September 14, 2015

Exemption No. 12846

Regulatory Docket No. FAA

− 20 15

− 2100

Mr. Michael M. Brouder

Above and Beyond Productions, LLC

13237 Snow Owl Drive

Carmel, IN 46033

Dear Mr. Brouder :

This letter is to inform you that we have granted your request for exemption. It transmits our

decision, explains its basis, and gives you the conditions and limitations of the exemption,

including the date it ends.

By letter dated May 21, 2015 , you petitioned the Federal Aviation Administration (FAA) on

behalf of Above and Beyond Productions, LLC ( hereinafter petitioner or operator ) for an

exemption . The petitioner requested to operate an unmanned ai rcraft system (UAS) to

conduct aerial video and photography of agricultural lands, architecture and construction, real

estate, special events, and la ndscapes

.

See Appendix A for the petition submitted to the FAA des cribing the proposed operations and

the regulations that the petitioner seeks an exemption

.

The FAA has determined that good cause exists for not publishing a summary of the petition

in the Federal Register because the requested exemption would not set a precedent, and any

delay in acting on this petition would be detrimental to the petitioner

.

Airworthiness Certification

The UAS proposed by the petitioner are the DJI Inspire 1 and DJI F550

.

The petitioner requested relief from 14 CFR part 21, C ertification procedures for products

and parts, Subpart H

— Airworthiness Certificates

. In accordance with the statutory criteria

provided in Section 333 of P ublic Law 112

− 95 in reference to 49 U

. S

. C

. § 44704, and in2

consideration of the size, weight, speed, and limited operating area associated with the

aircraft and its operation, the Secretary of Transportation has determined that this aircraft

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from

14 CFR part 21

, C ertification procedures for products and parts, Subpart H

— Airworthiness

Certificates , and any associated noise certification and testing requirements of part 36, is

not necessary.

The Basis for Ou r Decision

You have requested to use a UAS for aerial data collection 1

. The FAA has issued grants of

exemption in circumstances similar in all material respects to those presented in your petition.

In Grants of Exemption No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352),

11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No.

FAA−2014−0642), the FAA found that the enhanced safety achieved us ing an unmanned

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that

—

 They are similar in all material respects to relief previously requested in Grant of

Exemption Nos. 11062, 11109, 11112, and 11213 ;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and

11213 also apply to the situation you present; and

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest.

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701,

delegated to me by the Administrator, Above and Beyond Productions, LLC is granted an

exemption from 14 CFR §§ 61.23(a) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a)

, 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and

91.417(a) and (b), to the extent necessary to allow the petition er to operate a UAS to perform

aerial data collection

. This exemption is subject to the conditions and limitations listed

below.

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA.

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF

analysis, etc.), chemical measurement (part iculate measurement, etc.), or any other gathering of data by

instruments aboard the UA.3

Conditions and Limitations

In this grant of exemption, Above and Beyond Productions, LLC is hereafter referred to as

the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Inspir e 1 and

DJI F550 when weighing less than 55 pounds including payload. Proposed operations

of any other aircraft will require a new petition or a petition to amend this exemption

.

2. Operations for the purpose of closed

- set motion picture and television film ing are

not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The

exemption holder may use either groundspeed or calibrated airspeed to determine

compliance with the 87 knot speed restriction. In no case will the UA be operated at

airspeeds greater than the maximum UA operating airspeed recommended by the

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated 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 or

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used

to satisfy the VLOS requirement as long as the PIC always maint ains VLOS

capability. The VO and PIC must be able to communicate verbally at all times ;

e lectronic messaging or texting is not permitted during flight operations. The PIC

must be designated before the flight and cannot transfer his or her designation fo r the

duration of the flight. The PIC must ensure that the VO can perform the duties

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its

operations in accordance with the conditions and limitations stated in thi s grant of

exemption, are hereinafter referred to as the operating documents. The operating

documents must be accessible during UAS operations and made available to the

Administrator upon request. If a discrepancy exists between the conditions and

limita tions in this exemption and the procedures outlined in the operating documents,4

the conditions and limitations herein take precedence and must be followed.

Otherwise, the operator must follow the procedures as outlined in its operating

documents. The ope rator 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 or any law enforcement official upon request. The

operator must also present up dated and revised documents if it petitions for extension

or amendment to this grant of exemption. If the operator determines that any update

or revision would affect the basis upon which the FAA granted this exemption, then

the operator must petition for an amendment to its grant of exemption. The FA A’s

UAS Integration Office (AFS− 80) may be contacted if questions arise regarding

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS op eration

or flight characteristics, e.g.

, replacement of a flight critical component, must undergo

a functional test flight prior to conducting further operations under this exemption.

Functional test flights may only be conducted by a PIC with a VO and mu st remain at

least 500 feet from other people. The functional test flight must be conducted in such

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it i s

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the

UAS is in a condition for safe flight. The pre

- flight inspection must account for all

potential discrepancies, e.g.

, inoperable comp onents, items, or equipment. 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.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul,

replacement, inspection, and life limit requirements for the aircraft and

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport,

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a

current FAA airman medical certificate or a valid U.S. driver’s license issued by a

state, the District of Col u mbia, Puerto Rico, a territory, a possession, or the Federal

government. The PIC must also meet the flight revi ew requirements specified in

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certifi cate.5

14. The operator may not permit any PIC to operate unless the PIC demonstrates the

ability to safely operate the UAS in a manner consistent with how the UAS will be

operated under this exemption, including evasive and emergency maneuvers and

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC

qualification flight hours and currency must be logged in a manner consistent with

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs

(traini ng, p roficiency, and experience

- building) and determining the PIC’s ability to

safely operate the UAS in a manner consistent with how the UAS will be operated

under this exemption are permitted under the terms of this exemption. However,

training operations ma y only be conducted during dedicated training sessions. During

traini ng, 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 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All

operations must be conducted under visual meteorological conditions (VMC). Flights

under special visual flight r ules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not

denoted with an ARP, the center of the airport symbo l as denoted on the current

FAA

- published aeronautical chart, unless a letter of agreement with that airport’s

management is obtained or otherwise permitted by a COA issued to the exemption

holder. The letter of agreement with the airport management must be mad e available

to the Administrator or any law enforcement official upon request.

17. 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.

18. If the UAS loses communications or loses its GPS sign al, the UA must return to a

pre

- determined location within the pr ivate or controlled

- access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast

weather conditions) there is enough available power for the UA to conduct the

intended operation and to operate after that for at least five minutes or with the reserve

power recommended by the manu facturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All

operations shall be cond ucted in accordance with an ATO

- issued COA. The

exemption holder may apply for a new or amended COA if it intends to conduct

op erations that cannot be conducted under the terms of the attached COA

.6

22. All aircraft operated in accordance with this exemption must be identified by serial

number, registered in accordance with 14 CFR part 47, and have identification

(N− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the

PIC at the Ground Control Station of the UAS any time the aircraft is operating.

These documents must be made available to the Administrator or any law enforcement

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and

activities at all times.

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

26. All Flight operations must be conducted at least 500 feet from all nonpartici pating

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 r emain 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 in a manner ensuring the safety

of nonparticipating persons ; and

b. The owner/ controller of any vessels, vehicles or structures has granted permission

for operating closer to those objects 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 hazard

.

