1

February 26, 2016

Attn: U. S. Department of Transportation Docket Operations West Building Ground Floor, Room w12

- 140 1200 New Jersey Ave, SE Washington, DC 20590

RE: INTEGRITY IMAGES, LLC

Petition for Exempti on under Section 333

REQUEST AN EXEMPTION 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 DJI Inspire 1
UNMANNED AIRCRAFT SYSTEMS PURSUAN T TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)

APPLICANT :

Michael Reiland

CEO/Producer Integrity Images, LLC 11210 Steeplecrest Drive, Suite 300 Houston, Texas 77065

P

- 713

- 862

- 4919 F

- 713

- 862

- 5438 mreiland@integrityimages.net

A pplication submitted by Applicant's legal counsel:

Phillip Black

– Attorney Dossey & Jones, PLLC
25025 I

- 45 South, Suite 575 The Woodlands, TX 77380 Tel. (281) 362

- 9909 Fax. (281) 476

- 7045 phillip@dossey.com2 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.......................

............ ... ................................... 6

THE SPECIFIC S ECTIONS OF 14 C.F.R. FROM WHICH INTEGRITY IMAGES, LLC

SEEKS EX EMPTION........................................

........................................... ... ..... .... ..... ....... 7

THE EXTENT OF RELIEF INTEGRITY IMAGES, LLC SEEKS AND THE REASON INTEGRITY IMAGES, LLC SEEKS THE R ELIEF...................

................... ......... ....... . . 1 0

THE REASONS WHY GRANTING INTEGRITY IMAGES, LLC’S REQUEST WOULD
BE IN THE PUBLIC INTEREST ...................................

............ .................. .................... .1 2

THE REASONS W HY GRANTING THE EXEMPTION TO INTEGRITY IMAGES, LLC

WOULD NOT ADVE RSELY AFFECT SAFETY..........................................

................ .... 1 4

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER....

.......... .. . .. 25

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS A VAILABLE TO

SUPPORT INTEGRITY IMAGES, LLC’S R EQUEST...

.......................................... . . ... .... 25

CONCLUSION..........................................................................................

.................. . ........ 2 5

APPENDICES...............................................................

. .................... .... 263 GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

Section 333 FAA Modernizatio n and Reform Act of 2012 (FMRA)

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

Integrity Images, LLC hereafter referred to as INTEGRITY IMAGES 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 ( DJI Inspire

1 ) pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit IN TEGRITY IMAGES to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography of residential and

commercial real estate, civil landscape s and events over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

INTEGRITY IMAGES has for over thirteen years provided their clients ( which include private

se ctor, non

- profits, and Fortune 100 businesses ) with expertise and knowledge in video production,

multi media marketing

, advertising

, photography, and printing and using advanced technologies

and solutions. INTEGRITY IMAGES has worked on thousands of productions over the past 13 years in all type s of location s with a perfect client and employee safety record

. In the pas t

, we have suppl i ed o u r clients aerial video and photography using commercial aircraft . The objective of

INTEGRITY IMAGES and our Unmanned Aircraft System ( DJI Inspire 1 ) aerial operations is to provide a more affordable

, high

- quality production system for a variety of commercial, public, and residential uses, specifically targeting :

• Construction sites before and after

• Real

- estate marketing

• Economic development

• Special event coverage

• Safety training

• Small and m edium sized business marketing

BACKGROUND

Unmanned Aircraft Systems: DJI Inspire 1

, UAS

INTEGRITY IMAGES seeks an exemption to operate DJI Inspire 1 system for compensation or

hire within the NAS. The DJI Inspire 1 is vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The DJI Inspire 1 has a maximum gross weight of approximately 6.5 lb. while having a diagonal

di mension of 22” to 22.8” , a maximum speed of approximately 20 knots and a maximum flying height of 400'

. The DJI Inspire 1 is equipped with four main rotors; driven by Lithium Polymer

b attery powered electric motors. INTEGRITY IMAGES has been offering Professional Aerial Photography and Video while hiring private pilots (in traditional planes and helicopters) since J uly

of 2013. INTEGRITY IMAGES ’ crew has successfully flown the Inspire 1 Quadcopter for hobby/recreation while maintaining a perfect safety record.

For your convenience, we have attached a copy of the DJI Inspire 1 user manual, whi ch is incorporated by reference into this application for exemption.5

The DJI Inspire 1 that will be operated by INTEGRITY IMAGES 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

.

P l ease see the following web

- link for the Owner' s Manual for the DJI Inspire 1:

http://download.dji

- innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.4_en.pdf

BASIS FOR PETITION

Petitioner, INTEGRITY IMAGES , pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modern ization 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

, UAS in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

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

unmanned aircraft and its operation, INTEGRITY IMAGES operation of DJI Inspire 1 UAS 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, INTEGRITY IMAGES 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.

