting aerial video and photography over c ertain 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 5 5 pounds maximum gross weight: The DJI Phantom II quadcopter, DJI

Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs Unmanned Aircraft Systems. Proposed operations of any other aircraft will require a new petition or a petition to amen d this grant.21 2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photography.

3. The UAVs may not be flown at an indicated airspeed exceeding 100 knots.

4. The UAVs must be operated at an altitude of no more than 500 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved by ATC. All altitudes reported to ATC must be in feet AGL.

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

- issued airman
medical certificate.

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted.

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure th at the SO can perform the functions prescribed in the operating documents.

8. The SO 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 the camera or other instruments.

9. The operating documents and the grant of exemption must be accessible during UAVs operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations con tained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as

outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the 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 UAVs 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 UAVs to ensure that it is in a

cond ition 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 UASs is found to be in a condition for safe flight . The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records.

11. Any UAVs that has undergone maintenance or alterations that affect the UAVs operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraft records.22 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 UASs 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 aircraft records, including total time in service, description of work accomplished, and the signature of the authorized person returning the UAVs to service.

15. Each UAVs operated under this exemption must comply with all manufacturer Safety

Bu lletins.

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 student pilot, private pilot certificate, or greater and at

least a current third class medical certificate.

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safely operate the UAVs in a manner consistent with how the UAVs will be op erated 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). Flig hts 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 p ersons not essential for flight operations are considered nonparticipants, and the PIC must operate the UAVs with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119.23 19. UAVs operations may not be conducted during nig ht, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized.

20. The UAVs may not operate within 5 nautical miles of a 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 UAVs may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

22. If the UAVs loses communications or loses its GPS signal, it must return to a Pre

determined location within the planned operating area and lan d 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 w ind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UAVs with 25% battery power remaining.

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Wa iver or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (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 UAVs must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.24 28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must b e available to the PIC at the Ground Control Station of the UAV any time the UAV is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

29. The UAVs must remain clear and yield the right of way t o all manned aviation operations

and activities at all times.

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

31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than the PIC, SO , operator trainees or essential persons), vessels, vehicles,

and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UAVs, flight operations must cease immediately and/or;

b. The aircraft is operated near vessels, v ehicles 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 not present an undue hazar d, and;

c. Operations nearer to the PIC, 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 private or controlled

- access property with permission from the land own er/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

boundarie s 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

W eb site: www.ntsb.gov.

2. Reasons Why an Exemption from the Requirements of Section 61.113(a) and (b) Would Not Adversely Affect Safety.

Video Technology submits that the equivalent level of safety established by Sectio n 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate The DJI Phantom II quadcopter,

DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter25

UAVs in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and

structures.

Considering Video Technology' proposed area of operations, and the operating limitations

set forth

- above; the parallel nature of private pilot aeronaut ical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAV s, Video Technology submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for Video Technology' specific proposed flight operations.

The FAA has previously grant ed relief from Section 61.113(a) and (b) specific to UAVs, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

Video Technology will not allow any PIC to operate the DJI Phantom II quadcopter, DJI

Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs unless that PIC has demonstrated, by meeting minimum flight

- ho ur requirements or The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs training and currency requirements, that the PIC is able to safely operate The DJI Phantom II quadcopter, DJI Phantom II Vision+ q uadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs 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 a ccumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAVs rotorcraft pilot (with a minimum of 5 hours of those hours as a UAVs pilot operating the same make and model of UAS to be used for operations under th e exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes).

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in comp liance with applicable regulations will ensure an equivalent level of safety during Video Technology' proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent wit h 14 CFR 61.51(b), 25 hours of total time as a UAVs rotorcraft pilot including at least 10 hours logged as a UAVs pilot with a multi

- rotor UAVs. Prior to operations under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of 5 hou rs as a UAVs pilot operating the same make and model of UAVs to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be i ncluded in the 10 hours of multi

- rotor time and the 10 hours may

be included in the total 25 hours of UAVs rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days26 (for currency purpose s). 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 documen ted flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience

- building flights can also be conducted under the grant of exemption to accomplish the required flight

ti me. During training, proficiency, and experience

- building flights the PIC is required to operate the UAVs with appropriate distances in accordance with 14 C.F.R 91.119.

Exemption No. 11138 at page 15.

Accordingly, Video Technology will ensure safe operatio ns by not allowing any PIC to operate the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

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, Video Technology will ensure that the DJI Phantom II quadcopter, DJI

Phantom II Vision+ quad copter and the DJI Inspire

- 1 Pro quadcopter UAVs is in an airworthy condition based upon the UAV’s compliance with its operating documents and as

stated in the conditions and limitations herein.