The PIC, VO, operator trainees or essential persons are not considered

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or control led

- access property with

permission from the property owner/controller or aut horized representative.

Permission from property owner/controller or authorized representative will be

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical

boundaries of the opera tional area as defined by the applicable COA must be reported

to the FA A's UAS Integration Office (AFS− 80) within 24 hours. Accidents must be

reported to the National Transportation Safety Board (NTSB) per instructions

contained on the NTSB Web site: www.ntsb.gov

.7

If this exemption permits operations for the purpose of closed

- set motion picture and

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM)

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this

exemption must submit a written Plan of Activities to the local Flight Standards

District Office (FSDO) with jurisdiction over the a rea of proposed filming. The 3

- day

notification may be waived with the concurrence of the FSDO. The plan of activities

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted

under this grant of exemption;

c. Name and phone number of th e person responsible for the on

- scene operation of

the UAS;

d. Make, model, and serial or N− Number of UAS to be used;

e. Name and cer tificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners

and/or local officials to conduct the filming production event; the list of those

who gave permission must be made availa ble to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city,

town, county, and/or state over which filming will be conducted and the altitudes

es sential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons

consenting to be involved and necessary for the filming production, as specified in the

exemption holder’s MPTOM.

Unless otherwise spe cified in this grant of exemption, the UAS, the UAS PIC, and the UAS

operations must comply with all applicable parts of 14 CFR including, but not limited to,

parts 45, 47, 61, and 91.8

This exemption terminates on September 30, 2017 , unless sooner super seded or rescinded.

Sincerely,

/ s/

John S. Duncan

Director, Flight Standards Service

EnclosuresUNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

ABOVE AND BEYOND PRODUCTIONS, LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTION 21, SUBPART H; §45.23(b), 61.113(a) and (b), 91.7(a), 91.9(b)(2),

91.103 (b), 91.109, 91.119, 91.121, 91.151(b), 91.203 (a) & (b), 91.405(a), 91.407(a)(1),

91.409(a)(2), and 91.417(a) & (b),

CONCERNING COMMERCIAL OPERATION OF DJI INSPIRE 1 & DJI F550

UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112

- 95)

Submitted

, May 21

, 2015

Michael M. Brouder

Above and Beyond Productions, LLC

13237 Snow Owl Drive

Carmel, IN 46033

Tel: (317) 220

- 0354

michaelbrouder@mac.com2 TABLE OF CONTENTS

GLOSSARY OF ABBREVIATIONS 3

OVERVIEW 4

INTRODUCTION AND INTERESTS OF PETITIONER 4

BACKGROUND 4

BASIS FOR PETITION 5

NAME AND ADDRESS OF PETITIONER 6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH ABOVE AND BEYOND

PRODUCTIONS LLC SEEKS EXEMPTION 6

THE EXTENT OF RELIEF ABOVE AND BEYOND PRODUCTIONS LLC SEEKS AND

THE REASON ABOVE AND BEYOND PRODUCTIONS LLC SEEKS THE R E L I E F

7

THE REASONS WHY GRANTING ABOVE AND BEYOND PRODUCTIONS LLC’S

REQUEST WOULD BE IN THE PUBLIC INTEREST 1 0

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY

AFFECT SAFETY 1 2

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER. 18

CONCLUSION 18

EXHIBITS 203

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of A uthorizati on

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

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 OVERVIEW

Above and Beyond Productions, LLC seeks exemption from the requirements of 14 C.F.R

. 21, subpart H; § 45.23(b) , 61. 11 3(a) and (b)

, 91.7(a), 91.9(b)(2), 91.103 (b), 91.109,

91.119, 91.121, 91.151(b), 91.203 (a) & (b), 91.405(a), 91.407(a)(1), 91.409(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 Above

and Beyond Productions LLC to operate an Unmanned Aircraft System (UAS) for the

commercial purpose of conducting aerial video and photography of agricultural lands,

architecture and construction

, real estate, special events, and landscapes within the United

States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Above and Beyond Productions LLC will provide its clients with the high quality digital

video content for use in their commercial, personal, and non

- profit multimedia projects.

Above and Beyond Productions LLC bring s over 25 years of broadcast television production,

direction, editing and professional marketing expertise, along with state

- of

- the

- art technology to

make studio quality productions within reach for organizations of any size.

Above and Beyond Productions LLC has over 2 years recreational/hobby experience in all

aspects of aerial video and photography and is an active member in good standing with the

Academy of Model Aeronautics (AMA)

. Additionally, Above and Beyond Productions LLC

benefits from graduate

- level coursework at Ball State University relating to the current

regulatory, privacy and safety issues relating to commercial and private UAV use in the United

States. The objective of Above and Beyond Productions LLC ’s aerial video and

photogr aphy operations is to provide high quality imaging for a variety of commercial,

public, and residential uses, specifically targeting:

• Promotional corporate videos for businesses, non

- profits & local government

entities

• Edited videos to supplement commercial and residential real estate listings

• Aerial event filming and photography to promote travel and tourism

• Agricultural surveys and environmental monitoring

BACKGROUND

Unmanned Aircraft Systems: DJI Inspire 1 & DJI F550 Flamewheel UAS

Above and Beyond Productions LLC seeks an exemption to operate multiple DJI S ystems

UAVs for compensation or hire within the NAS. The DJI Inspire 1 (Inspire ) is a vertical

takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station

(GCS) utilizing electronic tablet or smart phone systems. The Inspire is an electric powered5

rotary wing UAS that is capable of transmitting live airborne video images and location

information to a Ground Control Station (GCS). The Inspire stores the photographs and

data on board and makes them available for download after completion of the flight. The

Inspire 1 is 22 in x 22 in x 8 in and weighs 6.4 pounds, well under the 55 lbs. mandated in

the FMRA. The Inspire can conduct hovering flight and has a maximum cruising speed of

42 knots. It is battery powered, has a flight endurance of no more than 22 minutes and can

operate in temperatures ranging from 0° to 40° C. The Inspire’s omni

- directional antenna

has a range of 2.1 km and operates in the 2.420

– 2.483 GHz frequency range.

The DJI F550 Flamewheel is a 6

- propeller multirotor vertical takeoff and landing (VTOL)

Unmanned Aircraft (UA) capable of transmitting live airborne video images and telemetry

information to a Ground C ontrol Station (GCS) and utilizes NAZA

- M V2 Flight Controller

for GPS navigation

. The F550’s total weight with maximum allowable payload is 6.5lbs

and measures 21.65” wide and 10.5” tall with landing gear. The F550 maximum airspeed is

30kts. The F550 is c ontrolled by a Futaba T8FG 14

- Channel Radio Control System

operating at 2.4 GHz.

BASIS FOR P ETITION

Petitioner, Above and Beyond Productions LLC, pursuant to the provisions of the Federal

Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of

2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems

, hereby

petitions the Administrator to commercially operate the DJI Inspire 1 in the National

Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R.

§45.23(b), 61.113(a) and (b), 91.9(b)(2), 91.103 (b), 91.109, 91.119, and 91.203 (a) & (b)

.