INTEGRITY IMAGES submits that the re quested relief is proper since an equivalent level of safety will be ensured. INTEGRITY IMAGES will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practi ces prescribed in the operating documents (i.e., Monthly Maintenance Log,

and DJI Inspire 1 Instruction Manual). Furthermore, INTEGRITY IMAGES will document and

maintain all maintenance records for the DJI Inspire 1 UAS.

Relief from certain requirements o f Section 61.113(a) and (b), entitled Private pilot privileges and

limitations: Pilot in command , is requested by INTEGRITY IMAGES 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 able to safely operate the DJI Inspire UAS in a manner consistent with this exemption, including evasive and emergency maneuver s and maintaining appropriate distances from people, vessels, vehicles and structures.

INTEGRITY IMAGES seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness

, because the DJI Inspire 1 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, INTEGRITY IMAGES submits that they will ensure that the DJI Inspire 1 UAS is in an airworthy condition, prior to every flight, by determining that the UAS6

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

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

INTEGRITY IMAGES also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , as the DJI Inspire 1 UAS will not have a typical barometric altimeter onboard. However, altitude information of the DJI Inspire 1 UAS will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which

downlin ks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with INTEGRITY IMAGES operation of the DJI Inspire 1 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, INTEGRITY IMAGES seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions

. INTEGRITY IMAGES submits that safety will not be affected by operation of the DJI In spire 1 UAS during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration of approximately 18 minutes . Battery power indicators are also able to show exactly how much battery power is left, as well as how much time is needed to retu rn safely back to point of take off.

In accordance with 14 C.F.R. § 11.81, INTEGRITY IMAGES 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:

Michael Reiland

CEO/Producer Integrity Images, LLC 11210 Steeplecrest Drive, Suite 300 Houston, Texas 77065

P

- 713

- 862

- 4919 F

- 713

- 862

- 5438 mreiland@integrityimages.net7

B. The Specific Sections Of 14 C.F.R. From Which INTEGRITY IMAGES Seeks Exemption.

1. INTEGRITY IMAGES Seeks Exemption From The Requirements Of Section 61.113(a) And (b).

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

, subsections (a) and (b) prescribe the following, in relevant part:

(a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PIC of an aircraft.

(b) A privat e 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 compensati on or hire.

2. INTEGRITY IMAGES Seeks Exemption From The Requirements Of Section 91.7(a).

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

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

3. INTEGRITY IMAGES Seeks Exemption From The Requirements Of Section 91.121.

Section 91.121, entitled Altimeter settings , subsection (a), states the following, in part:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

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

--

(i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station;

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. INTEGRITY IMAGES Seeks Exemption From The Requirements Of Section 91.151(b).

Secti on 91.151, entitled Fuel requirements for flight in VFR conditions , subsection

(b), states the following:8 (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. INTEGRITY IMAGES Seeks Exemption From The Requirement Of Section 91.405(a).

Section 91.405, entitled Maintenance required , subsection (a), states the following: Each owner or operator of an aircraft

—
(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.]

6. INTEGRITY IMAGES Seeks Exemption From The Requirements Of Section 91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding,
or alteration

, subsection (a)(1), states the following:

(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

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

7. INTEGRITY IMAGES Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2).

Section 91.409, entitled Inspections , subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

--
(1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.

8. INTEGRITY IMAGES 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:9 (1) Records of the maintenance, preventive maintenance, a nd alteration and records

of the 100

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

--
(i) A description (or reference to data acceptable to the Administrator) of the work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the aircraft

for return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each

rotor.

(ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis.

(iv) The cur rent 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 safe ty 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 prescri bed 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 spe cified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and

transferred with the aircraft at the time the aircraft is sold.10 (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. T he Extent Of Relief INTEGRITY IMAGES Seeks And The Reason INTEGRITY
IMAGES Seeks The Relief.

1. Extent Of Relief INTEGRITY IMAGES Seeks And The Reason INTEGRITY IMAGES Seeks Relief From Section 61.113(a) And (b).

Relief from Section 61.113(a) and (b) ent itled 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 emplo yment 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, INTEGRITY IMAGES submits that an equivalent level of safety

wil l be maintained because no PIC will be allowed to operate the 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 DJI Inspire 1 UAS in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures.

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

2. Extent Of Relief INTEGRITY IMAGES Seeks And The Reason INTEGRITY IMAGES 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 INTEGRITY IMAGES to determine that the DJI Inspire 1 UAS are in airwor thy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e.,

INTEGRITY IMAGES Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual).