Additionally, the FAA has previously granted relief from Sect ion 91.7(a) specific to UAVs, 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, 1 1160, 11161).

4. Reasons Why an Exemption from the Requirements of Section 91.103(b) (2) Would Not Adversely Affect Safety.

Video Technology will not operate the DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs in side area s of controlled airspace at airports and any other controlled air space unless permission granted from authorize d person or persons. The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs are VTOL aircraft and do not require an airport or will operate at any airport facility therefore would not adversely affect safety at those

facilities.

The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs will be flown in conditions not to exceed manufactures recommended conditions for a safe flight and Video Technology will operate The DJI

Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs with the rules set in section 333.

5. Reasons Why an Exemption from the Requirements of Section 91.105 Would Not Adversely Affect Safety.

The equivalent level of safety es tablished by Section 91.105 would be maintained because

there are no crew on board the DJI Phantom II quadcopter, DJI Phantom II Vision+27

quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs

6. Reasons Why an Exemption from the Requirements of Section 91.109 W ould Not Adversely Affect Safety.

Section 91.109 Would Not Adversely Affect Safety because of the equipment mentioned in Section 91.109 is for general aviation aircraft which is not on board or pertains to the DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs defined in Section 333.

Video Technology submits that the equivalent level of safety established by Section 91.109 will be maintained because no PIC will be allowed to operate the DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate The DJI Phantom II quadcopter, DJI

Ph antom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter

Video Technology will not allow any PIC to operate the DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs unless that PIC has demonstrated, by meeting minimum flight

- hour requirements or The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs training and currency requirements, that the PIC is able to safely operate The DJI Phantom II quadcop ter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels,

vehicles and structures

7. Reaso ns Why an Exemption from the Requirements of Section 91.119 Would Not Adversely Affect Safety.

Exemption Section 91.119 Would Not Adversely Affect Safety but improve it. This rule was written for general aviation aircraft to maintain altitude for safety of people in aircraft and property. The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs do not qualify as general aviation but fall under the rules mentioned in Section 333, which require this type of ai rcraft to stay below the altitude 400

- feet above terrain and obstacles.

Maintaining this rule without exemption would require UAVs to occupy the same airspace as general aviation making this dangerous and in violation of Section 333 where UAV must stay bel ow 400

- feet above terrain and obstacles.

8. Reasons W hy 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 II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs will be provided to the PIC via

G PS equipment and a radio communications telemetry data link, which downlinks from the UAVs to the GCS for active monitoring of the flight path and altitude. This altitude information, combined with Video Technology' s operation of The DJI Phantom II quadcop ter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UAVs within visual line of sight, at or below 500 feet AGL, will ensure a level of safety28

equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically established by the UAVs at ground level.

The FAA has previously granted relief from Section 91.121 specific to UAV in circumstances similar, in all mate rial 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).

9. Reasons Why an Exemption from the Requirements of Section 9 1.151(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 UAS flight, a zero altitude initiation point is; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, Video Technology will ensure that it will safely operate the battery powered UAS durin g daylight hours in VFR conditions, with enough battery power to fly for a total duration of 2 5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 5

minutes.

Here, as in Exemption No. 11109, t he technical specifications of the DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter ; 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 II quadcopter, DJI Phantom II

Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UASs provide audible and visual warnings to the PIC at the GCS when the UASs experiences low battery voltage, the first warning occurring at approximately 25% remaining battery power, and at approximately 10% remaining battery power UASs will descend and land automatically.

Significantly, previous exemptions g ranted 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 mini mums 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. Exem ption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

10. 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, Video Technology submits that the equivalent level of safety with regard to the regulatory maintenance and alteration requirements established by

Secti ons 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because Video Technology will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practice s prescribed in the operating documents (i.e., the Video Technology Aerial Operations Manual, Monthly Maintenance Log, Inspire 1 Instruction Manual). Furthermore,29

Video Technology will document and maintain all maintenance records for the DJI

Phantom 2 Vis ion+ and DJI Inspire 1 UASs.

Since The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UASs will be inspected as prescribed by the operating documents, Video Technology 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 II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter User

Manuals are attached hereto as Exhibit A,B and C ; a copy of the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS Maintenance LOG is attached hereto as Exhibit D, E and F

. Likewise, the exemption sought will not adversely affect safety because Video Technology 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 exemption sought would maintain an equivalent level of safety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the

DJI Phantom 2 Vision+ and DJI Inspire 1 UASs will be performed by trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log.

