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

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: Edwin E. Brochin FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF Blade 350 QX3 AND DJI INSPIRE 1 UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)

Submitted on March 22 , 2015
Edwin E. Brochin Ultimate Outdoors TV LLC 1275 West 86 th St. Indianapolis, IN 46260 Tel: (317) 709

- 22352 TABLE OF CONTENTS Page
GLOSSARY OF ABBREVIATIONS...................................................................................3
SUMMARY................................................................. ..........................................................4
INTRODUCTION AND INTERESTS OF PETITIONER....................................................4
BACKGROUND........................................................................................ ............................4
BASIS FOR PETITION.........................................................................................................5
NAME AND ADDRESS OF PETITIONER.............................................................7
THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH EDWIN E BROCHIN SEEKS EXEMPTION.................................................................8
THE EXTENT OF RELIEF EDWIN E. BROCHIN SEEKS AND THE REASON EDWIN E. BROCHIN SEEKS THE RELIEF......................... 11
THE REASONS WHY GRANTING EDWINN E. BROCHIN ’S REQUEST WOULD BE IN THE PUBLIC INTEREST .........................................................15
THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY...................................... ....................................19
SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER......34 ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT EDWIN E. BROCHIN ’S REQUEST.........34
CONCLUSION..................................... ...............................................................................35
APPENDICES........................................................................................373 GLOSSARY OF ABBREVIATIONS
AGL Above Ground Level AOI Area of Interest ATC Air Traffic Control ATO Air Traffic Org anization AV Aerial Vehicle CFR Code of Federal Regulations COA Certificate of Authorization FAA Federal Aviation Administration FAR Federal Aviation Regulation GCS Ground Control Station GPS Global Positioning System LOL Loss of Link NAS National Airspace System NOTAM Notice to Airman PIC Pilot In Command Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333 SO Safety Observer SOP Standard Operating Procedures UA Unmanned Aircraft UAS Unmanned Aircraft System VFR Visual Flight Rules VLOS Visual Line of Site VMC Visual Meteorological Conditions VTOL Vertical Takeoff and Landing4 SUMMARY
Edwin E. Brochin seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b) , 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Edwin
E. Br ochin to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and p hotography of, real estate , film sets, and landscape over
certain areas of the United States.
INTRODUCTION AND INTERESTS OF THE PETITIONER Edwin E. Brochin, provides his clients with the highest quality digital content for use in their commercial, personal, and non

- profit multimedia projects. Edwin E. Brochin
has over 15 years of professional exper ience in film and television production on a national and international level. He is also an award winning filmmaker with accreditation from
film fe stivals around the world. HE is experience d in all aspects of aerial video and photog raphy and has been taking drone

- flying courses from the best pilots in the industry. The objective of Edwin E. Brochin ’s aerial video and photography operation s is to provide high qualit y imaging for to his editors to enhance production quality and value of his film and television projects :

• Documentary Film Making (Wildlif e Films)

• Television Series Production (Ultimate Outdoors TV)

• Aerial acquisitions used for in spections of private land and wildlife
management

.

• Increase public knowledge of UAS and promote safe UAS operations.5 BACKGROUND
Unmanned Aircraf t Systems: Blade 350 QX3 , DJI Inspire 1 UASs
Edwin E. Brochin seeks an exemption to operate DJI and QX3 systems for compensation or hire within the NAS. The Blade 350 QX3 and DJI Inspire 1 are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The Blade 350 QX3 has a maximum gross weight of approximately 2 pounds , while having a length of 18 inches , width of 18 inches, height of 9 inches, and a maximum speed of approximately 29 k nots. The DJI Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of approximately 42 knots. The Blade 350 QX3 and DJI Inspire 1UAs are equipped with four

ma in rotors; driven by Lithium Polymer battery powered electric motors. The Blade 350 QX3 and DJI Inspire 1 UAs that will be operated by Edwin E.
Brochin will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft , as well as 14 C.F.R Part 47, Aircraft Registration , and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking

. BASIS FOR PETITION Petitioner, Edwin E. Brochin , pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereby petitions the Administrator to commercially operate the Blade 350 QX3 , DJI Inspire 1
UASs in the National Airspace System (NAS), and for an exemption from the6 requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). In consideration of the speed, weight, size, and limited op erating area associated with the unmanned aircraft and its operation, Edwin E. Brochin ’s op eration of the Blade 350 QX3 and DJI Inspire 1 UASs meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordan ce with 14 C.F.R. Part 21, Subpart H. Accordingly, Edwin E. Brochin 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 wit h an airworthiness certificate.
Edwin E. Brochin submits that the requested relief is proper since an equivalent level of safety will be ensured. Edwin E . Brochin will use experienced personnel or technicians to perform maintenance, alterations, or preven tive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log , and Blade 350 QX3 and DJI Inspire 1 Instruction Manual). Furthermore, Edwin E. Brochin will document and maintai n all maintenance records for
the Blade 350 QX3 and DJI Inspire 1 UASs. Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command , is requested by Edwin E. Brochin to the extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an airman medical certificate, and who has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is a ble to safely o perate the Blade 350 QX3 and DJI Inspire 1 UASs in a manner consistent with this exemption,7 including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.
Edwin E. Brochin seek s relief from Section 91.7(a), entitled Civil aircraft
airworthiness , b ecause the Blade 350 QX3 and DJI Inspire 1 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Edwin
E. Brochin submits that he wi ll ensur e that the Blade 350 QX3 and DJI Inspire 1UASs are in an airworthy condition, prior to every flight, by determining that the UASs are in compliance with the operating documents (i.e., Monthly Maintenance Log, Blade 350 QX3 and DJI Inspire 1 Instruc tion Manual), and that the aircraft are in a condition for safe flight.
Edwin E. Brochin also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , as the Blade 350 QX3 and DJI Inspire 1 UAs will not have a typical barom etric altimeter onboard. However, altitude informat ion of the Blade 350 QX3 and DJI Inspire 1UAs will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from
the UA to the GCS for active monitoring of the flight path. This altitude information,
combined with Edwin E. Brochin ’s operat ion of the Blade 350 QX3 and DJI Inspire 1 UASs within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to S ection 91.121. Additionally, Edwin E. Brochin seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions

. Edwin E.
Brochin submits that safety will not be affected by operat ion of the Blade 350 Q X3 and DJI Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC) under8 visual flight rules (VFR), with enough battery power to fly for a total duration of approximately 13.5 minutes to the first point of intended landing and, assumi ng normal cruising speed, to fly after that for at least 4.5 minutes. In accordance with 14 C.F.R. § 11.81, Edwin E. Brochin provides the following information in support of its petition for exemption:
A. Name And Address Of The Petitioner.
The name and address of the Petitioner and point of contact is:
Edwin E. Brochin Ultimate Outdoors TV LLC 1275 West 86 th Street Indianapolis, IN 46260 Tel: ( 317 ) 709

- 2235 Email: captained@ultimateoutdoorstv.com B. The Spec ific Sections Of 14 C.F.R. From Which Edwin E. Brochin Seeks Exemption:
1. Edwin E. Brochin Seeks Exemption From The Requirements Of Section 61.113(a) And (b). Section 61.113, entitled Private pilot privileges and limitations: Pilot in command , subsections (a) and (b) prescribe the following, in relevant part: (a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that pers on, for compensation or hire, act as PIC of an aircraft. (b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if

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

2. Edwin E. Brochin Seeks Exemption From The Requirements Of Section 91.7(a).9 Section 91.7, entitled Civil aircraft airworthiness , subsection (a), states the following: (a) No person may operate a civil aircraft unless it is in an airworthy condition.
3. Edwin E. Brochin Exemption From The Requirements Of Section 91.121. Section 91.121, entitled Altimeter settings , subsection (a), states the following, in
part: (a) Ea ch person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

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

-- (i) The current reported altimeter setti ng 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.
4. Edwin E. Brochin Seeks Exemption From The Requirements Of Section 91.151(b). Section 91.151, entitled Fuel requirements for flight in VFR conditions , subsection (b), states the following: (b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.
5. Edwin E. Brochin 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

—10 (a) Shall have that aircraft in spected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.]
6. Edwin E. Brochin Seeks Exemption From T he Requirements Of Section 91.407(a)(1) Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration , subsection (a)(1), states the following: (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

-- (1) It has been approved for return to service by a person authorized under § 43.7 of this chapter [.]
7. Edwin E. Brochin S eeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2). Section 91.409, entitled Inspections , subsection (a), states the following: (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

-- (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by § 43.7 of this chapter; or (2) An inspection for the issuanc e of an airworthiness certificate in accordance with part 21 of this chapter.
8. Edwin E. B rochin Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b). Section 91.417, entitled Maintenance records , subsections (a) and (b), state the following: (a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Reco rds of the maintenance, preventive maintenance, and alteration and records of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and11 each engine, propeller, rotor, and a ppliance of an aircraft. The records must include

-- (i) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of completion of the work performed; and (iii) The signature, and certificate number of the person approving the aircraft for return to service. (2) Records containing the following information: (i) The total time in service of the airframe, each engine, each propeller, and each rotor. (ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms pre scribed by § 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed: (1) The records s pecified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retained and transferre d with the aircraft at the time the aircraft is sold.12 (3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.
C. The Extent Of Relief Edwin E. Brochin Seeks And The Reason Edwin E. Brochin Seeks The Relief.
1. Extent Of Relief Edwin E. Brochin Seeks And The Reason Edwin E. Brochin Seeks Relief From Section 61.113(a) And (b). Relief from Section 61.113(a) and (b) en titled 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 f light

