**Petition for Exemption 14 CFR § 11.81** 

Unmanned Aircraft Systems: DJI Phantom 3

Summary: Soleil Multimedia Productions LLC. seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Soleil Multimedia Productions LLC to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography of construction sites, real estate, and landscape over certain areas of the United States. The industries I serve are Real Estate, Solar, Fly

fishing. My company will create local jobs. I have over 8 years experience providing video and photography services professionally and have flown recreationally for 3 years. My goal is to fly the DJI Phantom 3 to provide marketi ng collateral to my clients. I am seeing an exemption to operate DJI systems for compensation.

Contact Information Soleil Multimedia Productions, LLC. Jared Sabater 87 Hill Creek Blvd Chapel Hill, N.C. 27516 206

- 265

- 1420 jared@soleilmultimedia.com www.soleilmultimedia.com**The specific section or sections of 14 CFR from w**  **hich yo**  **u seek**

**an exemption;** 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),

**The extent of relief y ou seek and the reason y**  **ou seek the relief; Relief from Section 61.113(a) and (b) entitled**  **:** I am submitting t hat an equivalent level of safety will be maintained b ecause no PIC will be allowed to operate the UAS unless that PIC has met certain flight

hour and currency requirements, demonstrating that the PIC is able to safely operate 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.

Relief from Section 91.7(a) Civil Aircraft Airworthiness: I will ensure that the UAS is i n airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual) prior to every flight, and further, determine that the aircraft is in condition for safe flight

Relief from Section 91.121 ((Altimeter Settings): As more fully set forth herein, an equivalent level of safety will be maintained since the DJI Inspire 1 UA is equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground le vel pressure setting will be established prior to each flight, and provides the PIC with altitude information of the UA on the heads

- up display of the GCS.

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, : The UAS is battery powered. Each battery last apx 15 minutes.Relief from 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, Dragonfly Live LLC requests relief from these Sections because UAS does not require airworthiness certificates. As set forth more fully below, the UAS meets the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, Soleil Multimedia 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., Monthly Maintenance Log, and DJI Phantom 3).

Soleil Multimedia Productions LLC will document and maintain all maintenance records for the DJI Phantom 3

**How y**  **our request w ould benefit the public as a w**  **hole;** This petitions will allow Soleil Multimedia Productions, LLC to safely, efficiently, and economically perform aerial video and photography of construction sites, real estate, and landscape over certain areas of the United States. Conducting aerial acquisitions with the DJI Phantom 3 UAS, instead of manned aircraft, will g reatly 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 Phantom 3 UAS produces no air po llution, 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 l eaded aviation fuel. DJI Phantom 3 UA, 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 DJI Phanto m 3 UAS to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, whichis 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 Phantom 3 UA (weighing approximately 2 pounds 11 ounces, at its maximum gross weight with a length of 16 inches, widths of 16 inches, and with no fuel on board), has physical potentia l for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations

**Reasons w hy** 

**the exemption w ould not adversely**  **affect safety**
**, or ho** **w the exemption w ould provide a**  **level of safety at least**  **equal to the existing rule;**

- The UA will be operated at an altitude of no more than 400 feet above ground level

- When the Control Link is lost, the DJI Phantom 3 UA will remain stationary, in flight, for 3 seconds or more. If, a fter 3 seconds, the DJI Phantom 3 UA does not reacquire control link data from the GCS, the UAs will assume that the Control Link is lost and the UAs will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown.

- Soleil Multimedia Productions LLC will only utilize certificated pilots who possess a current and valid airman medical certificate to act as a pilot in command (PIC) of the DJI Inspire 1 UAS. Additionally, a safety observer will assist all pilots during flight time.

- The DJI Phantom 3 weighs less than 5 pounds

- I only plan to fly to conduct operations of aerial video and photography

- I will not exceed 20 knots

- I will only operate the DJI Phantom 3 with in a visual line of sight at all times

- I will utilize a safety observer at all times

- I will have all operating documents accessible and available upon request

- Prior to each flight the PIC must pre

- flight inspection the UAS to ensure that it is in a condition for safe flight.

- We will not fly during the night time- we will not operate with in 5 nautical miles of an airport

- no PIC will be allowed to operate the DJI Phantom 3 UAS unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the P IC is able to safely operate the the DJI Phantom 3 UAS in a manner consistent with the exemption

**A summar** **y we** **can publish in the Federal stating**

**—** Soleil Multimedia Productions LLC. seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b ), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Soleil Mul timedia Productions LLC to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography of construction sites, real estate, and landscape over certain areas of the United States. The industries I serve are Real Estate, Solar, Fly

fishing. My company will create local jobs. I have over 8 years experience providing video and photography services professionally and have flown recreationally for 3 years. My goal is to fly the DJI Phantom 3 to provide marketing collateral to my clients. I am seeing an exemption to operate DJI systems for compensation.