In consideration of the speed, weight, size, and limited operating area associated with the

unmanned aircraft and their operation, Above and Beyond Productions ’ operation of the DJI

Inspire 1 and DJI F550 Flamewheel UAS s meets the conditions of FMRA Section 333 and

therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21,

Subpart H.

Accordingly, Above and Beyond Productions LLC 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.

Above and Beyond Productions LLC submits that the requested relief is proper since an

equivalent level of safety will be ensured. Above and Beyond Productions LLC will use

experienced personnel or technicians to perform maintenance, alterations, or preventive

maintenance on the UASs using the methods, techniques, and practices prescribed in the

operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 Instruction and

Maintenance Manual s ). Furthermore, Above and Beyond Productions LLC will document

and maintain all maintenance records for the DJI Inspire 1 UAS.

Above and Beyond Productions LLC seeks relief from Section 91.7(a), entitled Civil

aircraft airworthiness

, because the DJI Inspire 1 UAS do not require an airworthiness6

certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Above and Beyond

Productions LLC submits that it will ensure that the DJI Inspire 1 and DJI F550 Flamewheel

UAS are in an airworthy condition, prior to every flight by determining that the UASs are

in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI

Inspire 1 /F550 Instruction Manual s ), and that the aircraft are in a condition for safe flight.

Above and Beyond Productions LLC also seeks an exemption from the requirements of

Section 91.121, entitled Altimeter Settings

, as the DJI Inspire 1 and DJI F550 UA will not

have a typical barometric altimeter onboard. However, altitude information of the DJI

Inspire 1 and DJI F550 UA 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 Above and Beyond Productions LLC’s operation of the DJI Inspire 1 and DJI F550

UAS within visual line of sight, at or below 4 00 feet AGL, will ensure a level of safety

equivalent to Section 91.121.

Additionally, Above and Beyond Productions LLC seeks an exemption from the

requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions

. Above and Beyond Productions LLC submits that safety will not be affected by operation of

the DJI Inspire 1 and DJI F550 UA during daylight hours in visual meteorological

conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a

total duration of approximately 13.5 minutes to the first point of intended landing and,

assuming normal cruising speed, to fly after that for at least 4.5 minutes.

In accordance with 14 C.F.R. § 11.81, Above and Beyond Productions provides the

following information in support of its petition for exemption:



## A. Name a nd Address o f t he Petitioner

The name and address of the Petitioner and point of contact is:

Michael M. Brouder

Above and Beyond Productions, LLC

13237 Snow Owl Drive

Carmel, IN 46033

Tel: (317) 220

- 0354

michaelbrouder@mac.com



## B. The Specific Sections o f 14 C.F.R. From Which Above and

Beyond Productions LLC Seeks Exemption

1. Above and Beyond Productions LLC seeks exemption from the requirements

of Section 21 Subpart H and 14 C.F.R. 91: Airworthiness7

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for

procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1).

The size, weight and enclosed operational area of Above and Beyond LLC’s UASs

permit exemption from Part 21 because Above and Beyond LLC’s UASs meet an

equivalent level of safety pursuant to Section 333 of t he Reform Act. The FAA is

authorized to exempt aircraft from the airworthiness certificate requirement under both

the Act (49 U.S.C. § 44701(f)) and Section 333 of the Reform Act. Both pieces of

legislation permit the FAA to exempt UASs from the airworthin ess certificate

requirement in consideration of the weight, size, speed, maneuverability and proximity

to areas such as airports and dense populations. Above and Beyond LLC’s UASs meet

or exceed each of the elements.

14 C.F.R. §91.9(b)(2) requires an airc raft flight manual in the aircraft. As there are no

pilots or passengers, and given the size of the UASs, this Regulation is inapplicable. An

equivalent level of safety will be achieved by maintaining a manual at the flight

operations center. The FAA has p reviously issued exemptions to this regulation in

Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602,

10700 and 32827.

14 C.F.R. §91.121 regarding altimeter settings is inapplicable insofar as Above and

Beyond LLC’s UASs utili ze electronic global positioning systems and internal

gyroscopes to provide spatial coordination.

14 C.F.R. §§91.203(a) and (b) provide for the carrying of civil aircraft certifications

and registrations. Similar to, 14 CFR 91.9 (b) (2), given the size a nd configuration, the

UAS has no ability to carry certificate and registration documents on the aircraft. There

is no room, capacity, or pilot on board to adequately such documents. An equivalent

level of safety will be achieved by keeping these documents, to the extent they are

applicable to the UAS, at the ground control point where pilot has immediate access to

them.



## C. Extent of Relief of t he Specific Sections Of 14 C.F.R. and

Reason From Which Above and Beyond Productions LLC Seeks

Relief

1. Extent Of Relief Above and Beyond Productions LLC Seeks And The Reason

Above and Beyond Productions LLC Seeks Relief From 14 C.F.R. 45.23: Marking of

the Aircraft

.

Applicable FARs require aircraft to be marked according to certain specifications.

Above and Beyond LLC’s UASs are, by definition, unmanned. They therefore do not

have a cabin, cockpit or pilot station on which to mark certain words or phrases.

Further, two

- inch lettering is dif ficult to place on such small aircraft. Regardless,

Above and Beyond LLC will mark its UASs in the largest possible lettering by placing

the word "EXPERIMENTAL" on its fuselage as required by 14 C.F.R. §45.29(f) so

that the pilot, camera operator, spotter and others working with the UAS will see the8

markings. The FAA has previously issued exemptions to this regulation through

Exemptions Nos. 8738, 10167, 10167A and 10700.

2. Extent Of Relief Above and Beyond Productions LLC Seeks And The Reason

Above and Beyond Productions LLC Seeks Relief From Section 61.113(a) and (b) :

Private pilot privileges and limitations: Pilot in command

.

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations:

Pilot in command

, is requested to the extent necessary to allow a PIC holding a private

pilot or higher level certificate, as well as a current and valid airman medical certificate,

and who has met certain flight

- hour and currency requirements, to conduct the proposed

UAS flight operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state

that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection

with any business or employment if: (1) The flight is only incidental to that business or

employment; and (2) The aircraft does not carry passengers or property for

compensation or hire.

As set forth more fully below, Above and Beyond Productions LLC submits that an

equivalent level of safety will be maintained because no PIC will be allowed to operate

the DJI Inspire 1 UAS UA unless that PIC has met certain flight

- hour and currency

requirements, demonstrating that the PIC is able to safely operate either the DJI Inspire

and DJI F550 Flamewheel UAS in a manner consistent with the operations

specifications as described in this exemption, including evasive and emergency

maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles

and structures.

Further, Above and Beyond Productions LLC submits that all flights of the DJI Inspire

and DJI F550 Flamewheel UAS, conducted by the PIC pursuant to the grant of this

Petition: (1) will be incidental to Above and Beyond Productions LLC business; and (2)

will not carry passengers or property for compensation or hire.

