1 

## UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

JULIA N EVERLY CREATIVE VENTURES, INC.

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS

OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 91.9(b), 91.203(a), 91.203(b), 45.23(b) AND 21.185

CONCERNING OPERATION OF AN UNMANNED AIRCRAFT SYSTEM

PURSUANT TO SECTION 333 OF THE

FAA MODERNIZATION AND REFORM ACT OF 2012

Submitted on September 9 , 2015

JULIAN EVERLY CREATIVE VENTURES, INC Julian Everly Shervington Wright 2024 R Street, NW Washington

, DC 20009 Tel: ( 202 ) 656

- 622 Julian@julianeverly.com

Petitioner2 CONTENTS

GLOSSARY OF ABBREV IATION S

............................. ............................. 3

SUMMARY

........ .......................................................... ............................. 4

INTRODUCTION AND INTERESTS OF THE PETITIONER

.............. 4

BACKGROUN D

........... ................................................. ............................ 5

BASIS FOR PETITION..........

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

A. Name And Address Of The Petitioner.

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

B. The Specific Sections Of 14 C.F.R. F rom Which JECV Seeks Exemption....................................................... 8

C. The Extent Of Relief JECV Seeks And The
Reason JECV Seeks The Relief.

..... ............................. ............................ .. 11

D. The Reasons Why Granting JECV ’s Request Would Be In The Public Interest

................ ................................ 14

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety...

..... .................................... ............... 17

CONCLUSION

........... .............................................................................. 323 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

JECV Julian Everly Creative Ventures, Inc.

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA)

SO Safety Observer

SOP Stan dard 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

JULIAN EVERLY CREATIVE VENTURES , INC. (JECV) 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 t he FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit
JECV to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photogr aphy for real estate photography, wedding videography, special events, film sets and landscape

over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Julian Everly Shervington Wright , and his company Julian Everly Creative Ventures, Inc., is an experienced year veteran of the en tertainment industry

. Mr. Wright has 22 years experience producing content for Sony/BMG, Universal, EMI and WEG of which he has won sales awards for his efforts. In addition to his professional credentials, Mr. Wright holds:

• A valid Medical Certificate Third Class and Studen t Pilot Certificate (Certificate Number GX1242573)

• Student Pilot

- Pre

- Solo Aeronautical Knowledge Endorsement

• FAA Certificate of Achievement DC Special Flight Rules Area, Course

ALC

- 405 (Certificate number 0741613

- 20140723

- 00405)

• 11. 5 hours of fixed wing piston engine experience flying in and out of the DC Special Flight Rules Area

As an aviation enthusiast, Mr Wright and JECV have chosen to comply with any applicable FARs despite the decision of Administrative Law Judge

Patrick G. Geraghty in Administrator v Pirker

. As a result of our policy to “err on the side of caution”, JECV has conducted no commercial UAS missions until the FAA has granted JECV an authorization via Section 333 exemption.

The objective of JECV .’s contemplated aerial video and photography operations is to provide high quality imaging for a variety of commercial projects including :

• Creation of commercial messages for Television • Motion Picture Filming • Real Estate Videography and Photography5 • Wedding Videog raphy and Photography • Land survey & appraisals • Equipment Inspections • Roof Inspections

• Construction sites before & after

• Precisio n Agriculture • Search and Rescue Operations • Increase public knowledge of UAS and promote safe UAS operations

BACKG ROUND

Unmanned Aircraft Systems: DJI Phantom 2 Vision+

, DJI Phantom 3 and DJI Inspire 1 UASs

JECV seeks an exemption to operate DJI systems for compensation or hire

within the NAS. The DJI Phantom 2 Vision+ , DJI Phantom 3 and DJI Inspire

1 are vertical t akeoff a nd landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone
systems.

• The DJI Phantom 2 Vision+ has a maximum gross weight of approximately 2 p ounds 11 ounces, length of 16 inches

, width of 16 inches, height of 8 inches, and a maximum speed of approximately

29 knots.

• The DJI Phantom 3 has a maximum gross weight of approximately

1 280 g, length of 23 inches width of 23 inches, height of 8 inches, and a maximum speed of approximately 30 knots.

• The DJI Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of approximately 42 knots.

• All are equipped with four main rotors; driven by Lithi um Polymer battery powered electric motors.

The UAS operating software and GPS navigation systems do not allow any of

the JECV UAS vehic les to operate near airports or restricted fly zones. The failsafe software will disable the UAS vehicles from taking off and also limit

the UAS systems from operating within specific GPS preset no

- fly zones.

The DJI products are common, commercially available, model s of remote

multi

- rotor aircraft. They are currently operating safely within the National6 Airspace System (NAS) pursuant to Advisory Circular 9157, June 9, 1981. The DJI Phantom family of aircraft has been operating worldwide since 2006.

BASIS FOR PETITION

Petitioner, Julian Everly Creative Vent ures, Inc. , 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 Phantom 2 Vision+, DJI Phantom 3, DJI Inspire 1 UASs 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, Julian Everly Creative Ventures, Inc . operation of DJI Phantom 2 Vision+ , DJI Phantom 3 and DJI Inspire 1 UASs 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, Julian Everly Creative Ventures, Inc . requests relief from

Section s 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.

Julian Everly Creative Ventures, Inc . submits that the requeste d relief is proper since an equivalent level of safety will be ensured. Julian Everly Creative Ventures, Inc . will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techni ques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1 Instruction Manual). Furthermore, Julian Everly Creative Ventures, Inc . will document and maintain all maintenance records for the

DJI Phantom 2 Vision+ , DJI Phantom 3 and DJI Inspire 1 UASs.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private

P ilot privileges an d limitations: Pilot in command , is re quested by Julian Everly Creative Ventures, Inc., 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 Phantom 2 Vision+ , DJI Phantom 3 and DJI Inspire 1

U ASs in a manner consistent with this exemption, including evasive and7 emergency maneuvers and maintaining appropriate dista nces from people, vessels, vehicles and structures.