Significantly, previous exemptions granted by the FA A 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 Video Tech nology' proposed operating limitations, the operating documents, and the technical aspects of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs, Video Technology submits that safety will not be adversely affected by granting exemption from 14 C.F.R. Section s 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).

11. 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, Video Technology requests that the FAA prescribe special conditions for the intended operation of the DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter 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 §§ 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 UA S for the limited purpose of conducting aerial video and photography over certain areas of the United States for compensation or hire. FMRA Sect ion 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 cer tification 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. §30

21.16, for operation of the DJI Phantom II quadcopter , DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter 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. Se ction 21.16, entitled Special Conditions, states the following:

If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller

because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety

standard s for the aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent to that established in the regulations.

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the F AA may prescribe special conditions for Video Technology ’s intended operation of The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter 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),

9 1.407(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 Video Technology Seeks Exemption:

Video Technology seeks exemption from the requirements of 14 C.F.R Sections

6 1.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

A Brief Description Of The Nature Of The Exemption Video Technology Seeks:

This exemption will permit Video Technology to commercially operate an Unmanned Aircraft System, small (UASs) for the purpose of conducting aerial video and photography

over certain areas of the United States.

G. Any Additional Information, Views, or Arguments Available To Support Video Technology ' Request.

This Petition is mad e 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, Video Technology' 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, Video Technology will operate the DJI Phantom 2

Vision+ and DJI Inspire 1 UASs safely in the NAS, without creating a ha zard to users of the NAS, or the public, or otherwise pose a threat to national security.31 CONCLUSION

As set forth herein, Video Technology seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (F MRA), which will permit safe operation of the DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UASs commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography over certain areas of the United States. By granting 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

allowin g Video Technology to safely, efficiently, and economically operate the DJI Phantom 2

Vision+ and DJI Inspire 1 UASs commercially within the NAS.

WHEREFORE , in accordance with the Federal Aviation Regulations and the FAA Modernization

and Reform Act of 201 2, Section 333, Video Technology respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.103(b)(2), 91.105, 91.109, 91.119 (b) (c) (d), 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 Video Technology to operate the DJI

Phantom 2 Vision+ and DJI Inspire 1 UASs commercially for the purpose of conducting aerial video and photography over certain areas of the Unit ed States.

Video Technology will register the DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UASs as soon as the FAA completes the procedure needed to register and will place the necessary markings on the DJI Phantom II quadcopter, DJI

Phantom II Vision+ quadcopter and the DJI Inspire

- 1 Pro quadcopter UASs

.32

Dated: March 29, 2015
Respectfully submitt ed, Randal Schildmeyer , Owner Video Technology



### Video Technology

Randal Schildmeyer 235 Boyson Rd. NE Cedar Rapids, IA 52402

321

- 228

- 7714

rschildmeyer@mchsi.com

Appendices :

A

– DJI Phantom II Specifications Data Sheet

B

– DJI Phantom II Vision + quadcopter Specifications Data Sheet

C

– DJI Inspire 129 APPENDIX

– A

DJI Phantom II TECHNICAL SPECIFICATIONS

Video Technology only utilizes safe and reliable UASs. DJI is an industry leader in small UAS production. Our UASs utilizing 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 altit ude as well as limit flight to a predetermined and set distance. In addition, DJI software provides real

- time altitude and location information to the PIC via the lin k d monitor (laptop/tablet devices)

1. DJI Phantom

1.1 General Features

1.1.1 Ready to Fly, Multifunct ional Quad

- rotor System

1.1.2 Customized H3

- 2D and H3

- 3D Gimbal Support

1.1.3 Precision Flight and Stable Hovering

1.1.4 25min Flight Time & Smart Battery

1.1.5 Auto Return

- to

- Home & Landing

1.1.6 Advanced Power Management

1.1.7 Intelligent Orientation Control (IOC)

1.1.8 Easy Battery Replacement

1.1.9 Self

- tightening Propeller

1.1.10 Video Downlink Support

1.1.11 CAN

- Bus Expansion Module

1.2 Aircraft

1.2.1 Weight (Battery & Propellers included) 1000g

1.2.2 Hover Accuracy (Ready to Fly) Vertical: 0.8m; Horizontal: 2.5m

1.2.3 Max Yaw Angular Velocity 200°/s

1.2.4 Max Tilt Angle 35°

1.2.5 Max Ascent / Descent Speed

1.2.6 Ascent: 6m/s; Descent: 2m/s

1.2.7 Max Flight Speed

1.2.8 15m/s(Not Recommended)