3. Extent Of Relief Above and Beyond Productions LLC Seeks And The Above

and Beyond Productions LLC 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 Above and Beyond Productions LLC to determine that the DJI

Inspire and DJI F550 Flamewheel UAS s are in airworthy condition prior to every flight

by ensuring that the UAS is in compliance with the operating documents (i.e., the DJI

Inspire and DJI F550 Flamewheel Maintenance Manual, Monthly Maintenance Log, and

DJI Inspire and DJI F550 Flamewheel Instruction Manual).

Above and Beyond Productions LLC seeks the requested relief because the DJI Inspire

and DJI F550 Flamewheel UAS s do not require an airworthiness certificate in

accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Above and Beyond9

Productions LLC will ensure that the DJI Inspire and DJI F550 Flamewheel UAS s are in

airworthy condition based upon its compliance with the operating documents (i.e.,

Monthly Maintenance Log, and DJI Inspire and DJI F550 Flamewheel Instruction

Manual) prior to every flight, and further, determine that the aircraft are in condition for

safe flight, as stated in the conditions and limitations below.

4. Extent Of Relief Above and Beyond Productions LLC Seeks And The Above

and Beyond Productions LLC Seeks Relief From Section 91.103: Preflight Action

.

This regulation requires each pilot in command to take certain actions before flight t o

insure the safety of flight. As FAA approved rotorcraft flight manuals will not be

provided for the aircraft

, an exemption will be needed. An equivalent level of safety

will be provided as set forth in the DJI Inspire and DJI F550 Flamewheel Instruction

Manual. Additionally, t he PIC will take all actions including reviewing weather, flight

battery requirements, landing and takeoff distances and aircraft performance data

before initiation of flight.

5. Extent Of Relief Above and Beyond Productions LLC Seeks And The Above

and Beyond Productions LLC Seeks Relief From Section 91.119: Minimum Safe

Altitudes

.

14 C.F.R. §91.119 prescribes safe altitudes for the operation of civil aircraft. It allows

helicopters to be operated at lower altitudes in certain conditio ns. Above and Beyond

LLCs UASs will not operate at an altitude greater than 400 feet above ground level.

Given the size, weight, maneuverability and speed of Above and Beyond LLC’s UASs,

an equivalent level of safety will be achieved.

6. Extent Of Relief Above and Beyond Productions LLC Seeks And The Above

and Beyond Productions LLC 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 DJI Inspire and

DJI F550 Flamewheel 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.

Above and Beyond Productions LLC seeks the requested relief because without an

exemption from Section 91.151(b), the flight time duration of the battery powered DJI

Inspire and DJI F550 Flamewheel UA will severely constrain the practicality of any

aerial video or still photo flight operations that Above and Beyond Productions

proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the DJI Inspire and DJI

F550 Flamewheel UAS, the DJI Inspire and DJI F550 Flamewheel operating

documents, and Above and Beyond Productions LLC’s proposed operating limitations,

ensure that Above and Beyond Productions LLC will safely operate the battery

powered DJI Inspire and DJI F550 Flamewheel UAs during daylight hours in visual10

meteorological conditions (VMC), under visual flight rules (VFR), with enough battery

power to fly for a total duration of 13.5 minutes to the first point of intended landing

and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

7. Extent Of Relief Above and Beyond Productions LLC Seeks And The Above

and Beyond Productions LLC Relief From Sections 14 C.F.R. §§91.405 (a);

407(a)(1); 409(a)(2); 417(a) and (b): Maintenance Inspections

.

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, Above and Beyond Productions LLC

requests relief from these Sections because the DJI Inspire and DJI F550 Flamewheel

UAS s does not require airworthiness certificates. As set forth more fully below, the DJI

Inspire and DJI F550 Flamewheel UAS s meet the conditions of FMRA Section 333 for

operation without an airworthiness certificate. Accordingly, Above and Beyond

Productions LLC will use trained technicians to perform maintenance, alterations, or

preventive maintenance on the UASs using the methods, techniques, and practices

prescribed in the UAS operating documents (i.e., the DJI Insp ire and DJI F550

Flamewheel Maintenance Manual, Monthly Maintenance Log, and DJI Inspire and DJI

F550 Flamewheel Instruction Manual). Furthermore, Above and Beyond Productions

will document and maintain all maintenance records for the DJI Inspire and DJI F550

Flamewheel UAS.



## D. The Reasons Why Granting Above and Beyond

Productions LLC 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 Above and Beyond

Productions LLC to safely, efficiently, and economically conduct aerial video and

photography of agricultural lands, architecture and construction

, real estate, special events, and

landscapes within the United States.

Additionally, use of the DJI Inspire and DJI F550 Flamewheel UAS will decrease

congestion of the NAS, reduce pollution, and provide significant benefits to the economy.

Notably, the benefits of Above and Beyond Productions LLC’s proposed operation of the

DJI Inspire and DJI F550 Flamewheel UAS s will be realized without implicating any

privacy issues.

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

The DJI Inspire and DJI F550 Flamewheel UAS s are battery powered and serve as a

safe, efficient, and economical alternative to the manned aircraft traditionally utilized to

obtain aerial imagery. By reducing the amount of manned aircraft needed to perform

aerial acquisitions, an exemption allowing the use of a DJI Inspire and DJI F550

Flamewheel UAS s would reduce the amount of manned aircraft in the NAS, reduce

noise and air pollution, as well as increase the safety of life and property in the air and11

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 Inspire and DJI F550 Flamewheel UAS s 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 Inspire

and DJI F550 Flamewheel UAS.

Conducting aerial acquisitions with the DJI Inspire and DJI F550 Flamewheel UAS s

, instead of manned aircraft, will greatly benefit the public by drastically reducing the

levels of air and noise pollution generated during traditional aerial video and still

photography flight operations. By using battery power and electric motors, the DJI

Inspire and DJI F550 Flamewheel UAS s produce no air pollution, and is the most

viable environmentally conscious alternative to the cabin class, six cylinder internal

combustion engine aircraft that are typically utilized for aerial video and photography,

while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The DJI

Inspire and DJI F550 Flamewheel UAS s

, while reducing the carbon footprint of aerial

acquisitions, also eliminates noise pollution, as the UASs are propelled by battery

powered electric motors, rather than an internal combustion engine.

By using the DJI Inspire and DJI F550 Flamewheel UAS s to perform aerial

acquisitions, the substantial risk to life and property in the air and on the ground, which

is usually associated with traditional manned aircraft flight operations, will be

substantially reduced or completely eliminated. Aside from the lack of flight crew

members located onboard the aircraft, the DJI Inspire and DJI F550 Flamewheel UAS s

(weighing approximately 6.5 pounds maximum gross weights with a length and width

between 17.3 inches and 21 inches

, 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 Inspire

and DJI F550 Flamewheel UAS Will Benefit The Economy.

In addition to being safe and efficient, the DJI Inspire and DJI F550 Flamewheel is also

an economical alternative to using manned aircraft to conduct similar aerial operations.

As such, operation of the DJI Inspire and DJI F550 Flamewheel UAS will allow

United States based companies, like Above and Beyond Productions LLC, to remain

competitive and contribute to growth of the U.S. economy.

Specifically, with the rising cost of aviation fuel and the Environmental Protection

Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and

operated companies must adopt new and alternative technology in order to remain

competitive.