Julian Everly Creative Ventures, Inc., seeks relief from Section 91.7(a),

entitled Civil aircraft airworthiness, because the DJI Phantom 2 Vision+ , DJI

Phantom 3 and DJI Inspire 1 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Julian Everly Creative Ventures, Inc., submits that they will ensure

tha t the DJI Phantom 2 Vision+, DJI Phantom 3 and DJI Inspire 1 UASs are in an airworthy condition, pr ior to every flight, by determining that the UASs are in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1 Instruction Manual), and that the aircraft are in a condition for safe flight.

Jul ian Everly Creative Ventures, Inc., also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , as the DJI

Phantom 2 Vision+ , DJI Phantom 3 and DJI Inspire 1 UAs will not have a typical barometric altimeter onboard. Howev er, altitude information of the

DJI Phantom 2 Vision+ , DJI Phantom 3 and DJI Inspire 1UAs will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to

the GCS for ac tive monitoring of the flight path. This altitude information,

combined with Julian Everly Creative Ventures, Inc .’s operation of the DJI

Phantom 2 Vision + , DJI Phantom 3 and DJI Inspire 1 UASs within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent

to Section 91.121

.

Additionally, Julian Everly Creative Ventures, Inc., seeks an exe mption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in

VFR conditions. Julian Everly Creative Vent ures, Inc. submits that safety will not be affected by operation of the DJI Phantom 2 Vision+ , DJI Phantom

3 and DJI Inspire 1 UAs during daylight hours in visual meteorological

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

to fly for a total duration of approximately 13.5 minutes to the first point of intended landing and, a ssuming normal cruising speed, to fly after that for at

least 4.5 minutes.

In accordance with 14 C.F.R. § 11.81, Julian Everly Creative Ventures, Inc.

pro vides the following information in support of its petition for exemption:

A. Name And Address Of The Petitioner.

Julian Everly Shervington Wright

c/o Julian Everly Creative Ventures, Inc.8 2 02 4 R Street, NW Washington, DC 20009 Tel: (202 ) 656

- 0622
Email: Julian@julianeverly.com

B. The Specific Sections Of 14 C.F.R. Fro m Which Julian Everly Creative Ventures, Inc . Seeks Exemption.

1. Julian Everly Creative Ventures, Inc

., Seeks Exemption F rom The Requirement s Of Section Part 21, Subpart H 14 C.F.R. Part 21, Subpart H, establishes the procedural requirements for the issuance of airworthiness certificates as required by 14 C.F.R. §91.203(a)(1)

.

2. Julian Everly Creative Ventures, Inc

., Seeks Exemption From The Requirements Of Section 61.113(a) And (b). Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections (a) and (b) prescribe the following, in relevant part:

(a) No person who holds a private pilot certificate may act as a pilot in

command (PIC) of an aircraft that is carrying passengers or property for
compensation or hire; nor may that person, for compensation or hire, act as

PIC of an aircraft.

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

—

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

hire.

3. Julian Everly Cre ative Ventures, Inc

. , Seeks Exemption F rom 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.

4. Julian Everly Creative Ventures, Inc

. , Seeks Exemption From The Requirements Of Section 91.121. Section 91.1 21, entitled Altimeter settings

, subsection (a), states the following, in part:

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

--9 (1) Below 18,000 feet MSL, to

--

(i) The current reported altimeter setting of a station along the route and

within 100 nautical mi les 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.

5. Julian Everly Creative Ventures, Inc

. , Seeks Exemption F rom The Requirements Of Section 91.151(b). Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states the following:

(b) No person may begin a flight in a rotorcraft under VFR conditions unless ( considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended land ing and, assuming normal cruising speed, to fly after that f or at least 20 minutes.

6. Julian Everly Creative Ventures, Inc

. , 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[.]

7. Julian Everly Creative Ventures, Inc

. , Seeks Exe mption 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 o f this chapter

.

8. Julian Everly Creative Ventures, Inc

. , Seeks Exemption From The10 Requirements Of Sections 91.409(a)(1) And 91.409(a)(2). Secti on 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.

9. Julian Everly Creative Ventures, Inc

. , Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b). Section 91.417, entitled Maintenance records, subsections (a) and (b), state

the following:

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and

records of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airfra me) 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 current inspec tion status of the aircraft, including the time since the last inspection required by the inspection program under which11 the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safety directive s 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 prescribed 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 specified in parag raph (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 aircraf t at the time the aircraft is sold. (3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.

C. The Extent Of Relief Julian Everly Creative Ventures, Inc

. , Seeks A nd The

Reason Julian Everly Creative Ventures, Inc

. Seeks The Relief.

1. Relief Julian Everly Creative Ventures, Inc., Seeks Exemption From The Requirements Of Section Part 21, Subpart H. Given the size and limited operating area associated with the UAS to be utilized by Relief Julian Everly Creative Ventures, Inc ., an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333

o f the Reform Act. The Federal Aviation Act (49 U.S.C.§ 44701(f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational c apability, and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions prop osed will be at least as safe, or safer, than a conventiona l rotorcraft operating with

an airworthiness certificate without the restrictions and conditions of the proposed UAS operations.

2. Extent Of Relief Julian Everly Creative Ventures, Inc . Seeks And The

Reason Relief Julian Everly Creative Ventures, Inc. Seeks Relief From12 Section 61.113(a) And (b). Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations:

Pilot in command, is requested to the extent necessar y 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 o r 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 inc idental 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, Relief Julian Everly Creative Ventures, Inc

. submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the DJI Phantom 2 Vision+ UAS , DJI Phantom 3

UAS or DJI Inspire 1 UAS unless that PIC has met certain flight

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

either th e DJI Phantom 2 Vision+ UAS , DJI Phantom 3 UAS or DJI Inspire 1

UAS in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from peopl e, vessels, vehicles and

structures.

Further, Julian Everly Creative Ventures, Inc

. submits that all flights of the

DJI Phantom 2 Vision+ UAS , DJI Phantom 3 UAS or DJI Inspire 1 UAS

, conducted by the PIC pursuant to the grant of this Petition:

(1) will be incidental to Julian Everly Creative Ventures, Inc

. ' s business; and

(2) will not carry passengers or property for compensation or hire.