- hour and currency requirements, to conduct the proposed UAS flight operations for compensation or hire. This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, a ct as PIC of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. As set forth more fully below , Edwin E. Brochin submits that an equivalent level of safety will be maintained because no PIC will be allowed to o perate the Blade 350 QX3 UAS or DJI Inspire 1 UAS unless that PIC has met certain flight

- hour and currency requirements, demonstrating that the PIC is able to safely operate either the Blade 350 QX3 or DJI Inspire 1 UAS in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distance s from people, vessels, vehicles and structures.13 Further, Edwin E. Brochin submits that all flig hts of the Blade 350 QX3 and DJI Inspire 1 UASs, conducted by the PIC pursuant to the grant of this Petition: (1) will be
incidental to Edwin E. Brochin ’s busin ess; and (2) will not carry passengers or property for compensation or hire.
2. Extent Of Relief Edwin E. Brochin Seeks And The Reason Edwin E. Brochin Seeks Relief From Section 91.7(a). Relief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to the extent required to allow Edwin E. Brochin to determin e that the Blade 350 QX3 and DJI Inspire 1 UASs are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., the Ed win E. Brochin Aerial Operations Manual, Monthly Maintenanc e Log, and Blade 350 QX3 and DJI Inspire 1 Instruction Manual).
Edwin E. Brochin seeks the requested relief because the Blade 350 QX3 and DJI Inspire 1 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Edwin E. Brochin will ensur e that the Blade 350 QX3 and DJI Inspire 1 UASs are in airworthy condition based upon its compliance with the operating documents (i.e ., Monthly Maintenance Log, and Blade 350 QX3 and DJI Inspire 1 Instruction Manual) prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated in the conditions and limitatio ns below.
3. Extent Of Relief Edwin E. Brochin Seeks And The Reason Edwin E. Brochin Seeks Relief From Section 91.121. Relief from Section 91.121, entitled Altimeter settings , may be required to allow flight operations of the Blade 350 QX3 and DJI Inspir e 1 UASs, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PIC at the ground control station (GCS).14 Since the FAA requires that any altitude inform ation concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), Edwin E. Brochin seeks the requested relief b ecause the Blade 350 QX3 and DJI Inspire 1 UA’s altimeter may be set on the ground to zero feet AGL, rat her 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 will
be maintained since the Blade 350 QX3 and DJI Inspire 1 UAs are equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the PIC with
altitude information of the UA on the heads

- up display of the GCS.
4. Extent Of Relief Edwin E. Brochin Seeks And The Reason Edwin E. Brochin 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 e xtent required to allow flights of the batte ry powered Blade 350 QX3 and DJI Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least
4.5 minutes. Edwin E. Brochin seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the batte ry powered Blade 350 QX3
and DJI Inspire 1 UAs will severely constrain the practicality of any aerial video or still photo flight operations that Edwin E. Brochin proposes to conduct pursuant to this Petition.15 Significantly, as set forth below, the technical specificati ons of the Blade 350 QX3 and DJI Inspire 1 UASs, the Blade 350 QX3 and DJI Inspire 1 operating documents, and
Edwin E. Brochin ’s proposed operating limitations, ensure that Edwin E. Brochin will safely operate the batte ry powered Blade 350 QX3 and DJI Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that f or at least 4.5
minutes.
5. Extent Of Relief Edwin E. Brochin Seeks And The Reason Edwin E. Brochin 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, Edwin E. Brochin requests relief
from these Sections b ecause the Blade 350 QX3 and DJI Inspire 1 UASs do not require airworthiness certificates. As set forth more fully below, the Blade 350 QX3 and DJI Inspire 1 UASs meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, Edwin E. Brochin will use trained technicians to perform maintenance, alterations, or preventive mainte nance on the UASs using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the
Edwin E. Brochin Aerial Operations Manual, Monthly Maintenanc e Log, and Blade 350 QX3 and DJI Inspire 1 Instruction Manual). Furthermore, Ed win E. Brochin will document
and maintain all m aintenance records for the Blade 350 QX3 and DJI Inspire 1 UASs. D. The Reasons Why Granting Edwin E Brochin ’s Request Would Be In The Public Interest; That Is, How It Would Benefit The Public As A Whole.16 G ranting the present Petition will further the public interest by allowing Edwin E.
Brochin to safely, efficiently, and economically perform aerial video and photography of
of real estate , film sets, and landscape over certain areas of the United States.
Ad di tionally, use of the Blade 350 QX3 and DJI Inspire 1 UASs will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of Edwin E. Brochin ’s proposed operat ion of the Blade 350 QX3 and
DJI Inspire 1 UASs will be realized without implicating any privacy issues. 1. The Public Will Benefit From Decreased Congestion Of The NAS. The Blade 350 Qx3 and DJI Inspire 1 UAs are battery powered and serve as a safe, efficient, and economical alternativ e 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 th e use of a Blade 350 QX3 or DJI Inspire 1 UAS
would reduce the amount of mann ed aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground. Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be re duced. The Blade 350 QX3 and DJI Inspire 1 UAs do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography
missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations. 2. The Public Will Benefit From The Safety And Efficiency Of The Blade 350 Qx3 and DJI Inspire 1 UASs. Conducting aerial acquisition s with the Blade 350 QX3 and DJI Inspire 1 UASs, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels17 of air and noise pollution generated during traditional aerial video and still photography flight ope rations. By using battery power and electric m otors, the Blade 350 Qx3 and DJI Inspire 1 UASs produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that a re typically utilized for aerial video and photography, while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The Blade 350 QX3 and DJI Inspire 1 UAs, while reducing the carbon footprint of aerial acquisitions, also eliminates noise p ollution, as the UAs are propelled by battery powered electric motors, rather than an internal combustion engine. By using the Blade 350 QX3 and DJI Inspire 1 UASs to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located
onboard the air craft, the Blade 350 QX3 and DJI Inspire 1 UAs (weighing approximately 2