Operating the battery powered DJI Inspire and DJI F550 Flamewheel UAS is one such12

technology that not only allows companies greater operational flexibility compared to

manned aircraft, but provides such flexibility without the high operational cost of a

traditional manned aircraft.

By operating the DJI Inspire and DJI F550 Flamewheel UAS s

, companies such as

Above and Beyond Productions LLC, 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 Inspire and DJI F550 Flamewheel

UAS s

, 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, Above and Beyond Productions LLC ’s proposed operation of the DJI Inspire

and DJI F550 Flamewheel UAS will not implicate any privacy issues. Specifically, the

DJI Inspire and DJI F550 Flamewheel UAS will be operated only in compliance with

the conditions set forth in any exemption granted under this petition.



## 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 Above and Beyond Productions LLC Seeks

Exemption.

1. Reasons Why The DJI Inspire and DJI F550 Flamewheel Will 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, Above and Beyond Productions LLC operation

of the DJI Inspire and DJI F550 Flamewheel UAS meet the conditions of FMRA

Section 333, and will not require an airworthiness certificate in accordance with 14

C.F.R. Part 21, Subpart H.

Section 333 provides authority for a UAS to operate without airworthiness certification

and sets forth requirements for considering whether a UAS will create a hazard to users

of the NAS or the public, or otherwise pose a threat to national security. Specifically,

FMRA Section 333 states the following, in part:

(a) In General.

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

later than 180 days after the date of enactment of this Act, the Secretary of13 Transportation shall determine if certain unmanned aircraft systems may operate

safely in the national airspace system before completion of the plan and rulemaking

required by section 332 of this Act or the guidance required by section 334 of this

Act.

(b) Assessment of Unmanned Aircraft Systems.

-- In making the determination

under subsection (a), the Secretary shall determine, at a minimum

--

(1) which types of unmanned aircraft systems, if any, as a result of their

size, weight, speed, operational capability, proximity to airports and

populated areas, and operation within visual line of sight do not create a

hazard to users of the national airspace system or the public or pose a

threat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or

airworthiness certification under section 44704 of title 49, United States

Code, is required for the operation of unmanned aircraft systems identified

under paragraph (1).

(c) Requirements for Safe Operation.

-- If the Secretary determines under this

section that certain unmanned aircraft systems may operate safely in the 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, Above and Beyond Productions LLC submits that the DJI Inspire

and DJI F550 Flamewheel UAS can operate safely in the NAS pursuant to FMRA Section

333, as demonstrated by:

(a) the characteristics of the DJI Inspire and DJI F550 Flamewheel UAS;

(b) the pilot certification requirement; and

(c) the specific operating limitations.

a. The Specifications Of The DJI Inspire and DJI F550 Flamewheel UAS

Demonstrate Its Safe Characteristics.

The DJI Inspire and DJI F550 Flamewheel UAS does not create a hazard to users of

the NAS or the public, or otherwise pose a threat to national security considering its

size, weight, speed, and operational capability.

i. Technical Specifications Of The DJI Inspire and DJI F550

Flamewheel UAS.

The technical specifications of the DJI Inspire and DJI F550

Flamewheel UAS is set forth by the DJI Inspire and DJI F550

Flamewheel Specifications and Data Sheet, attached hereto as

Exhibit A.

ii. The DJI Inspire and DJI F550 Flamewheel UAS Autonomous

Flight And Navigation Modes Enable The UAS To Remain Within A

Defined Operational Area.14 The DJI Inspire and DJI F550 Flamewheel UAS may be operated in

both manual and fully autonomous flight modes. A complete

description of the flight and navigational modes of the DJI Inspire and

DJI F550 Flamewheel UAS is provided in the DJI Inspire and DJI

F550 Flamewheel User Manual, attached hereto as Exhibit B.

iii. The DJI Inspire and DJI F550 Flamewheel UAS 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 Inspire and DJI F550

Flamewheel UA will remain stationary, in flight, for 3 seconds or

more. If, after 3 seconds, the DJI Inspire or DJI F550 Flamewheel UA

do not reacquire control link data from the GCS, the UA will assume

that the Control Link is lost and the UA 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 DJI Inspire

and DJI F550 Flamewheel UAS are set forth in the DJI Inspire and

DJI F550 Flamewheel User Manual, attached hereto as Exhibit B.

iv. The DJI Inspire and DJI F550 Flamewheel GCS And Its

Operation.

A complete description of the operation and specifications of the DJI

Inspire and DJI F550 Flamewheel GCS and flight control software is

provided in the DJI Inspire and DJI F550 Flamewheel User Manual.

DJI Inspire and DJI F550 Flamewheel User Manual is attached

hereto as Exhibit B.

b. Flight Operations Of DJI Inspire and DJI F550 Flamewheel UAS Are

Limited To The Line Of Sight With a Camera Operator and Safety Observer.

Above and Beyond Productions LLC will fly LOS in daytime hours only, staff each

flight with a remote control pilot, camera operator and a spotter/Safety Observer (SO)

with communications allowing real time communication among them.

c. Flig hts Of DJI Inspire and DJI F550 Flamewheel UAS Will Be

Conducted Pursuant To Specific Operating Limitations.

In seeking this exemption, proposes to commercially operate DJI Inspire and DJI

F550 Flamewheel UAS for the special purpose of conducting aerial video and

photography over certain areas of United States, pursuant to the following specific

operating limitations:

1. Operations authorized by this grant of exemption will be limited to

the following aircraft described in the operating documents, rotorcraft UASs15 weighing less than 55 pounds maximum gross weight: DJI Inspire and DJI

F550 Flamewheel and DJI F550 Unmanned Aircraft System s

. Proposed

operations of any other aircraft will require a new petition or a petition to

amend this grant.

2. UAS operations under this exemption will be limited to conducting

operations for the purpose of aerial video and photography.

3. The UAs may not be flown at an indicated airspeed exceeding 20

knots.

4. The UA must be operated at an altitude of no more than 4 00 feet

above ground level (AGL), as indicated by the procedures specified in the

operating documents unless a special request is made and approved by ATC.

All altitudes reported to ATC must be in feet AGL.

5. The UAs must be operated within 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

.

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 that

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 UAS operations and made available to the Administrator

upon request. If a discrepancy exists between the conditions and limitations

contained in the grant of exemption and the procedures outlined in the

operating documents, the conditions and limitations contained in the grant of

exemption take precedence and must be followed. Otherwise, the operator

must follow the procedures as outlined in its operating documents. The

operator may update or revise its operating documents. It is the operator’s

responsibility to track such 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 any16 update or revision would affect the basis upon which the FAA granted the

exemption, then the operator must petition for amendment to its grant of

exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted

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

10. Prior to each flight the PIC must inspect the UAS to ensure that it is

in a condition for safe flight. If the inspection reveals a condition that affects

the safe operation of the UAS, the aircraft is prohibited from operating until

the necessary maintenance has been performed and the UAS is found to be in

a condition for safe flight. The Ground Control Station must be included in

the preflight inspection. All maintenance and alterations must be properly

documented in the 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 potential 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

a ircraft/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 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 discrepancies discovered between inspections.