INTEGRITY IMAGES seeks the requested relief because the DJI Inspire 1 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, INTEGRITY

IMAGES will ensure that the DJI Inspire 1 UAS are in airworthy condition based upon i ts11

compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 ) prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated in

the conditions and limitations below.

3. Extent Of Relief INTEGRITY IMAGES Seeks And The Reason INTEGRITY IMAGES

Seeks Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings , may be required to allow flight operations

of the DJI Inspire 1 UAS, which utilize a barometric press ure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reporte d to air traffic control (ATC) in feet above ground level (AGL),

INTEGRITY IMAGES seeks the requested relief because the DJI Inspire 1 UAS altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude,

bef ore 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 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 o f the GCS.

4. Extent Of Relief INTEGRITY IMAGES Seeks And The Reason INTEGRITY IMAGES Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions , is requested to the extent required to allo w flights of the battery powered DJI Inspire 1 UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total

duration of 18 minutes. INTEGRITY IMAGES seeks the requested relief because without an exemptio n from Section 91.151(b), the flight time duration of the battery powered DJI Inspire 1

UAS will severely constrain the practicality of any aerial video or still photo flight operations that

INTEGRITY IMAGES proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the DJI Inspire 1 UAS , the DJI Inspire 1 operating documents, and INTEGRITY IMAGES proposed operating limitations, ensure

that INTEGRITY IMAGES will safely operate the battery powered DJI I nspire 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 18 minutes

.12

5. Extent Of Relief INTEGRITY IMAGES Seeks And The Reason INTEGRITY IMAGES 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, INTEGRITY IMAGES r equests relief from these

Sections because the DJI Inspire 1 UAS do not require airworthiness certificates. As set forth more fully below, the DJI Inspire 1 UAS meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, INTEGRITY IMAGES will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the

INTEGRITY IMAGES Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, INTEGRITY IMAGES will document and maintain all

maintenance records f

or the DJI Inspire 1 UAS

.

D. The Reasons Why Granting INTEGRITY IMAGES 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 INTEGRITY IMA GES to safely, efficiently, and economically perform aerial video and photography of construction sites, real estate, events and civic landscape over certain areas of the United States.

Additionally, use of the DJI Inspire 1 UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of INTEGRITY IMAGES proposed operation of the DJI Inspire 1 UAS will be realized without implicating any privacy

issues.

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

The DJI Inspire 1 UAS are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the

amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use

of a DJI Inspire 1 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The 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, arriv al, and landing phases of flight operations.13

2. The Public Will Benefit From The Safety And Efficiency Of The DJI Inspire 1 UAS.

Conducting aerial acquisitions with the DJI Inspire 1 UAS, instead of manned aircraft, will greatly benefit the public by dra stically 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 1 UAS 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 gall ons per hour of leaded aviation fuel. The DJI Inspire 1 UAS , while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAS are propelled by battery powered electric motors, rather than an internal combustion engine

. By using the DJI Inspire 1 UAS 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 compl etely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI Inspire 1 UAS (weighing approximately

2 .8 pounds at their maximum gross weight with diagonal dimension of 23.2 inches , and with no fuel on board), has less p hysical 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 1 UAS Will Benefit The Economy.

In addition to being safe and efficient, the DJI Inspire 1 UAS are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Inspire 1

UAS will allow United States based companies, like INTEGRITY IMAGES , 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 orde r to remain competitive. Operating the battery powered DJI Inspire 1 UAS is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional

manned aircraft.

By operating the DJI Inspire 1 UAS, companies such as INTEGRITY IMAGES , can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately contribute to gro wth of the U.S. economy. Improved financial performance of U.S. companies, through commercial use of the DJI Inspire 1 UAS, 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.14

4. There Are No Privacy Issues.

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

INTEGRITY IMAGES proposed operation of the DJI Inspire 1 UAS will not implicate any privacy issues. Specifically, the DJI Inspire 1 UAS will be operated only in compliance with operating documents (i.e., INTEGRITY IMAGES Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual) which requires 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 INTEGRITY IMAGES Seeks E xemption.

1. Reasons Why The DJI Inspire 1 UA S 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 o peration, INTEGRITY IMAGES operation of the DJI Inspire 1 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. Speci fically, 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 certa in 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 Syste ms.

-- 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 populate d 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 airspace15 system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system.

In seeking this exemption, INTEGRITY IMAGES submits that the DJI Inspire 1 UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of

the DJI Inspire 1 UAS ; (b) the pilot certification requirement; and (c) the specific operating

limitations.

a. The Specifications Of The DJI Inspire 1 UAS Demonstrate Its Safe Characteristics.