pou nds and 6 pounds 7.5 ounces respectively, at their maximum gross weights with lengths
of 18 inches and 17.3 i nches respectively, widths of 18 inches and 17.7 inches respectively, and with no fuel on board), has less physi cal 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 Operation s With The Blade 350 QX3 and DJI Inspire 1 UASs Will Benefit The Economy. In addition to being safe and efficient, the Blade 350 QX3 and DJI Inspire 1 UASs are also an economical alternative to using manned aircraft to conduct similar aerial18 operations. As such, operation of the Blade 350 QX3 and DJI Inspire 1 UASs will allow United States based companies, like Edwin E. Brochin’s Ultimate Outdoors TV
Pro ductions , 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 Blade 350 QX3 and DJI Inspire 1 UASs is one such technology that not only allows companies greater operational flexibility compared to
manned aircraft, but provides such flexibility without the high operational cost of a
traditional manned aircraft. By operating the Blade 350 QX3 and DJI Inspire 1 UASs, companies such as
Edwin E. Brochin’s Ultimate Outdoors TV Productions , can remain competitiv e 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 Blade 350 QX3 and D JI Inspire 1 UASs, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the United States and abroad

. 4. There Are No Privacy Issues. Similar to the manned aerial acquisition flight operations that have been conducted for decades, Edwin E. Brochin ’s proposed operation of the Blade 350 QX3 and DJI Inspire 1 UASs will not implicate any privacy issues. Sp ecifically, the Blade 350 QX3 and DJI Inspire 1 UASs will be operated only in compliance with operating documents (i.e., the19 Blade 350 QX3 Aerial Operations Manual, Monthly Maintenanc e Log, and Blade 350 QX3 and DJI Inspire 1 Instruction Manual) which requ ires property owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119. E. The Reasons 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 Edwin E. Brochin Seeks Exemption. 1. Reasons Why The Blade 350 QX3 and DJI Inspire 1 UAs Meet The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333. In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, Edwin E. Brochin ’s operation of the Blade 350 QX3 and DJI Inspire 1 UASs meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Section 333 provides authority for a UAS to operate without airworthiness

cert ification and sets forth requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part: (a) In General.

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

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

-- (1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security; and20 (2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United St ates Code, is required for the operation of unmanned aircraft systems identified under paragraph (1). (c) Requirements for Safe Operation.

-- If the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the
na tional airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system. In seeking this exemption, Edwin E. Brochin submits that the Blade 350 QX3 and DJI Inspire 1 UASs can oper ate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the Blade 350 QX3 and DJI Inspire 1 UASs; (b) the pilot certification requirement; and (c) the specific operating limitations. a. The Specifications Of The Blade 350 QX3 and DJI Inspire 1 UASs Demonstrate Its Safe Characteristics.
The Blade 350 QX3 and DJI Inspire 1 UASs do not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its size, weight, spe ed, and operational capability. i. Technical Specifications Of The Blade 350 QX3 and DJI Inspire 1