1.2.9 Diagonal Length 350mm

1.2.10 Flight Time 25mins

1.2.11 Take

- off Weight ≤1300g

1.2.12 Operating Temperature

- 10°C ~ 50°C

1.2.13 Supported Battery29 1.3 DJI Smart Battery

1.3.1 DJI Smart Battery Type 3S LiPo

1.3.2 Capacity 5200mAh, 11.1V

1.3.3 Charging Environment R ange to 40 °C

1.3.4 Discharging Environment Range

- 20 °C to 50 °C

1.3.5 2.4GHz Remote Control

1.3.6 Operating Frequency 2.4GHz ISM

1.3.7 Communication Distance (open area)1000m

1.3.8 Receiver Sensitivity (1%PER)

- 97dBm

1.3.9 Working Current/Voltage 120 mA@3.7V

1.3.10 Built

- in LiPo Battery Working Current/Capacity

1.3.11 3.7V, 2000mAh31 APPENDIX

– B

DJI Phantom II Vision + TECHNICAL SPECIFICATIONS Video Technology only utilizes safe and reliable UASs. DJI is an industry leader in small UAS production. Our UASs utilizing 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 pre determined and set distance. In addition, DJI software provides real

- time altitude and location information to the PIC via the linked monitor (laptop/tablet devices)

2. DJI Phantom II Vision + QUADCOPTER

1.4 Aircraft

2.1.1 Supported Battery I 5200mAh LiPo Battery

2.1.2 Weight ( Battery & Propellers included) 1242g

2.1.3 Hover Accuracy (Ready to Fly) Vertical: 0.8m; Horizontal: 2.5m

2.1.4 Max Yaw Angular Velocity 200°/s

2.1.5 Max Tiltable Angle 35°

2.1.6 Max Ascent / Descent Speed Ascent: 6m/s; Descent: 2m/s

2.1.7 Max Flight Speed 15m/s (Not Rec ommended)

2.1.8 Diagonal motor

- motor distance 350mm

1.5 Camera

2.2.1 Operating Environment Temperature 0 °C

- 40 °C

2.2.2 Sensor size 1/2.3"

2.2.3 Effective Pixels 14 Megapixels

2.2.4 Resolution 4384×3288

2.2.5 HD Recording 1080p30 & 720p

2.2.6 Recording FOV 110° / 85°

2.2.7 Range Extender

2.2.8 Operating Frequency 2412

- 2462MHz

2.2.9 Communication Distance (open area) 500

- 700m

2.2.10 Transmitter Power 20dBm

2.2.11 Power Consumption 2W

2.3 Gimbal

2.3.1 Working Current Static : 750mA; Dynamic : 900mA

2.3.2 Control Accuracy ±0.03°

2.3.3 Controllable Range Pitch :

- 90°

- 0°

2.3.4 Maximum Angular Speed Pitch : 90°/s

2.4 Remote Control

2.4.1 Operating Frequency 5.728 GHz

- 5.85 GHz

2.4.2 Communication Distance (open area) CE Compliance: 400m; FCC Compliance: 800m31 2.4.3 Receiver Sensitivity (1%PER)

- 93dBm

2.4.4 Transmitter Power CE Compliance: 25mW; FCC Com pliance: 100mW

2.4.5 Working Voltage 120 mA@3.7V

2.4.6 Built

- in LiPo Battery Working Current/Capacity 3.7V, 2000mAh

2.5 DJI VISION App

2.5.1 System Requirement Of Mobile Device S version 6.1 or above/ Android system

version 4.0 or above

2.5.2 Mobile Device Support iOS recommended: iPhone 4s, iPhone 5, iPhone 5s, iPhone 6, iPhone 6 Plus, iPod touch 5 (available but not recommended: iPad 3, iPad 4, iPad mini)

2.5.3 Android recommended: Samsung Galaxy S3, S4, Note 2, Note 3 or phones of similar configuration31 APPENDIX

– C

DJI Inspire

- 1 Pro quadcopter TECHNICAL SPECIFICATIONS Video Technology only utilizes safe and reliable UASs. DJI is an industry leader in small UAS production. Our UASs utilizing software enabling the user to set parameters which will not allow flight into controlled airspa ce. 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

- time altitude and location information to the PIC via the linked monitor (laptop/tablet devices)