17. The operator may not permit any PIC to operate unless the PIC meets

the operator’s qualification criteria and demonstrates the ability to safely

operate the UAS in a manner consistent with how the UAS will be operated

under the exemption, including evasive and emergency maneuvers and

maintaining appropriate distances from persons, vessels, vehicles and

structures. PIC qualification flight hours must be logged in a manner

consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the

operator’s PICs are permitted under the terms of the exemption. However,

training operations may only be conducted during dedicated training17 sessions. During training, proficiency, and experience

- building flights, all

persons not essential for flight operations are considered nonparticipants,

and the PIC must operate the UA with appropriate distance from

nonparticipants in accordance with 14 C.F.R. § 91.119.

17.1. UAS operations may not be conducted during night , and a ll

operations must be conducted under visual meteorological conditions

(VMC).

18. The UA may not operate within 5 nautical miles of an airport

reference point as denoted on a current FAA

- published aeronautical chart

unless a letter of agreement with that airport’s management is obtained, and

the operation is conducted in accordance with a NOTAM as required by the

operator’s COA. The letter of agreement with the airport management must

be made available to the Administrator upon request.

19. 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.

20. If the UA loses 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.

21. The PIC must abort the flight in the event of unpredicted obstacles or

emergencies in accordance with the operating documents.

22. The PIC is prohibited from beginning a flight unless (considering

wind and forecast weather conditions) there is enough power to fly at normal

cruising speed to the intended landing point and land the UA with 25%

battery power remaining.

23. 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.

24. The UA must remain clear and yield the right of way to all manned

aviation operations and activities at all times.

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

vehicle.

26. 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 of18 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 those 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).

27. 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.

28. Any incident, accident, or flight operation that transgresses the lateral

or vertical boundaries of the operational area as defined by the applicable

COA must be reported to the FAA's UAS Integration Office (AFS

- 80)

within 24 hours. Accidents must be reported to the National Transportation

Safety Board (NTSB)

.



## F. A Summary That Can Be Published In The Federal Register, stating: The Rules From Which Above and Beyond

Productions LLC Seeks Exemption:

Above and Beyond Productions LLC seeks exemption from the requirements of 14 C.F.R

Sections 61.101(e)(4) and (5), 61.315(a), 61.23(a), 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).

This exemption will permit Above and Beyond Productions LLC to commercially operate an

Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and

photography over certain areas of the United States.

CONCLUSION

As set forth herein, Above and Beyond Productions LLC seeks an exemption pursuant to 14

C.F.R § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012

(FMRA), which will permit safe operation of the DJI Inspire and DJI F550 Flamewheel

UAS commercially, without an airworthiness certificate, for the limited purpose of19

conducting aerial video and photography over certain areas of the United States. By

granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate

of the FAA Modernization and Reform Act of 2012, while also advancing the interests of

the public, by allowing Above and Beyond Productions LLC to safely, efficiently, and

economically operate the DJI Inspire and DJI F550 Flamewheel UAS commercially within

the NAS.

I n accordance with the Federal Aviation Regulations and the FAA Modernization and

Reform Act of 2012, Section 333, Above and Beyond Productions LLC respectfully

requests that the Administrator grant this Petition f or an exemption from the requirements

of 14 C.F.R Sections 61.101(e)(4) and (5), 61.315(a), 61.23(a), 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

Above and Beyond Productions LLC to operate the DJI Inspire 1 and DJI F550 UAS s

commercially for the purpose of conducting aerial video and photography over areas of the

United States.

Dated: May 2 1 , 2015

Respectfully submitted,

Michael M. Brouder

Above and Beyond Productions , LLC

Exhibits :

A

– DJI Inspire and DJI F550 Flamewheel Specifications Data Sheet

B

– DJI Inspire and DJI F550 Flamewheel Manufacturer’s User Manual

C

– DJI Inspire and DJI F550 Flamewheel Maintenance Manual

D

– Monthly Maintenance Log20 EXHIBIT

– A

DJI Inspire and DJI F550 Flamewheel Specifications Data Sheet21

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

Aircraft Model

T600

Weight (Battery Included)

2935 g

Hovering Accuracy (GPS Mode)

Vertical: 0.5 m

Horizontal: 2.5 m Max

Angular Velocity

Pitch: 300°/s

Yaw: 150°/s

Max Tilt Angle

35°

Max Ascent Speed

5 m/s

Max Descent Speed

4 m/s

Max Speed

22 m/s (ATTI mode, no wind)

Max Flight Altitude

4500 m

Max Wind Speed Resistance

10 m/s

Max Flight Time

Approximately 18 minutes

Motor Model

DJI 3510

Propeller Model

DJI 1345

Indoor Hovering

Enabled by default

Operating Temperature Range

- 10° to 40° C

Diagonal Distance

559 to 581 mm

Dimensions

438x451x301 mm

Gimbal Model

ZENMUSE X3

Output Power (With Camera)

Static: 9 W

In Motion: 11 W

Operating Current

Station: 750 mA

Motion: 900 mA

Angular Vibration Range

±0.03°

Mounting

Detachable

Controllable Range

Pitch:

- 90° to +30°22 Pan: ±320°

Mechanical Range

Pitch:

- 125° to +45°

Pan: ±330°

Max Controllable Speed

Pitch: 120°/s

Pan: 180°/s

Camera Name

X3

Model

FC350

Total Pixels

12.76M

Effective Pixels

12.4M

Image Max Size

4000x3000

ISO Range

100

- 3200 (video)

100

- 1600 (photo)

Electronic Shutter Speed

8s

- 1/8000s

FOV (Field Of View)

94°

CMOS

Sony EXMOR 1/2.3”

Lens

20mm (35mm format equivalent)f/2.8 focus at ∞

9 Elements in 9 groups

Anti

- distortion

Still Photography Modes

Single shoot

Burst shooting: 3/5/7 frames

Auto Exposure Bracketing (AEB): 3/5 bracketed frames at 0.7EV Bias

Time

- lapse

Video Recording Modes

UHD (4K): 4096x2160p24/25, 3840x2160p24/25/30

FHD: 1920x1080p24/25/30/48/50/60

HD: 1280x720p24/25/30/48/50/60

Max Bitrate Of Video Storage

60 Mbps

Supported File Formats

FAT32/exFAT

Photo: JPEG, DNG

Video: MP4/MOV (MPEG

- 4 AVC/H.264)

Supported SD Card Types

Micro SD

Max capacity: 64 GB. Class 10 or UHS

- 1 rating required.