UASs. The technical specifications of the Blade 350 QX3 and DJI Inspire 1 UASs are set forth by the Blade 350 QX3 and DJI Inspire 1 Specifications and Data Sheet, attached
hereto as Exhibit A and B.
ii. The Blade 350 QX3 and DJI Inspire 1 UASs Autonomous Flight And Navigation Modes Enable The UASs To Remain Within A Defined Operational Area. The Blade 350 QX3 and DJI Inspire 1 UASs may be operated in both manual and fully autonomous flight modes. A complete description of the flight and navigational
modes of the Blade 350 QX3 and DJ I Inspire 1 UASs is provided with the users manual21 for the Blade 350 QX3 and pages 1 2

- 16 and 45

- 50 of the DJI Inspire 1 User Manuals , attached hereto as Exhibit C and D.
iii. The Blade 350 QX3 and DJI Inspire 1 UASs Are Designed For Automatic Return To Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation. When the Control Link is lost, the Blade 350 QX3 and DJI Inspire 1 UAs will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the Blade 350 QX3 and DJI Inspire 1 UAs do not reacquire control link data from the GCS, the UAs will

assu me that the Control Link is lost and the UAs will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown. A complete description of the Failsafe Functions of the Blade 350 QX3 UAS are
set forth in its users manual and throug h pages 15 of 17 and DJI Inspire 1 User Manuals,
attached hereto as Exhibit C and D. iv. The Blade 350 QX3 and DJI Inspire 1 GCS And Its Operation. A complete description of the operation and specificatio ns of the Blade 350 QX3 and DJI Inspire 1 GCS and flight control software is provided in the Blade 350 QX3 User Manual and pages 40 through 47 of the DJ I Inspire 1 User Manual. Blade 350 QX3 and DJI Inspire 1 User Manuals are attached hereto as Exhibits C and D. b. Flight Operations Of Blade 350 QX3 and DJI Inspire 1 UASs Are Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer.
Edwin E. Brochin will only utilize certificated pilots who possess a current and
valid airman medical certificate to act as a pilot in com mand (PIC) of the Blade 350 QX3
and D JI Inspire 1 UASs. Additionally, a safety observer will assist all pilots during flight
time.22 c. Flights Of the Blade 350 QX3 and DJI Inspire 1 UASs Will Be Conducted Pursua nt To Specific Operating Limitations. In seeking this exemption, Edwin E. Brochin proposes to commercial ly operate the Blade 350 QX3 and DJI Inspire 1 UASs for the special purpose of conducting aerial video and photography over certain areas of United St ates, pursuant to the following specific operating limitations: 1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross w eight: Blade 350 QX3 and DJI Inspire 1 Unmanned Aircraft Systems. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant. 2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photography. 3. The UAs may not be flown at an indicated airspeed exceeding 20 knots. 4. The UA must be operated at an altitude of no mo re 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 UAs must be operated within vis ual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate. 6. The use of first person view (F PV) by the PIC or safety observer (SO) is not permitted. 7. All operations must utilize a safety observer (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 communi cate 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 that the SO c an 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.23 9. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in it s 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 update d 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 amendm ent to its grant of exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operating documents. 10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condit ion for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. T he Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records. 11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraft records. 12. The pre

- flight inspection must account for all poten tial discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents. 13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. 14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accorda nce 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 au thorized person returning the UAS to service. 15. Each UASs operated under this exemption must comply with all manufacturer Safety Bulletins. 16. The authorized person must make an entry in the aircraft record of the corrective action taken against dis crepancies discovered between inspections.24 17. The PIC must possess at least a private pilot certificate and at least a current third

- class medical certificate. 18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qua lification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator’s PICs are permitted under the terms of the exemption. However, training operations m ay only be conducted during dedicated training sessions. During training, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distanc e from nonparticipants in accordance with 14 C.F.R. § 91.119. 19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is requir ed, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized. 20. The UA may not operate within 5 nautical miles of an airport reference point as denoted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport man agement must be made available to the Administrator upon request. 21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.
22. If the UA lose s communications or loses its GPS signal, it must return to a pre

determined location within the planned operating area and land or be recovered in accordance with the operating documents. 23. The PIC must abort the flight in the event of unpredicted ob stacles or emergencies in accordance with the operating documents. 24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing p oint and land the UA with 25% battery power remaining.25 25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (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 clas s 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) mar kings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable. 27. Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made available to the Administrator or any law enforcement official upon request.
29. The U A must remain clear and yield the right of way to all manned aviation operations and activities at all times. 30. The UAS may not be operated by the PIC from any moving device or vehicle. 31. Flight operations must be conducted at least 500 feet from al l 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 deb ris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of the risk of operating closer to th ose objects and determined that it does not present an undue hazard, and; c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a).26 32. All operations shall be conducted over private or controlled

- access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted. 33. Any incident , accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents must be reported to the N ational Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