3. DJI Inspire 1 Pro QUADCOPTER

3.1 Aircraft

3.1.1 Model T600

3.1.2 Weight 2870 g (Battery and propellers included, Zenmuse X5 excluded)

3.1.3 3400 g (Battery, propellers and Zenmuse X5 included)

3.1.4 Max Takeoff Weight 3500 g

3.1.5 Hovering Accuracy (P Mode) Vertical: 0.5 m

3.1.6 Horizontal: 2.5 m

3.1.7 Max Angular Velocity Pitch: 300°/s

3.1.8 Yaw: 150°/s

3.1.9 Max Tilt Angle 35°

3.1.10 Max Ascent Speed 5 m/s

3.1.11 Max Descent Speed 4 m/s

3.1.12 Max Speed 18 m/s (ATTI mode, no wind)

3.1.13 Max Service Ceiling Above Sea Level 4,500 m (Software altitude limit: 120 m above takeoff point)

3.1.14 Max Wind Speed Resistance 10 m/s

3.1.15 Max Flight Time Approxi. 15 minutes

3.1.16 Motor Model DJI 3510H

3.1.17 Propeller Model DJI 1345T

3.1.18 Indoor Hovering Enabled by default

3.1.19 Operating Temperature 14° to 104° F (

- 10° to 40° C)

3.1.20 Diagonal Distance 559 mm

3.2 Remote Controller

3.2.1 Name C1

3.2.2 Operating Frequency 922.7~927.7 MHz (Japan Only)

3.2.3 5.725~5.825 GHz

3.2.4 2.400~2.483 GHz

3.2.5 Max Transmitting Distance FCC Compliant: 3.1 miles (5 km); CE Compliant: 2.1 miles (3.5 km)

3.2.6 (unobstructed, free of interference)

3.2.7 EIRP 10 dBm@ 900m MHz, 13 dBm@5.8 GHz, 20 dBm@2.4 GHz

3.2.8 Video Output Ports USB, Mini HDMI

3.2.9 Power Supply Built

- in battery

3.2.10 Charging DJI charger31 3.2.11 Dual User Capability Host

- and

- Slave connection

3.2.12 Mobile Device Holder Tablet or Smart Phone

3.2.13 Max Mobile Device Width 170mm

3.2.14 Output Power 9 W

3.2.15 Operating Temperature 14° to 104° F (

- 10° to 40° C)

3.2.16 Storage Temperature Less than 3 months:

- 4° to 113° F (

- 20° to 45° C)

3.2.17 More than 3 months: 72° to 82° F (22° to 28° C)

3.2.18 Charging Temperature 32° to 104° F (0° to 40° C)

3.2.19 Battery 6000 mAh 2S LiPo

3.3 B attery (Standard)

3.3.1 Name Intelligent Flight Battery

3.3.2 Model TB47

3.3.3 Capacity 4500 mAh

3.3.4 Voltage 22.2 V

3.3.5 Battery Type LiPo 6S High voltage battery

3.3.6 Energy 99.9 Wh

3.3.7 Net Weight 570 g

3.3.8 Operating Temperature 14° to 104° F (

- 10° to 40° C)

3.3.9 Storage Temperature Less than 3 mont hs:

- 4° to 113° F (

- 20° to 45° C)

3.3.10 More than 3 months: 72° to 82° F (22° to 28° C)

3.3.11 Charging Temperature 32° to 104° F (0° to 40° C)

3.3.12 Max Charging Power 180 W

3.4 Gimbal and Camera

3.4.1 General

01 Name Zenmuse X5

02 Dimensions 120 (W) x 135 (H) x 140 (D) mm

03 Weight 530 g (Including original lens, balancing ring, lens hood, Micro SD card)

04 Operating Temperature 32° to 104° F (0° to 40° C)

3.4.2 Camera

01 Lens Replaceable lens

02 M43 mount supporting auto

- focus

03 Supported Lens DJI MFT 15mm f/1.7 ASPH

04 Panasonic Lumix G Leica DG Summilux 15 mm f/1.7 ASPH

05 Olympus M.Zuiko Digital ED 12mm f/2.0

06 Olympus M.Zuiko 17mm f1.8 (Balancing ring will be available on the DJI Store soon)

07 Sensor Type 4/3 CMOS sensor

08 Effective Pixels 16 M

09 Max Resolution 4608x3456

10 ISO Range 100

- 25600

11 Electronic Shutter Speed 8 s

- 1/8000 s

12 Field of View DJI MFT 15mm f/1.7 ASPH 72°

13 Still Photography Modes Single shot

14 Burst shooting:3/5/7 frames

15 Auto Exposure Bracketing (AEB):3/5 bracketed frames at 0.7EV31 bias

16 Timelapse (3/5/7/10/20/30/60 sec)

17 Video Resolution UHD:4K (4096×2160) 24 /25p, 4K (3840×2160) 24/25/30p,2.7K (2704×1520) 24/25/30p; FHD:1920×1080 24/25/30/48/50/60p