Operating Temperature Range

0° to 40° C23

Remote

Controller Name

C1

Operating Frequency

922.7~927.7 MHz (Japan Only)

5.725~5.825 GHz

2.400~2.483 GHz

Transmitting Distance (Outdoor And Unobstructed)

2 km

EIRP

10dBm@900m

, 13dBm@5.8G, 20dBm@2.4G

Video Output Port

USB, mini

- HDMI

Power Supply

Built

- in battery

Charging

DJI charger

Dual User Capability

Host

- and

- Slave connection

Mobile Device Holder

Tablet or Phone

Max Mobile Device Width

170mm

Output Power

9 W

Operating Temperature Range

- 10° to 40° C

Storage Temperature Range

Less than 3 months:

- 20° to 45° C

More than 3 months: 22° to 28° C

Charging Temperature Range

0

- 40° C

Battery

6000 mAh LiPo 2S

Charger Model

A14

- 100P1A

Voltage

26.3 V Rated

Power 100

W

Battery

(Standard) Name

Intelligent Flight Battery

Model

TB47

Capacity

4500 mAh

Voltage

22.2 V

Battery Type

LiPo 6S High voltage battery

Energy40

DJI F550 FLAMEWHEEL TECHNICAL SPECIFICATIONS

Model Flame Wheel 550 (F550)

Frame Weight 478g

Diagonal Wheelbase 550mm

Takeoff Weight 1200g ~ 2400g

Recommended Propeller 10 × 3.8in ; 8 × 4.5in

Recommended Battery 3S~4S LiPo

Recommended Motor 22 × 12mm (Stator size)

Recommended ESC 15A OPTO

NAZA

- M V2 CONTROL PLATFORM TECHNICAL SPECIFICATIONS

Platform Multi

- rotor

Size MC: 45.5mm x 32.5mm x 18.5mm

PMU: 39.5mm x 27.5mm x 10.0mm

GPS & Compass 46mm(diameter)x10mm

LED: 25mm x 25mm x 7.0mm 99.9 Wh

Net Weight

570 g

Operating Temperature Range

- 10° to 40° C

Storage Temperature Range

Less than 3 months:

- 20° to 45° C

More than 3 months: 22° C to 28° C

Charging Temperature Range

0° to 40° C

Max Charging Power

180 W

Vision

Positioning Velocity Range

Below 8 m/s (2 m above ground)

Altitude Range

5

- 500 cm

Operating Environment

Brightly lit (lux > 15) patterned surfaces

Operating Range

0

- 250 cm40

Weight MC:27g

PMU:28g

GPS:27g

LED:13g

Power Consumption MAX: 3.15W(0.25A@12.6V)

Normal:1.638W(0.13A@12.6V)

Working Voltage MC : 4.8V ~ 5.5V

PMU : 7.4V ~ 26.0 V

(recommend 2S ~ 6S LiPo)

Operating Temperature

- 10°C to 50°C

Functions Max Yaw Angular Velocity 200°/s

Max Tilt Angle 35°

Ascent 6m/s / Descent 4.5m/s

Packing List MC x 1

GPS x 1

PMU x 1

USB Cable x 1

LED x 1

Servo Cables x 8

Micro

- USB Cable x 1

CAN Cable x 141 EXHIBIT

– B

DJI Inspire and DJI F550 Flamewheel Manufacturer’s User Manual

http://download.dji

innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.2_en.pdf

http://download.dji

innovations.com/downloads/flamewheel/en/F550_User_Manual_v1.9_en.pdf42 Exhibit

– C

DJI Inspire and DJI F550 Flamewheel Maintenance Manual43 

# Maintenance Manual



# INSPIRE 1

To ensure that your aircraft continues to offer optimal performance and to ensure flight safety,

it is recommended that comprehensive maintenance be performed after every 200 flights or 50

flight hours . This manual is intend to help users maintain their aircraft and maximize its continued

reliability.

I. Checking the Battery

1. Check the battery for damage and deformities. If

there are any signs of damage to the battery, stop

using it and discharge the battery to 10% or below

for disposal. Do not disassemble the battery for any

reason.

2. Check the battery pins and rub them clean with an

eraser if any residue is observed. This will help to

ensure a more reliable connection.

3. Check the metal battery power connectors for

damage. If the connectors appear burnt, try to clear

them. This can be done by inserting a piece of

sandpaper (1mm thic k) into the connectors to polish

the metal.

4. Check the contact pins in the battery compartment to

ensure that the pins are clear. They should be able

to establish easy contact with the battery connectors

and should not be bent.

5. Check the electrodes on the battery. If they appear

burnt, polish them with sandpaper. If there is serious

erosion, send the battery in for repairs.

6. Check the plastic components of the battery bracket

to see it is in good condition and that all screws are

secure. This prev ents the battery from becoming

loose during flight.

7. Check the power cables between the arms and the

center plate, if the cables are worn, contact DJI to

arrange repairs.

8. For long term storage, please refer to the “Intelligent

Flight Battery Safety Guidelines” and check the

battery once a month to prevent the battery cell from

being damaged.

9. Run the DJI Pilot App to confirm that all battery cells

are at similar voltage levels and stay at the same level

when the battery is fully charged. If all ce lls maintain

voltage levels above 3.7V but any cell is 0.2V higher

or lower than the others, contact DJI for analysis. You

can also check the battery cell warning history. If any

warning are reported, contact DJI.

II. Checking the Transformation System

1. Check the servomotor cables for wear. Also confirm

that the connection points are still in good condition

. 2. Check the lead screws and contact DJI Support

to arrange repairs if any bending or damage is

discovered. Clean the lead screws with WD

- 40 spra y

if they show signs of rust.

3. Listen to the servomotors during the transformation,

if there is abnormal noise, it may indicate that the

servomotors worn.

4. After the landing gear rises, check the lead screws

and bearings. If any dirt or dust is found, clean and IV. Checking the Motors

1. Check the rotors to confirm that they have not

become loose.

2. Detach the propellers and start the m otors. Listen

carefully. If there is any abnormal noise, please

replace the motors. This may be a sign that the

bearings have been worn out.

3. Detach the propellers and start the motors. Carefully

examine the edge of the rotor and confirm that the

shaft is perfectly centered on the motor. Check

for any abnormal or excessive vibration. If any

problems are detected, contact DJI Support to order

replacement motors.

4. Check for deformities by confirming that the gap

between the motor and motor base is even. If not

contact DJI Support to order replacement motors.

5. Ensure that the screws used to secure the motor

base are tight and the plastic components around

the motors are in good condition. If not please

tighten the screws and contact DJI to repair any

broken plastic components.

V. Checking the Propellers

1. Check the propellers. If there is any bending,

breakage or cracking on a propeller, do not use it.

2. Attach the propeller to the motor, turn on the aircraft,

and place it on the ground. Stand 1 meter away from

the aircraft and observe the rotating propellers. If you

can see two distinct propeller outline layers, when

looking at a spinning propeller from the side, this

propeller is damaged and should not be used.

VI. Checking the IMU

1. Open DJ I Pilot app to check the condition of the IMU

and perform an advanced IMU calibration. Please

place the aircraft in a cool environment and on a

flat, stable surface (if the landing gear is damaged,

support the aircraft with four objects of equal

height). Do not touch the craft during the calibration.

2. Turn on the aircraft and listen for any abnormal noise

or vibration from the fan located on the front of the

aircraft. If any irregularity is detected, replace the

fan.

VII. Checking the Control and Vide o Transmission System

1. Check the 4 antennas on the landing gear to ensure

that they are secure. Also check for any bending or

damage.

2. Check the antennas of the remote controller for

Damage

3. Check the neck strap for damage or wear, replace44 grease the bearings.

5. Check the lead screws. If there is any scratches,

dents, or plastic particles underneath them, contact

DJI Support to arrange repairs.

III. Checking the Aircraft

1. Confirm that all the screws are still adequately

tightened.