. 2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety.
Edwin E. Brochin submits that the equivalent level of safety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the Blade 350 QX3 and DJI Inspire 1 UASs unless that PIC has demonstrated, by meeti ng minimum flight

- hour and currency requirements, that the PIC is able to safely operate the Blade 350 QX3 or DJI Inspire 1 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels,
vehicles and structures. Considering Edwin E. Brochin ’s proposed area of operations, and the operating
limitations set forth

- above; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requ irements ( See Exemption No. 11062); and the airmanship skills necessary to safel y operate the Blade 350 QX3 or DJI Inspire 1 UAS,
Edwin E. Brochin submits that the additional manned airmanship experience of a commercially certificated pilot would not corre late to the airmanship skills necessary for
Edwin E. Brochin ’s specific proposed flight operations. The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presente d herein (e.g.27 Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).
Edwin E. Brochin will not allow any PIC to o perate the Blade 350 QX3 or DJI Inspire 1 UAS u nless that PIC has demonstrated, by meeting minimum flight

- hour requirements or the Blade 350 QX3 or DJI Inspire 1 UAS training and currency requirements, that the PIC is able to safely operate the Blade 350 QX3 or DJI Inspire 1 UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and

structures. Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In addition to the hour requiremen ts, 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 compliance with applicable regulations will ensure an equivalent level of safety during Edwin E. Brochin ’s 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:

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

- rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot28 operating the same make and mo del of UAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi

- rotor time and th e 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight

- hou r requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the petitioner’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in complian ce 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 time. During training, proficiency, and experience

- bu ilding flights the PIC is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15. Accordingly, Edwin E. Brochin will ensure safe operations by not allowing any
PIC to o perate the Blade 35 0 QX3 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

o perate the Blade 350 QX3 or DJI Inspire 1 UAS in a manner consistent with the exemption, including evasiv e 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 establi shed by Section 91.7(a) will be maintained because prior to every flight, Edwin E. Brochin will ensur e that the Blade 350 QX3 or DJI Inspire 1 UAS is in an airworthy condition based upon the UAS’s compliance with its operating documents and as stated in th e conditions and limitations herein. Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g.29 Exemption Nos. 11062, 11063, 11064, 11065, 1 1066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety. The equivalent level of safety established by Section 91.121 will be maintained
because the altitude information of the Blade 350 QX3 and DJI Inspire 1 UAs will be provided to the PIC via GPS equipment and a radio communications telemetry data link,
which downlinks from the UA to the GCS for active monitoring of the flight path and altitude. This altitude information, combined with Edwin E. Brochin ’s operation of the Blade 350 QX3 and DJI Inspire 1 UAs within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a
zero altitude initiat ion point is automatically established by the UASs at ground level. The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely Affect Safety. A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the Blade 350 QX3 and DJI Inspire 1 UASs; (2) the limitations on the proposed flight operations; and (3)
the location o f the proposed flight operations. Accordingly, Edwin E. Brochin will ensure that it will safely operate the battery powered Blade 350 QX3 and DJI Inspire 1 UAs during daylight hours in VFR conditions, with enough battery power to fly for a total30 duration o f 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. Here, as in Exemption No. 11109, the technical specifications of the Blade 350 QX3 and DJI Inspire 1 UASs; the limitatio ns 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 Blade 350 QX3 and DJI Inspire 1 UASs provide audible and visual warnings to the PIC at the GCS when the UAs experiences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery power. At the critically low batter y level, the Blade 350 QX3 and DJI Inspire 1 UASs will descend and land automatically. Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics and

op erating limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief
fr om Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 1115 6, 11157, 11158, 11159, 11160, 11161). 6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety. In seeking this exemption, Edwin E. Brochin submi ts that the equivalent level of safety with regard to the regulatory maintenance and alteration requirements established by31 Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met
because Edwin E. Brochin will use trained t echnicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., the Edwin E. Brochin Aerial Operations Manual, Monthly Maintenanc e Log, and Blad e 350 QX3 and DJI Inspire 1 Instruction Manual). Furthermore, Edwin E. Brochin will document and maintain all maintenance