The DJI Inspire 1 UAS do es 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 1 UAS

. The technical specifications of the DJI Inspire 1 UAS are set forth by the DJI Inspire 1 Use r Manual , att ached hereto as Appendix A

.

ii. The DJI Inspire 1 UAS Global Positioning Modes Enable The UAS To Remain Within A Defined Operational Area.

The DJI Inspire 1 UAS may be operated in both manual and global positioning flight modes. A complete description of the flight and navigational modes of the DJI Inspire 1 UAS is provided at

pages 11 of the DJI Inspire 1 User Manual att ached hereto as Appendix A

.

iii. The DJI I nspire 1 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 1 UAS will remain stationary, in flight, for 3 seconds or more. If, after 3 second s, the DJI Inspire 1 UAS do es not reacquire control link data from the GCS, the UAS will assume that the Control Link is lost and the 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 Failsaf e Functions of the DJI Inspire 1 UAS are set forth at pages

13 through 16 of the DJI Inspire 1 User Manual, attached hereto as Appendix A

.

iv. The DJI Inspire 1 GCS And Its Operation.

A complete description of the operation and specifications of the DJI Inspire 1 GCS and flight control software is provided at pages 39 through 44 of the DJI Inspire 1 User Manual. DJI Inspire

1 User Manual is att ached hereto as Appendix A

. b. Flight Op erations Of DJI Inspire 1 UAS Is Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer.

INTEGRITY IMAGES video production staff will be the only person s to act as a pilot in command (PIC) of the DJI Inspire 1 UAS . Additionally, a safety observer will assist him at all times during flight time.16

c. Flights o f DJI Inspire 1 UAS Will Be Conducted Pursuant To Specific Operating

Limitations.

In seeking this exemption, INTEGRITY IMAGES proposes to commercially operate DJI Inspire

1 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 f ollowing aircraft described in the operating documents, rotorcraft UAS weighing less than 55 pounds maximum gross weight: 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 photog raphy.

3. The UA S 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 de vice other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate.

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

7. All operations must utilize a safety observer (SO). The SO m ay 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 des ignated 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 t he 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 opera ting 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. The17 operator may update or revise its operat ing documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AF S

- 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 affe cts 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 inspecti on. 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, mu st 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, n ot 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 i ts 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 i n service, description of work accomplished, and the signature of the authorized person returning the UAS to service.

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

Bulletins.

16. The authorized person must make an en try in the aircraft record of the corrective action taken against discrepancies discovered between inspections.

17. The PIC must possess at least a private pilot certificate and at least a current third

class medical certificate.

18. The operator may no t 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 mane uvers and maintaining appropriate distances from persons,18 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 permitt ed under the terms of the exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonpar ticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119.

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under vi sual meteorological conditions (VMC). If flight at night is required, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not

authorized.

20. The UA may not operate within 5 nautical miles of an airport reference point as

denoted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request.

21. The UA may not be operated less than 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 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.

23 . The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents.

24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough po wer to fly at normal cruising speed to the intended landing point and land the UA with 25% battery power remaining.

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 wit h airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requirements.

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

Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable.19 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.

2 8. 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 UA 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 all nonparticipating persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation

arises where nonparticipating persons leave such protection and are within 500 feet of the 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 st ructures 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 per sons do not present an undue hazard to those persons per § 91.119(a).

32. All operations shall be conducted over private or controlled

- access property with permission from the land owner/controller or authorized representative. Permission

from land owner/ controller or authorized representative will be obtained for each flight

to be conducted.

33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS

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

2. Reasons Why An Exemption From The Requ irements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety.20

INTEGRITY IMAGES submits that the equivalent level of safety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI Inspire 1 UA S unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the 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 INTEGRITY IMAGES ’ proposed area of operations, and the operating limitations

set forth

- above; the parallel nature of private pilot aeronautical knowledge requirements to thos e of commercial pilot requirements ( See Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI Inspire 1 UAS, INTEGRITY IMAGES submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for INTEGRITY IMAGES’ specific proposed flight operations.

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

INTEGRITY IMAGES will not allow any PIC to operate the DJI Inspire 1 UAS unless tha t PIC has demonstrated, by meeting minimum flight

- hour requirements or the DJI Inspire 1 UAS training and currency requirements, that the PIC is able to safely operate the 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

INTEGRITY IMAGES’ proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows:

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

- rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and mod el 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 the 10 hours may be21

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

- hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the petitioner’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in complianc e 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

- bui lding 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, INTEGRITY IMAGES will ensure safe operations by not allowing any PIC to operate the DJI Inspi re 1 UAS unless that PIC has demonstrated, by meeting minimum flight

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

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.7(a) will be maintained because prior to every flight, INTEGRITY IMAGES will ensure that the DJI Inspire 1 UAS is in an airworthy condition based upon the UAS’s compliance with its operating document s and as stated in the

conditions and limitations herein.