18 Max Video Bitrate 60 Mbps

19 Supported File Systems FAT32 (≤ 32 GB), exFAT (> 32 GB)

20 Photo Formats JPEG, DNG (RAW)

21 Video Formats MP4/MOV (MPEG

- 4 AVC/H.264)

22 Supported Storage Devices Class 10 or UHS

- 1 or above

Micro SD cards

23 Max capacity of 64 GB

3.4.3 Origin Lens

01 Name DJI MFT 15mm f/1.7 ASPH

02 Focal Length f=15 mm (35 mm format equivalent 30 mm)

03 Aperture Type 7 diaphragm blades/circular aperture diaphragm

04 Maximum Aperture F1 .7

05 Minimum Aperture F16

06 Lens Construction 9 elements in 7 groups (3 aspherical lenses)

07 In Focus Distance 0.2 m to ∞ (from the focus distance reference line)

08 Mount Micro Four Thirds Mount

09 Angle of View 72°

10 Max. Diameter Approx. 2.26 inches (57.5 mm)

11 Overal l Length Approx. 1.42 inches (36 mm)

12 Weight Approx. 115 g

3.4.4 Gimbal

01 Angular Vibration Range ±0.02°

02 Mount Detachable

03 Controllable Range Pitch:

- 90° to +30° Pan ±320°

04 Max Controllable Speed Pitch: 120°/s Pan: 180°/s

3.4.5 Charger

01 Model A14

- 100P1A

02 Voltage 26.3 V

03 Rated Power 100 W

3.4.6 Battery (Optional)

01 Name Intelligent Flight Battery

02 Model TB48

03 Capacity 5700 mAh

04 Voltage 22.2 V

05 Battery Type 6S LiPo High voltage battery

06 Energy 129.96 Wh

07 Net Weight 670 g

08 Operating Temperature 14° to 104° F (

- 10° to 40° C)

09 Storage Temperature Less than 3 months:

- 4° to 113° F (

- 20° to 45° C)

10 More than 3 months: 72° to 82° F (22° to 28° C)31 11 Charging Temperature 32° to 104° F (0° to 40° C)

12 Max Charging Power 180 W

13 Max Flight Time Approx. 18 minutes

3.4.7 Battery (Standard)

01 Name Intelligent Flight Batter y Model TB47

02 Capacity 4500 mAh

03 Voltage 22.2 V

04 Battery Type LiPo 6S High voltage battery

05 Energy 99.9 Wh

06 Net Weight 570 g

07 Operating Temperature 14° to 104° F (

- 10° to 40° C)

08 Storage Temperature Less than 3 months:

- 4° to 113° F (

- 20° to 45° C)

09 More than 3 months: 72° to 82° F (22° to 28° C)

10 Charging Temperature 32° to 104° F (0° to 40° C)

11 Max Charging Power 180 W

3.4.8 Vision Positioning

01 Velocity Range < 8 m/s @altitude 6.56 feet (2 m)

02 Altitude Range 0.16

- 16.4 feet (5

- 500 cm)

03 Operating Environment S urfaces with clear patterns and adequate lighting (> 15 lux)

04 Operating Range < 9.84 feet (300 cm)

3.4.9 DJI GO App

01 Requirements iOS 8.0 (or later) and Android 4.1.2 (or later)

02 Supported Mobile Devices Compatible with iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air Wi

- Fi + Cellular, iPad mini 2, iPad mini 2 Wi

- Fi + Cellular, iPad Air 2, iPad Air 2 Wi

- Fi + Cellular, iPad mini 3, and iPad mini 3 Wi

- Fi + Cellular. This app is optimized for iPhone 5s, iPhone 6, and iPhone 6 Plus.

03 Compatible with Samsung tabs 70 5c, Samsung S6, Samsung S5, Samsung NOTE4, Samsung NOTE3, Google Nexus 9, Google Nexus 7 II, Ascend Mate7, Huawei P8 Max, Nubia Z7 mini, SONY Z3,EXPERIA, MI 3, MI PAD, Smartisan T1. *Support for additional Android devices available as testing and developme nt continues.