3. Extent Of Relief Julian Everly Creative Ventures, Inc

. Seeks A nd The

Reason Julian Everly Creative Ventures, Inc

. Seeks Relief From Section 91.7(a). Relief from Section 91.7(a) entitled Civil aircraft airworthin ess, is requested to the extent required to allow Julian Everly Creative Ventures,

Inc

. to determine that the DJI Phant om 2 Vision+ and DJ Inspire 1 UASs are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., the Julian Everly Creative Ventures, Inc

. Aerial Operations Manual, Monthly Maintenance Log, and13 DJI Phantom 2 Vision+ UAS , DJI P hantom 3 UAS or DJI Inspire 1 UAS Instruction Manual). MA Julian Everly Creative Ventures, Inc

. seeks the requested relief because the DJI Phantom 2 Vision+ UAS , DJI Phantom 3

UAS or DJI Inspire 1 UAS do not require an airworthiness certificate in

accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Julian Everly Creative Ventures, Inc

. will ensure that the DJI Phantom 2 Vision+ UAS

, DJI Phantom 3 UAS or DJI Inspire 1 UAS are in airworthy condition based upon its compliance with the operating do cuments (i.e., Monthly Maintenance Log, and DJI Phantom 2 Vision+ UAS , DJI Phantom 3 UAS or DJI Inspire 1 UAS 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 Julian Everly Creative Ventures, Inc

. Seeks A nd The

Reason Julian Everly Creative Ventures, Inc

. Seeks Relief From Section

91.121. Relief from Section 91.12 1, entitled Altimeter settings , may be required to allow flight operations of the DJI Phantom 2 Vision+ UAS , DJI
Phantom 3 UAS or DJI Inspire 1 UAS , which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to
downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), Julian Everly Creative Ventures, Inc

. seek s the requested relief because the DJI Phantom 2 Vision+, DJI Phantom 3 or DJI Inspire 1 UAS ’s altimeter may be set on the ground to zero feet AGL, rather

than the local barometric pressure or field altitude, before each flight. Considering the limited alt itude 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 Phantom 2 Vision+

UAS , DJI Phantom 3 UAS or 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 establ ished prior to each flight,

and provides

.

5. Extent Of Relief Julian Everly Creative Ventures, Inc

. Seeks A nd The

Reason Julian Everly Creative Ventures, Inc

. Seeks Relief From Section 91.151(b). Relief from Section 91.151(b) entitled Fuel requirements f or flight in VFR conditions, is requested to the extent required to allow flights of the battery powered DJI Phantom 2 Vision+ UAS , DJI Phantom 3 UAS or DJI Inspire 1 UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duratio n 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. Julian Everly Creative Ventures, Inc

.14 seeks the requ ested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered DJI Phantom 2

Vision+ UAS , DJI Phantom 3 UAS or DJI Inspire 1 UAS will severely constrain the practicality of any aerial video or still photo flight operations

that Julian Everly Creative Ventures, Inc

. propo ses to conduct pursuant to
this Petition. Significantly, as set forth below, the technical specifications of

the DJI Phantom 2 Vision+ UAS , DJI Phantom 3 UAS or DJI Inspire 1 UAS

, the DJI Phantom 2 Vision+ UAS , DJI Phantom 3 UAS or DJI Inspire 1 UAS
operat ing documents, and Julian Everly Creative Ventures, Inc .’s proposed operating limitations, ensure that Julian Everly Creative Ventures, Inc

. . will safely operate the battery powered DJI Phantom 2 Vision+ UAS , DJI
Phantom 3 UAS or DJI Inspire 1 UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to f ly for a total duration of 13.5 minutes to the first point of intended landin g and, assuming normal cruising speed, to fly after

that f or at least 4.5 minutes.

6. Extent Of Relief Julian Everly Creative Ventures, Inc . Seeks And The

Reason Julian Everly Creative Ventures, Inc

. 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, Julian Everly Creative Ventures, Inc . requests relief from these Sections because DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJ I Inspire 1 UAS do not require airworthiness certificates. As set forth more fully below, the DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, Julian Everly Creative Ventures, Inc . will use

trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the UAS operati ng documents (i.e., the Julian Everly Creative Ventures, Inc . Aerial Operati ons Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS Instruction Manual). Furthermore, Julian Everly Creative Ventures, Inc . w ill

document and maintain all maintenance records for the DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS

.

D. The Reasons Why Granting Julian Everly Creative Ventures, Inc . Request

Would Be In The Public Interest; That Is, How It Would B enefit The Public

As A Whole.

Granting the present Petition will further the public interest by allowing Julian Everly Creative Ventures, Inc . to safely, efficiently, and economically perform aerial video and photography of, real estate, wedding films, sp ecial15 events, precision agriculture, land survey & appraisal, construction sites, equipment & roof inspections, film sets and landscape over certain areas of

the United States.

Additionally, use of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs will

dec rease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of Julian Everly Creative Ventures, Inc .’s proposed operation of the DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or 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 Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS are battery powered and serve as a safe, efficient, and econom ical 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 Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or 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 Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS do not require an airport to takeoff or land.

Likewise, a reduction of manned aircraft conduc ting 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 E fficiency Of The DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS

.

Conducting aerial acquisitions with the DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS

, instead of manned aircraft, will greatly benefit the public by drastically reducing the l evels 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 2 Vision+ UAS, DJI Phantom 3 UAS or 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 DJI16 Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or 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 m otors, rather than an internal combustion engine.