recor ds for the Blade 350 QX3 and DJI Inspire 1 UASs. Since the Blade 350 QX3 and DJI Inspire 1 UASs will be inspected as prescribed by the operating documents, Edwin E. Brochin 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 Blade 350 QX3 and DJI Inspire 1 User Manuals are attached hereto as Exhibit C and D; a c opy of the Blade 350 QX3 and DJI Inspire 1 UAS Maintenance LOG is attached hereto as Exhibit E. Likewise, the exemption sought will not adversely affect safety because Edwin E.
Bro chin 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 l evel of safety established by Sections 91.407, 91.417(a) and 91.417(b), b ecause all maintenance of the Blade 350 QX3 and DJI Inspire 1 UASs will be performed by trained technicians. Maintenance will be documented and maintained utilizing the monthly mainte nance log. Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is32 not adversely affected when the technical characteristics and operating limit ations of the
UAS are considered.
In consideration of Edwin E. Brochin ’s proposed operating limitations, the operating documents, and the technical aspe cts of the Blade 350 QX3 and DJI Inspire 1 UASs, Edwin E. Brochin submits that safety will not be adver sely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted relief specific to UAS in circumstances similar, in all material respects, to those presente d herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 7. The FAA May Prescribe Any Other Conditions For Safe Operation.
In accordance wit h Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions , Edwin E. Brochin requests that the FAA prescribe special conditions for the intended operat ion of the Blade 350 QX3 and DJI Inspire 1 UA Ss, 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 UAs for the limited purpose of conducting aerial video and photography over certain areas of the United States for compensation or hire. FMRA
Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certif ication33 in accordance with any requirements that must be established for the safe operation of the
UAS in the NAS. Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operat ion of the Blade 350 QX3 and DJI Inspi re 1 UASs, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 21.16,
entitled Special Conditions , states the following:
If 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 prop eller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FAA finds n ecessary to establish a level of safety equivalent to that established in the regulations.
See 14 C.F.R. § 21.16. Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for Leading Edge’s intende d operation of the Blade 350 QX3 and DJI Inspire 1 UASs, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).
F. A Summary That Can Be Published In The Federal Register, stating: The Rules From Which Edwin E. Brochin Seeks Exemption:
Edwin E. Brochin seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). A Brief Description Of The Nature Of The Exemption Edwin E. Brochin Seeks:34 This exemption will permit Edwin E. Brochin to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States.
G. Any Additional Information, Views, Or Arguments Available To Support Edwin E. Brochin ’s Request. This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. As such, Edwin E. Brochin ’s request for exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as
set forth above. FMRA Section 333 sets forth the requirements for considering whether a UAS will
create a hazard to users of th e 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, Edwin E. Brochin will o perate the Blade 350 QX3
and DJI In spire 1 UASs safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.
CONCLUSION As set forth herein, Edwin E. Brochin seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operat ion of the Blade 350 QX3 and DJI Inspire 1 UASs commercially, without an airworthiness certificate, for t he 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,35 by allowing Edwin E. Brochin to safely, efficiently, and economically o perate the Blade 350 QX3 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 2012, Section 333, Edwin E. Brochin respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Leading Edge to o perate the Blade 350 QX3 and DJI Inspire 1 UASs commercially for the purpose of conducting aerial video and photography over certain areas of the United States.
Date d: M arch 22 , 2015

Respectfully submitted,
Edwin E. Brochin

_________________________ Edwin E. Brochin Ultimate Outdoors TV LLC 1275 West 86 th St. Indianapolis, IN 46260 Tel: ( 317) 709

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Appendic es :
A

– Blade 350 QX3 Specifications Data Sheet B

– DJI Inspire 1 Specifications Data Sheet C

– Blade 350 QX3 Manufacturer’s User Manual D

– DJI Inspire 1 Manufacturer’s User Manual E

– Monthly Maintenance Log36 APPENDIX

– A Blade 350 QX3 TECHNICAL SPECIFICATIONS
Edwin E. Brochin only utilizes safe and reliable UASs. DJI and Blade are industry leader s in small UAS production. DJI and Blade U ASs are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit f l ight to a predetermined and set distance. In addition, DJI and Blade software provides real

- time altitude and location information to the PIC via the linked monitor (smart phone/tablet devices) 1.1 Blade 350 QX337 1.1.1 Aircraft 1. 1.1.1 Supported Battery

– 3S 11.1V 30 00mAH LiPo Battery 1.1.1.2 Weight (Battery & Prop ellers Included)

– 2lbs ( 90 7.18 g) 1.1.1.3 Hover Accuracy (Ready to Fly)

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

- 200 0 /s 1.1.1.5 Max Tilt Angel

- 35 0 1.1.1.6 Max Asc ent Speed

– 6m/s 1.1.1.7 Max Descent Speed

– 2m/s 1.1.1.8 Max Flight Speed

– 15m/s (NOT RECOMMENDED)
1.1.2 Gimbal 1.1.2.1 Working Current

– 12V 1.1.2.2 Control Accuracy

- ±0.03 0 1.1.2.3 Controllable Range

– Pitch:

- 90 0

- 0 0 1.1.2.4 Maximum Angular Speed

– Pitch: 90 0 /s
1.1.3 Camera 1.1.3.1 Operating Temperature Range

- 32 0 F

- 104 0 F (0 0 C

- 5 0 0 C) 1.1.3.2 Sensor Size

– 16M 1.1.3.3 Effective Pixels

– 16 M illion 1.1.3.4 Resolution

– 4384x3288 4.1.3.5 HD Video Recording

– 1080p30 & 720p 4.1.3.6 Recording Field of View

- 110 0 /85 0
1.1.4 Transmitter 1.1.4.1 Operating Frequency

– 5.728GHz

– 5.85GHz 1.1.4.2 Communication Distance (unobstructed)

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

- - 93dBm 1.1.4.4 Transmitter Power

– FCC Compliance: 100mW 1.1. 4.5 Working Voltage

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

– 2412

- 2462MHz 1.1.5.2 Communication Distance (unobstructed)

– 500

- 700m 1.1.5.3 Transmitter Power

– 20dBm 1.1.5.4 Power Consumption

– 2W38 APPENDIX

– B
DJI INSPIRE 1 TECHNICAL SPECIFICATIONS
Edwin E. Brochin only utilizes safe and reliable UASs. DJI and Blade are industry leader s in small UAS production. DJI UASs are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit f l ight to a predetermined and set distance. In addition, DJI software provides real

time altitude and location information to the PIC via the linked monitor (smart phone/tablet devices) 2.2	DJI	Inspire	139 2.2.1	Aircraft 2.2.1.1	Model

– T600 2.2.1.2	Weight	(Battery	Included)

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

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

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

- 350 2.2.1.6	Max	Ascent	Speed

– 5m/s 2.2.1.7	Max	Descent	Speed

– 4m/s 2.2.1.8	Max	Speed

– 22m/s	(ATTI	mode,	no	wind

– NOT	RECOMMENDED) 2.2.1.9	Max	Flight	Alt itude

– 4500m 2.2.1.10	Max	Wind	Resistance

– 10m/s 2.2.1.11	Max	Flight	Time

– Approximately	18	minutes 2.2.1.12	Motor	Model

– DJI	3510 2.2.1.13	Propeller	Model

– DJI	1345 2.2.1.14	Operating	Temperature	Range

– 140F	to	1040F	(

- 100C	to	400C) 2.2.1.15	Dimensi ons – 17	1⁄4”	x	17	3⁄4”	x	12”

2.2.2	Gimbal 2.2.2.1	Model

– ZENMUSE	X3 2.2.2.2	Output	Power	(with	camera)

– Static:	9W;	In	Motion:	11W 2.2.2.3	Operating	Current

– Static:	750mA;	In	Motion:	900mA 2.2.2.4	Angular	Vibration	Range

- ±0.030 2.2.2.5	Mounting

– Detachable 2.2.2.6	Controllable	Range

– Pitch:

- 900	to	+300;	Pan:	±3200 2.2.2.7	Mechanical	Range

– Pitch:

- 1250	to	450;	Pan:	±3300 2.2.2.8	Max	Controllable	Speed

– Pitch:	1200/s;	Pan:	1800/s

2.2.3	Camera 2.2.3.1	Name

– X3 2.2.3.2	Model

– FC350 2.2.3.3	Tot al	Pixels

– 12.76M 2.2.3.4	Effective	Pixels

– 12.4M 2.2.3.5	Image	Max	Size

– 4000x3000 2.2.3.6	ISO	Range

– 100

- 3200 2.2.3.7	Field	of	View

- 940 2.2.3.8	CMOS

– Sony	EXMOR	1/2.3” 2.2.3.9	HD	Video	Recording

– UHD(4K):	4096x2160p24/25, 3840x2160p24/25/30;	FHD: 1920x1080p24/25/30/48/50/60;	HD: 1280x720p24/25/30/48/50/60 2.2.3.10	Operating	Temperature	Range

- 320F

- 1040F	(00C

- 400C)

2.2.4	Transmitter 2.2.4.1	Name

– C140 2.2.4.2	Operating	Frequency

– 5.728

- 5.850GHz;	2.400

- 2.483GHz 2.2.4.3	Communicating	Distance	( unobstructed)

– 2000m 2.2.4.4	Output	Power

– 9W 2.2.4.5	Operating	Temperature	Range

- 140F	to	1040F	(

- 100C	to	400C) 2.2.4.6	Battery

– 600mAh	LiPo	2S41 APPENDIX

– C Blade 350 QX3 Manufacturer’s User Manual42 APPENDIX

– D DJI Inspire 1 Manufacturer’s User Manual

APPENDIX

– E43 month:_________(year:________ UAS$#:$___________ Date(Issue( Discovered Date(Issue( Addressed Software(Updates

Airframe(

Engines

Propellers

Camera(Gimbal

Landing(Gear

Vibration(Dampening

Other: MONTHLY$MAINTENANCE$LOG

Issue(Description(&(Maintenance(Conducted Maintenance(Performed(By:((( Print(&(Sign