2. Check the aircraft for breaks or damage. If there is

any reason to believe that detectable damage might

affect flight safety, consult with DJI Support.

3. Check the carbon tubes of the arms for damage

. 4. Check the dampers on the landing gears. If they are

loose, secure them with 502 glue.

5. Ensure that there are no obstacles on or around the

GPS module or around the antennas on the landing

gear. Remove any obstacles (such as tapes with

conductive material) that might affect or block the

signal

6. Check that the right and left landing gear rest at the

same tilt angle. if nece ssary.

VIII. Checking the Gimbal and Camera

1. The quick

- mount connector for the camera is a

particularly vulnerable component. If the gimbal

fails to initialize when turned on, fails to work after

initialization, or fails to transmit video to the app

(while OSD data is displayed), the quick

- mount

connector may be worn. In this case, replace the

rubber mat, circuit board, and/or connector on the

gimbal quick

- mount.

2. Check the metal contacts on the quick mount

connector board, if any contact is bent, replace

the quick

- mount connector.

3. Check the contact pins on the quick

- mount

connector board, if there is any dirt, rub it clean

with an eraser. If any contact pins are worn out it

should be replaced.

4. Confirm that the gimbal is able to properly sta bilize

itself. If its stabilizing performance deteriorates,

contact DJI to arrange repairs.

5. Listen for any abnormal noise from the fan when

the gimbal is turned on. This may indicate unusual

vibration and the fan should be replaced.

IX. Checking the Vision Positioning System

1. Check the lens of the camera. If any dirt or residue

is detected, gently clean the lens.

2. Check for and remove objects that might block the

sensors.

3. Ensure that the Vision Positioning System is securely

installed on the aircraft.

4. Detach the propellers and turn on the aircraft. Hold

the aircraft 1

- 2 meters above a surface with rich

patterns, under good lighting conditions. Change

the Flight Mode switch to P Mode on the controller

and check the DJI Pilot app. If the app displays an

altitude value and indicates that P

- OPTI mode is

active, the Vision Positioning System should function

normally.45 

# Maintenance Manual



# DJI F550 Flamewheel

To ensure that your aircraft continues to offer optimal performance and to ensure flight safety,

it is recommended that comprehensive maintenance be performed after every 200 flights or 50

flight hours . This manual is intend to help users maintain their aircraft and maximize its continued

reliability.

I. Checking the Battery

1. Check the battery for damage and deformities. If

there are any signs of damage to the battery, stop

using it and discharge the battery to 10% or below

for disposal. Do not disassemble the battery for any

reason.

2. Check the batter y pins and rub them clean with an

eraser if any residue is observed. This will help to

ensure a more reliable connection.

3. Check the metal battery power connectors for

damage. If the connectors appear burnt, try to clear

them. This can be done by insert ing a piece of

sandpaper (1mm thick) into the connectors to polish

the metal.

4. Check the contact pins in the battery compartment to

ensure that the pins are clear. They should be able

to establish easy contact with the battery connectors

and should not be bent.

5. Check the electrodes on the battery. If they appear

burnt, polish them with sandpaper. If there is serious

erosion, send the battery in for repairs.

6. Check the plastic components of the battery bracket

to see it is in good condition and that all screws are

secure. This prevents the battery from becoming

loose during flight.

7. Check the power cables between the arms and the

center plate, if the cables are worn, contact DJI to

arrange repairs.

8. For long term storage, please refer to th e “Intelligent

Flight Battery Safety Guidelines” and check the

battery once a month to prevent the battery cell from

being damaged.

9. Run the DJI Pilot App to confirm that all battery cells

are at similar voltage levels and stay at the same level

when th e battery is fully charged. If all cells maintain

voltage levels above 3.7V but any cell is 0.2V higher

or lower than the others, contact DJI for analysis. You

can also check the battery cell warning history. If any

warning are reported, contact DJI.

II. Checking the Transformation System

1. Check the servomotor cables for wear. Also confirm

that the connection points are still in good condition.

2. Check the lead screws and contact DJI Support

to arrange repairs if any bending or damage is

discovered. Clean the lead screws with WD

- 40 spray

if they show signs of rust.

3. Listen to the servomotors during the transformation,

if there is abnormal noise, it may indicate that the

servomotors worn. 4. After the landing gear rises, check the lead screws

and bearings. If any dirt or dust is found, clean and

grease the bearings.

5. Check the lead screws. If there is any scratches,

de nts, or plastic particles underneath them, contact

DJI Support to arrange repairs.

III. Checking the Aircraft

1. Confirm that all the screws are still adequately

tightened.

2. Check the aircraft for breaks or damage. If there is

any reason to believe that detectable damage might

affect flight safety, consult with DJI Support.

3. Check the carbon tubes of the arms for damage.

4. Check the dampers on the landing gears. If they are

loose, secure them with 502 glue.

5. Ensure that there are no obstacles on or around the

GPS module or around the antennas on the landing

gear. Remove any obstacles (such as tapes with

conductive material) that might affect or block the

signal.

6. Check that the right and left landing gear rest at the

same tilt angle.

IV. Chec king the Motors

1. Check the rotors to confirm that they have not

become loose.

2. Detach the propellers and start the motors. Listen

carefully. If there is any abnormal noise, please

replace the motors. This may be a sign that the

bearings have been wor n out.

3. Detach the propellers and start the motors. Carefully

examine the edge of the rotor and confirm that the

shaft is perfectly centered on the motor. Check

for any abnormal or excessive vibration. If any

problems are detected, contact DJI Support to order

replacement motors.

4. Check for deformities by confirming that the gap

between the motor and motor base is even. If not

contact DJI Support to order replacement motors.

5. Ensure that the screws used to secure the motor

base are tight and the pl astic components around

the motors are in good condition. If not please

tighten the screws and contact DJI to repair any

broken plastic components.46 V. Checking the Propellers

1. Check the propellers. If th ere is any bending,

breakage or cracking on a propeller, do not use it.

2. Attach the propeller to the motor, turn on the aircraft,

and place it on the ground. Stand 1 meter away from

the aircraft and observe the rotating propellers. If you

can see two di stinct propeller outline layers, when

looking at a spinning propeller from the side, this

propeller is damaged and should not be used.

VI. Checking the Control and Video Transmission System

1. Check the antennas of the remote controller for

damage

2. Check the neck strap for damage or wear, replace

if necessary. VIII. Checking the Gimbal and Camera

1. If the gimbal fails to initialize when turned on, fails to work after

initialization, or fails to transmit video to the app

(while OSD data is displayed), replace the

circuit board, and/or connector on the

gimbal.

2. Check the metal contacts on the

connector board, if any contact is bent, replace

the quick

- mount connector.

3. Check the contact pins on the quick

- mount

connector board, if there is any dirt, rub it clean

with an eraser. If any contact pins are worn out it

should be replaced.

4. Confirm that the gimbal is able to properly stabilize

itse lf. If its stabilizing performance deteriorates,

contact DJI to arrange repairs.

5. Check the lens of the camera. If any dirt or residue

is detected, gently clean the lens.47 EXHIBIT

– D

Monthly Maintenance Log48



# DJI F550 / DJI Inspire 1