By using the DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or 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 completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS (weighing approximately 2 pounds 11 ounces and 6 pounds 7.5 ounces respectively, at their maximum gross weights with lengths of 16 inches and 17.3 inches respectively, widths of 16 inches and 17.7 inches respectively, and with no fuel on board), has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a len gth of 34 feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations With The DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS Will Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS will allow United States based companies, like Julian Everly Creative Ventures, Inc

. 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 Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UA S 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 Phantom 2 Vision+ U AS, DJI Phantom 3 UAS or DJI Inspire 1 UAS , companies such as Julian Everly Creative Ventures, Inc

. can17 remain competitive and profitable, and therefore, provide greater job stability

to e mployees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through commercial use of the DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS , provides a stable workforce that increases consumer spending; improves local, state, an d 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 b een conducted for decades, Julian Everly Creative Ventures, Inc

. ’s proposed operation of the DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS will not implicate any privacy issues. Specifically, the DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS will be operated only in compliance with operating documents (i.e., the Julian Everly Creative Ventures, Inc

. Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1

UAS Instruction Manual) which requires p roperty 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 Gr anting 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 Julian Everly Creative Ventures, Inc . Seeks Exemption.

1. Reasons Why The DJI Phantom 2 Vis ion+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS Meet The Conditions Of The FAA Modernizatio n 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, Julian Everly Creative Ventures, Inc

. ’s operation of the DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or 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. Pa rt 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 threat18 to national security. Specifically, FMRA Section 333 states the following, in
part:

(a) In General.

-- Notwithstanding any other requirement of this subtitle, and

not l ater than 180 days after the date of enactment of this Act, the Secretary

of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act.

(b) Assessment of Unmanned Aircraft Systems.

-- In making the 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 authoriz ation, 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, Julian Everly Creative Ventures, Inc

. submits

that DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI Phantom 2 Vision+ UAS,

D JI Phantom 3 UAS or DJI Inspire 1 UAS ; (b) the pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS Demonstrate Its Safe Characteristics

.

The DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS

do not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability.19 i. Technical Specifications Of The DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS

. The technical specifications of the DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS are set forth by

the DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS Specifications and Data Sheet, attached hereto as Exhibit A, B and C

.

ii. The DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1

UAS ’ Autonomous Flight And Navigation Modes Enable The UASs To

Remain Within A D efined Operational Area. The DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS may be operated in both

manual and fully autonomous flight modes. A complete description of the flight and navigational modes of the DJI Phantom 2 Vision+ UAS, D JI Phantom 3 UAS or DJI Inspire 1 UAS are provided at pages 23

- 41 of the DJI

Phantom 2 Vision+; pages 25

- 35 of the DJI Phantom 3 ; and p ages 12

- 18 and

45

- 52 of the DJI Inspire 1 User Manua ls, attached hereto as Exhibit D, E and

F

.

iii. The DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 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 Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Insp ire 1

UAS will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS do not reacquire control link data from the GCS, the UAs

will assume that the Control Link is los t and the UAs will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position

and shutdown. A complete description of the Failsafe Functions for the DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS are set forth at pages 32 through 34 of the DJI Phantom 2 Vision+ User Manual; pages 13 through 15 of the DJI Phantom 3 ; and for the DJI Inspire 1 at pages 13 through 15 of the DJI Inspire 1 User Manual, attached hereto as Exhibit D,E and F

.

iv. The DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1

UAS GCS And Its Operation. A complete description of the operatio n and specifications of the DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS GCS and flight control software is prov ided at pages 7 through 17 of the DJI Phantom 2 Vision+ User Manual; pages 32 through 43
of the DJI Phantom 3 User Manual ; and pages 24 through 34 of the DJI Inspire 1 User Manual. DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS User Manu als are attached hereto as Exhi bits D, E and F

.20 b. Flight Operations Of DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS Are Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer.

Julian Everly Creative V entures, Inc . 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 Phantom 2 Vision+ , DJI Phantom 3 and DJI Inspire 1 UAS . Additionally, a safety observer will assist all pilots during flight time

.

c. Flights DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1

UAS Will Be Conducted Pursuant To Specific Operating Limitations.

In seeking this exemption, Julian Everly Creative Ventures, Inc . proposes to

commer cially operate DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS for the special purpose of conducting aerial video and ph otography over certain areas of United States, pursuant to the following specific operating limitations:

1. Operation s authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UASs weighing less than 55 pounds maxi mum gross weight: DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS Unm anned Aircra ft Systems. Proposed operations of any other aircraft will require a new petition

or a petition to amend this grant.

2. UAS operations under this exemptio n will be limited to conducting operations for the purpose of aerial video and photograph y.

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 500 feet above ground level (AGL), as indicated by the proced ures specified in the operating

documents unless a special request i s 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, as sp ecified on the PIC’s FAA

- issued
airman medical certificate.

6. The use of first person view (FPV) by the PIC or safety observer (S O) is not
permitted.21 7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long a s 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 ass isting 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 op erations and made avai lable 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 contain ed in the grant of exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The
operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. If the operator determines that any update or revision would affect the basis upo n which the FAA granted the exemption, then the operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration Offi ce (AFS

- 80) may be contacted if questions arise regarding up dates or revisions to the operating documents.

10. Prior to each flight the PIC must inspect th e UAS to ensure that it is in a

condition for safe flight. If the inspection revea ls a condition that affects the safe operation of the UAS, the aircraft is pro h ibited 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

d ocumented in the aircraft records.

11. Any UAS that has undergone maintenance or alterations that affect the

UAS operation or flight characteristics, e.g. r eplacement of a flight critical
component, must undergo a functional test flight. The PIC who condu cts the functional test flight must make an entry in the aircraft records.22 12. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipm ent, not already covered in the
relevant sections of the operating documents.

13. The operator must follow the UAS man ufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. 14. The operator must carry out its maintenance, inspections, and record keeping requ irements, in accordanc e with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircraft r ecords, 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 entr y in the aircraft record of the

corrective action taken against discrepancies discovered between inspections.

17. The PIC must possess at least a private p ilot certificate and at least a

current third

- class medical certificate.

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrate s the ability to safely operate

the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emer gency maneuvers and maintaining appropriate distances from per sons, 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 exemptio n. However, traini ng operations

may only be conducted during dedicated trai ning sessions. During training, proficiency, and experience

- building flights, all persons n ot essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appr opriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119.