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 1 1063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety.

The equivalent lev el of safety established by Section 91.121 will be maintained because the

altitude information of the 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 INTEGRITY
IMAGES’ operation of the 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 be22

generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically established by the UAS at ground level.

The FAA has previously granted relief from Sec tion 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, 11 161).

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 technic al specifications of the DJI Inspire 1 UAS ; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, INTEGRITY IMAGES will ensure that it will safely operate the battery powered DJI Inspire 1 UAS during daylight hours in VFR conditions, with enough battery power to fly for

a total duration of 23 minutes.

Here, as in Exemption No. 11109, the technical specifications of the DJI Inspire 1 UAS ; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Inspire 1 UAS provide audible and visual warnings to the PIC at

the GCS when the UAS experiences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery power. At the critically low battery level, the DJI Inspire 1 UAS will descend and land

auto matically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in circumstances similar, in all materia l respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

6. Reasons Why An Exemption From T he 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, INTEGRITY IMAGES submits that the equivalent level of safety with regard to the regulatory mainte nance and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because23

INTEGRITY IMAGES will use trained technicians to perform maintenance, alterations, or preventive maintenance o n the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., INTEGRITY IMAGES Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, INTEGRITY IMAGES
will document and maintain all maintenance records for the DJI Inspire 1 UAS.

Since the DJI Inspire 1 UAS will be inspected as prescribed by the operating documents,

INTEGRITY IMAGES will maintain the equivalent level of safety established by Sections

91. 405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI Inspire 1 User Manuals are attached hereto as Appendix A and B; a copy of the DJI Inspire 1 UAS Maintenance LOG is attached hereto as Appendix C.

Likewise, the exemption sought will not adversely a ffect safety because INTEGRITY IMAGES 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 soug ht would maintain an equivalent level of safety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI Inspire 1 UAS will be performed by trained technicians. Maintenance will be documented and maintained utilizing

the monthly maintenance 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 is not adversely

affected when the technical characteristics and o perating limitations of the UAS are considered.

In consideration of INTEGRITY IMAGES’ proposed operating limitations, the operating documents, and the technical aspects of the DJI Inspire 1 UAS

, INTEGRITY IMAGES submits that safety will not be adversely a ffected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted relief specific to UAS in circumstances similar, in all material respects, to those presented here in (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

7. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Sect ion 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions

, INTEGRITY IMAGES requests that the FAA prescribe special conditions for the intended operation of the DJI Inspire 1 UAS , which contain

such sa fety 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,24

provides the authority for such UAS to operate without airworthiness certification in accordance with any requirements that must be established for the safe operation of the UAS in the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of the DJI Inspire 1 UAS , 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 p ropeller, 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 find s necessary to establish a level of safety equivalent to that established in the regulations.

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for Leading Edge’s intended operation of the DJI Inspire 1 UAS , 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),

9 1.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

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

Rules From Which INTEGRITY IMAGES Seeks Exemption:

INTEGRITY IMAGES 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 INTEGRITY IMAGES Seeks:

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

• Any Additional Information, Views, Or Arguments Available To Support
INTEGRITY IMAG ES ’ 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, INTEGRITY IMAGES’ 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.25

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the publi c, 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, INTEGRITY IMAGES will operate the DJI Inspire 1 UAS safely in the NAS, witho ut creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.

CONCLUSION

As set forth herein, INTEGRITY IMAGES 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 1 UAS commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing INTEGRITY IMAGES to safely, efficiently, and economically operate th e DJI Inspire

1 UAS commercially within the NAS.

WHEREFORE , in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, INTEGRITY IMAGES respectfully requests that the Administrator grant this Petitio n for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Leading Edge to operate the DJI Inspire 1 UAS commercially for the purpose of conducting aerial video and photography over certain areas of the

United States.

Dated: February 26, 2016

Respectfully submitted,

____ /Phillip Black/

_____ Phillip Black, attorney for P e titioner :

Michael Reiland Integrity Images, LLC

Phillip Black

– Attorney Dossey & Jones, PLLC
25025 I

- 45 South, Suite 575 The Woodlands, TX 77380 Tel. (281) 362

- 9909 Fax. (281) 476

- 704526

Appendices :

A

– Link to DJI Inspire 1 Manual: Click on link below

http://download.dji

- innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.4_en.pdf