19. UAS operations may not be conducted during night, as defined in 1 4 C.F.R. § 1.1. All operations must be conduc ted under visual meteorological conditions (VMC). If flight at night is required, a special request will be made at the FAA office closest to proposed area of op erations. Flights under special visual flight rules (SVFR) are not authorized.

20. The UA may not operate within 5 nautica l miles of an airport reference point as denoted on a current FAA

- publis hed aeronautical chart unless a23 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 wit h 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 t han 2,000
feet horizontally from a cloud or when visibili ty is less than 3 statute miles
from the PIC.

22. If the UA loses communications or loses it s GPS signal, it must return to

a pre - determined location within the planned operating area and land or b e 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 i s enough power to fly at normal cruising speed to the inten ded landing point and land the UA with 25% battery power remaining.

25. The operator must obtain an Air Tr affic Organization (ATO) issued

Certificate of Waiver or Authorizatio n (COA) prior to conducting any operations under the grant of exemption. This CO A will also require the operator to request a Notice to Airman (N OTAM) not more than 72 hours in
advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO

issued COA in cluding class of airspac e, altitude level and potential transponder requirements.

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

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

27. Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal

Communications Commission (FCC) or other appropriate government oversight agency requirements.

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be

available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These doc ument s must be made available to the Administrator or any law enforcement official upon request.24 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 th e PIC from any moving device or

vehicle.

31. Flight operations must be condu cted 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. Bar riers or structures are present that sufficiently protect n onparticipating persons from the UA and/or debris in the eve nt of an accident. The operator

must ensure that nonparticipating persons rem ain under such protection. If a

situation arises where nonpa rticipating person s 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, v ehicles or structures where the

owner/controller of such vessels, veh icles or structure s has granted permission and the PIC has made a safety asse ssment 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 t rainees or essential persons do
not present an undue hazard to those persons per § 91.119(a).

32. All operations shall be conducted ov er 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 t hat transgresses the lateral or

vertical boundaries of the operational area a s defined by the applicable COA must be reported to the FAA's UAS Integr ation 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 T he Requirements Of Section 61.113(a)

And (b) Would Not Adversely Affect Safety.

Julian Everly Creative Ventures, Inc . submits that the equivalent level of safety established by Section 61.113(a) and (b) wi ll be maintained because no

PIC will be allowed to operate the DJI Phan tom 2 Vision+, DJI Phantom 3 and DJI Inspire 1 UASs unless that PIC has demonstrated, by meeting25 minimum flight

- hour and currency requir ements, that the PIC is able to safely operate the DJI Phantom 2 Vision+ o r 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 Julian Everly Creative Ventures, Inc .’s propo sed area of operations, and the o perating limitations set forth

- above; the p arallel nature of private pilot aeronautical knowledge requiremen ts to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI Phantom 2 Vision+ , DJI Phantom 3 and DJI Inspire 1 UAS

, Julian Everly Creative Ventures, Inc . sub mits that the

additional manned airmanship experience of a commercially certifi cated pilot

would not correlate to the airmanship skills necessary f or Julian Everly

Creat ive Ventures, Inc.’s specific proposed flight operations.

The FAA has previously granted relief from Sec tion 61.113(a) and (b) specific

to UAS, in circumstances similar, in all materi al respects, to those presented herein (e.g. Exemption Nos. 11062, 110 63 , 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 111 38, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

Julian Everly Creative Ventures, Inc . will not all ow any PIC to operate the

DJI Phantom 2 Vision+ , DJI Phantom 3 and DJI Inspire 1 UA S unless that

PIC has demonstrated, by meeting minimum flight

- hour requirements or the

DJI Phantom 2 Vision+ , DJI Phantom 3 and DJI Inspire 1 UAS UAS training and currency requirements, that the PIC is able to s afely operate the DJI

Phantom 2 Vision+ , DJI Phantom 3 and DJI Inspire 1 UAS in a manner

c onsistent with this exemption, i ncluding evasive and emergency maneuv ers and maintaining appropriate distances from people, vessels, vehicles and

structures.

Specifically, the PIC must have accu mulated and logg ed, 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 hour s of those hours as a UAS pilot operating the same make and model of UAS to be used for operation s under the exemption). In addi tion to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes).

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance w ith applicable regulations will

ensure an equivalent level of safety during Julian Everly Creative Ventures,

Inc .’ s proposed operations. The Administrator has he ld that prior documented26 flight experience that was obtained in compliance with applicable regu la tions would ensure safe operations, stating as follows:

In Exemption No. 11062, the FAA re quired that prior to conducting operations for the purpose of motion picture f ilming (or similar operations),

the PIC must have accumulated and logged, in a manner c onsistent with 14 CFR 61.51(b), 25 hours of total time as a UA S 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 mini mum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for oper ations 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 tim e may be
included in the 10 hours of multi

- rotor time and the 10 hours may be

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

- hour requirements in Exempti on 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 prio r documented flight experience that was obtained in compliance with appli cable regulations would satisfy this requirement. Training, proficiency, and experience

building flights can also be conducted under the grant of exemption t accomplish the required f light time. During training, proficiency, and experience

- building flights the PIC is req uired to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119.

Exemption No. 11138 at page 15. Accordingly, Julian Everly Creative Ventures, In c . wil l ensure safe operations by not allowing any PIC to operate the DJI Phantom 2 Vision+

, DJI Phantom 3 and DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 2 Vision+ , DJI Phantom 3 and DJI Inspire 1 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

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

The equivalent level of safety established by Section 91.7(a) will be

maintained because prior to every flight

, Julian Everly Creative Ventures,

Inc. will ensure that the DJI Phantom 2 Vision+ , DJI Phantom 3 and DJI Inspire 1 UAS in an airworthy condition based upon the UAS’s compliance27 w ith its operating documents and as stated in the conditions and limitations

her ein. 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, 11063, 11064, 1106 5, 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 level of safety established by Se ction 91.121 will be

mai ntained because the altitude informati on of the DJI Phantom 2 Vision+

, DJI Phantom 3 and DJI Inspire 1 UASs 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 p ath and altitude.

This altitude information, combined with Julian Everly Creative Ventures,

Inc .’ s operation of the DJI Phantom 2 Vision+ , DJI Phantom 3 and DJI Inspire 1 UASs within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information will be gener ated by GPS equipment installed onboard the aircraft.

Prior to each flight, a zero altitude initiation point is a utomatically established by the UASs at gro und level.

The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g.
Exemption Nos. 11062, 11063, 11064, 110 65, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely Affect Safety.

A grant of this exemption would ensur e an equivalent level of safety

established by 14 C.F.R. Section 91.151(b) a s a result of (1) the technical specifications of the DJI Phantom 2 Vision+ , DJI Phantom 3 and DJI Inspire

1 UASs ; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. A ccordingly, Julian Everly Creative Ventures, Inc . will ensure that it will safely operate the battery powered DJI

Phantom 2 Vision+ , DJI Phantom 3 and DJI Inspire 1 UASs during daylight hours in VFR conditions, 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.28 Here, as in Exemption No. 11109, the tech nical specifications of the DJI

Phantom 2 Vision+ , DJI Phantom 3 and DJI Inspire 1 UASs ; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Phantom 2 Vision+

, DJI Phantom 3 and DJI Inspire 1 UASs provide audible and visual warnings

to th e 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 critic ally low battery level, the DJI Phantom 2 Vision+ , DJI Phantom 3 and DJI Inspire 1

UASs will descend and land automatically.

Significantly, previous exemptions granted by the FAA concerning Section

91.151 establish that safety is not advers ely affected when the technical

characteristics and operating limitations of the U AS are considered. Relief has been granted for manned aircraft to op erate 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 material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11 064, 11065, 11066, 11067, 110 80, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

6. Reasons Why An Exemption Fr om The Requirements Of Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would N ot Adversely Affect Safety.

In seeking this exemption, Julian Everly Creative Ventures, Inc. submits

that the equivalent level of safety with regard to the regulatory maintenance

and alteration requirements established by Se ctions 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because Julian Everly Creative Ventures, Inc . will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating docume nts (i.e., the Julian Everly Creative Ventures, Inc . Aerial Operati ons Manual, Monthly

Maintenance Log, and Se ction 91.121 will be maintained because the altitude
informati on of the DJI Phantom 2 Vision+ , DJI Phantom 3 and DJI Inspire 1 UASs Instruction Manual). Furthermore, Julian Everly Creative Ventures,

Inc . will document and maintain all maintenance records for the Se ction

91.121 will be maintained because the altitude informati on of the DJI

P hantom 2 Vision+ , DJI Phantom 3 and DJI Inspire 1 UASs

.

Since the Se ction 91.121 will be maintained because the altitude informati on of the DJI Phantom 2 Vision+ , DJI Phantom 3 and DJI Inspire 1 UASs will29 be inspected as prescribed by the operating do cume nts, Julian Everly Creative Ventures, Inc. will maintain the equivalent level of safety

est ablished by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of th e the DJI Phantom 2 Vision+ , DJI Phantom 3 and DJI Inspire 1 UASs User

Manuals are attach ed hereto as Exhibit D, E and F.

Likewise, the exemption sought will not advers ely affect safety because Julian Everly Creative Ventures, Inc . will use trained technicians to perform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed by the operating documents.

Furthermore, the exemption sought would maintai n an equivalent level of safety established by Sections 91.407, 91.41 7(a) and 91.417(b), because all

maintenance of the DJI Phantom 2 Vision+ , DJI Phantom 3 and DJI Inspire

1 UASs will be performed by trained technicians. Mainte nance will be

documented and maintained utilizing the monthly maintenance log.

Significantly, previous exemptions granted by the FAA concerning Sections

9 1.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2) , and 91.417(a) & (b) establish that safety is not adversely affected when th e technical characteristics and operating limitations of the UAS are considered.

In consideration of Julian Everly Creative Ventures, Inc .’s proposed operating limitations, the operating documents, and the technic al aspects of

the DJI Phantom 2 Vision+ , DJI Phantom 3 and DJI Inspire 1 UASs, Julian Everly Creative Ventures, Inc . submits that safety w ill not be adversely affected by grant ing ex emption 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 herein (e.g. Exempti on 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 Section 333 of the F AA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21. 16 entitled Special Conditions, Julian Everly Creative Ventures, Inc

. requests that the FAA prescribe special

conditions for the intended operation of the DJI Phantom 2 Vision+ , DJI

Phantom 3 and DJI Inspire 1 UASs , which contain such safety standards

that the Administrator finds necessary to establish a level of safety equivalent to that established30 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), 91.40 9(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 vid eo and photography over certain
areas of the United States for compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to op erate 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 Phantom 2 Vision+ , DJI Phantom 3 and DJI Inspire 1 UASs

, since the airwort hiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropria te 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 t he aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety standards for t he a ircraft, aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent to that established in the regulations.

See 14 C.F.R. § 21.16. Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may pre scribe special conditions for Julian Everly Creative Ventures, Inc

. ’s intended operation of the DJI Phantom 2 Vision+

, DJI Phantom 3 and DJI Inspire 1 UASs

, which contain such safety standards

that the Administrator finds necessary to establish a level of safety equivalent to that established b y 14 C.F.R. Part 21, Subpart H, and 14 C.F.R

Section s 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

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

The Rules From Which Julian Everly Creative Ventures, Inc . Seeks Exemption:

Julian Everly Creative Ventures, Inc . seeks exemption fr om the requirements
of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.1 51(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).31 A Brief Description Of The Nature Of The Exemption Julian Everly Creative Ventures, Inc. Seeks:

This exemption will permit Julian Everly Creative Ventures, Inc. 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 Argu ments Available To Support Julian Everly Creative Ventures, Inc .’s Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of

2012 (FMRA) Section 333, which directs the Secretary of Transportation to

determine if certain UAS may operate safely in the NAS. As such, Julian Everly Creative Ventures, Inc .’s request for exem ption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above. FMRA Section 333 sets forth the requirements for considering

whether a UAS will create a hazard to use rs of the NAS or the public, or otherwise po se a threat to national secu rity; and further, provides the authority for such UAS to operate without airworthiness certification. As discussed in detail above, Julian Everly Creative Ventures, Inc . will operate
the DJI Phantom 2 Vision+ , DJI Phantom 3 and DJI Inspire 1 UASs safely in the NAS, without creating a hazard to users of the N AS, or the public, or

otherwise pose a threat to national security

.32 CONCLUSION

As set forth above, Julian Everly Creative Ventures, Inc. seeks an exemption

pu rsuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernizatio n and Reform Act of 2012, which will permit safe operation of the DJI Phantom 2

Vision+ , DJI Phantom 3 and DJI Inspire 1 UASs commercially, without an airworthine ss certificate, for the special purpose of conducting aerial videography and image processes over certain areas of the Untied States . By granting this Petition , the FAA Administrator will be fulfilling the Congressional mandate of t he FAA Modernization and Reform Act of 2012,

while also advancing the interests of the public, by allowing REC to safely, efficiently, and economically operate the DJI Phantom 2 Vision+ , DJI Phantom 3 and DJI Inspire 1 UAS commercially within the NAS.

WHEREFORE, in accordance with the Feder al Aviation Regulations and the

FAA Modernization and Reform Act of 2012, Section 333, REC respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R. §§ 91.9(b), 91.203(a), 91.203(b), 45.23(b), as well as the restricted category airworthiness certific ation standards specified in 14 C.F.R. § 21.185, including the requirement to have a certificate of

airworthiness issued for the DJI Phantom 2 Vision+ , DJI Phantom 3 and DJI Inspire 1 UASs

, as contemplated by 14 C.F.R. Part 21.

Dated: September 9 , 2015 Respectfully submitted, Julian Everly Creative Ventures, Inc

. /s/ Julian Everly Shervington Wright

_______________________________ Julian Everly Shervington Wright UAS Project Manager

2024 R Street, NW Washington, DC 20009 Tel: (202 ) 656

- 0622 Julian@julianeverly.com

Petitioner33 APPENDIX

– A

DJI	PHANTOM	2	VISION+	TECHNICAL	SPECIFICATIONS

Julian	Everly	Creative	Ventures,Inc .	only	utilizes	safe	and	reliable	UASs.	DJI	is	an	industry

leader	in	small UAS	production.	DJI	UASs	are	loaded	with	ground	breaking	software enabling	the	user to	set	parameters	which	will	not	allow	flight	into	controlled	airspace.

Parameters	can	also be	set	to	limit	flight	to	no	higher	than	a	predetermined	and	set altitude

as	well	as	limit flight	to	a	predetermined	and	set	distance.	In	addition,	DJI	software	provides

real

- time altitude	and	location	information	to	the	PI C	via	the	linked	monitor (smar phone/tablet devices)

1.1	DJI	Phantom	2	Vision+

1.1.1	Aircr aft 1.1.1.1	Supported	Battery

– DJI	5200mAH	LiPo	Battery 1.1.1.2	Weight	(Battery	&	Propellers	Included)

– 2lbs	11.810oz	(1242g) 1.1.1.3	Hover	Accuracy	(Ready	to	Fly)

– Vertical:	.8m;	Horizontal:	2.5m

1.1.1.4 Max	Yaw	Angular	Velocity

- 2000/s
1.1.1.5	Max	Tilt	Angel

- 350
1.1.1.6	Max	Ascent	Speed

– 6m/s 1.1.1.7	Max	Descent	Speed

– 2m/s

1.1.1.8	Max Flight	Speed

– 15m/s	(NOT	RECOMMENDED)

1.1 .2	Gimbal 1.1.2.1	Working	Current

– Static:	750mA;	Dynamic:	900mA 1.1.2.2	Control	Accuracy

- ±0.030
1.1.2.3	Controllable	Range

– Pitch:

- 900

- 00
1.1.2.4	Maximum	Angular	Speed

– Pitch:	900/s

1.1.3	Camera 1.1.3.1	Operating	Temperature	Range

- 320F

- 1040F	(00C

- 400C)

1.1.3.2	Sensor	Size

– 1/2.3”

1.1.3.3	Effective	Pixels

– 14M

1.1.3.4	Resolution

– 4384x3288 1.1.3.5	HD	Video	Recording

– 1080p30	&	720p 1.1.3.6	Recording	Field	of	View

- 1100/850

1.1.4	Transmitter 1.1.4.1	Operating	Frequency

– 5.728GHz

– 5.85GHz 1.1.4.2	Communication	Distance	(unobs tructed)

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

- - 93dBm

1.1.4.4	Transmitter	Power

– FCC	Compliance:	100mW 1.1.4.5	Working	Voltage

– 120mA@3.7V

1.1.5	Range	Extender 1.1.5.1	Operatin g	Frequency

– 2412

- 2462MHz 1.1.5.2	Communication	Distance	(unobstructed)

– 500

- 700m

1.1.5.3	Transmitter	Power

– 20dBm 1.1.5.4	Power	Consumption

– 2W34 APPENDIX

– B

DJI	PHANTOM	3	TECHNICAL	SPECIFICATIONS

Julian	Ev erly	Creative	Ventures,	Inc. only	utilizes	safe	and	reliable	UASs.	DJI	is	an	industry leader	in	small	UAS	production.	DJI	UASs	are	loaded	with	ground	breaking	software enabling	the	user	to	set	parameters	which	will	not	allow	flight	into	controlled	airspace

. Parameters	can	also	be	set	to	limit	flight	to	no	higher	than	a	predetermined	and	set	altitude as	well	as	limit	flight	to	a	predetermined	and	set	distance.	In	addition,	DJI	software	provides

real

- time	altitude	and	location	information	to	the	PIC	via	the	l inked	monitor	(smart phone/tablet	devices)

1.1	DJI	Phantom	3

1.1.1	Aircraft 1.1.1.1	Supported	Battery

– DJI	4480	mAh	LiPo	Battery 1.1.1.2	Weight	(Battery	&	Propellers	Included)

– 2lbs	13.15oz	(1280g) 1.1.1.3	Hover	Accuracy	(Ready	to	Fly)

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

- 200/s 1.1.1.5	Max	Tilt	Angel

- 35 1.1.1.6	Max	Ascent	Speed

– 6m/s 1.1.1.7	Max	Descent	Speed

– 2m/s 1.1.1.8	Max	Flight	Speed

– 15m/s	(NOT	RECOMME NDED)

1.1.2	Gimbal 1.1.2.1	Working	Current

– Static:	750mA;	Dynamic:	900mA 1.1.2.2	Control	Accuracy

- ±0.03 1.1.2.3	Controllable	Range

– Pitch:

- 90

- 0 1.1.2.4	Maximum	Angular	Speed

– Pitch:	90/s

1.1.3	Camera 1.1.3.1	Operating	Temperature	Range

- 32F

- 104F	(0C

- 40C)

1.1.3.2	Sensor	Size

– 1/2.3”

1.1.3.3	Effective	Pixels

– 12.4M

1.1.3.4	Resolution

– 4000x3000 1.1.3.5	HD	Video	Recording

– 4096x2160p	24/25,	3840x2160p	24/25/30 1.1.3.6	Recording	Field	of	View

- 94°	20mm

1.1.4	Transmitter

1.1.4 .1	Operating	Frequency

– 5.728

- 5.850GHz;	2.400

- 2.483GHz 1.1.4.2	Communication	Distance	(unobstructed)

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

- - 93dBm

1.1.4.4	Transmitter	Power

– FCC	Compliance:	100mW 1.1.4.5	Working	Voltage

– 120mA@3.7V

1.1.5	Range	Extender 1.1.5.1	Operating	Frequency

– 2412

- 2462MHz 1.1.5.2	Communication	Distance	(unobstructed)

– 2000m

1.1.5.3	Transmitter	Power

– 20dBm 1.1.5.4	Power	Consumption

– 2W35 APPENDIX

– C

DJI INSPIRE	1	TECHNICAL	SPECIFICATIONS

Julian	Everly	Creative	Ventures,	Inc.	only	utilizes	safe	and	reliable	UASs.	DJI	is	an	industry	leader	in	small	UAS production.	DJI	UASs	are	loaded	with	ground	breaking	software	enabling	the	use	to	set	parameters	which	wi ll not	allow	flight	into	controlled	airspace.	Parameters	can	also	be	set	to	limit	flight	to	no	higher	than	a predetermined	and	set	altitude	as	well	as	limit	flight	to	a	predetermined	and	set	distance.	In	addition,	DJI software	provides	real

- time	altitude	a nd	location	information	to	the	PIC	via	the	linked	monitor (smartphone/tablet	devices)

2.2	DJI	Inspire	1

2.2.1	Aircraft

2.2.1.1	Model

– T600 2.2.1.2	Weight	(Battery	Included)

– 6lbs	7.5291oz	(2935g)

2.2.1.3	Hoveri ng	Accuracy	(GPS	Mode)

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

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

- 350 2.2.1.6	Max	Ascent	Speed

– 5m/s 2.2.1.7	Max	Descent	Speed

– 4m/ s 2.2.1.8	Max	Speed

– 22m/s	(ATTI	mode,	no	wind

– NOT	RECOMMENDED) 2.2.1.9	Max	Flight	Altitude

– 4500m

2.2.1.10	Max	Wind	Resistance

– 10m/s 2.2.1.11	Max	Flight	Time

– Approximately	18	minutes

2.2.1.12	Motor	Model

– DJI	3510 2.2.1.13	Propeller	Model

– DJI	1345 2.2.1.14	Operating	Temperature	Range

– 140F	to	1040F	(

- 100C	to	400C)

2.2.1.15	Dimensions

– 17	1⁄4”	x	17	3⁄4”	x	12”

2.2.2	Gimbal

2.2.2.1	Model

– ZENMUSE	X3 2.2.2.2	Output	Power	(with	camera)

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

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

- ±0.030

2.2.2.5	M ounting

– Detachable 2.2.2.6	Controllable	Range

– Pitch:

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

– Pitch:

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

– Pitch:	1200/s;	Pan:	1800/s

2.2.3	Camera

2.2.3.1	Name

– X3

2.2.3.2	Model

– FC350

2.2.3.3	Total	Pixels

– 12.76M

2.2.3.4	Effective	Pixels

– 12.4M 2.2.3.5	Image	Max	Size

– 4000x3000 2.2.3.6	ISO	Range

– 100

- 3200

2.2 .3.7	Field	of	View

- 940

2.2.3.8	CMOS

– Sony	EXMOR	1/2.3” 2.2.3.9	HD	Video	Recording

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

FHD: 1920x1 080p24/25/30/48/50/60; HD:	1280x720p24/25/30/48/50/60 2.2.3.10	Operating	Temperature	Range

- 320F

- 1040F	(00C

- 400C)

2.2.4	Transmitter

2.2.4.1	Name

– C1 2.2.4.2	Operating	Frequency

– 5.728

- 5.850GHz;	2.400

- 2.483GHz 2.2.4.3	Communicating	Distance	(unobstructed)

– 2000m 2.2.4.4	Output	Power

– 9W

2.2.4.5 Operating	Temperature	Range

- 140F	to	1040F	(

- 100C	to	400C) 2.2.4.6	Battery

– 600mAh	LiPo	2S36 APPENDIX

– D DJI	Phantom	2	Vision	+ Manufacturer’s	User	Manual	See	A tt achment

‘ Julian _Everly_Creative_Ventures_Inc _Phantom_2_Vision+ _User_Manual_v1.2_en.pdf’

APPENDIX

– E DJI Phantom	3 Manufacturer’s	User	Manual	See	Attachment

‘ Julia n_Everly_Creative_Ventures_Inc _Phantom_3_Professional_User_Manual_v1_2 ’

APPENDIX

– F DJI Inspire	1	Manufacturer’s	User	Manual	See	Attachment

‘ Julia n_Everly_Creative_Ventures_Inc _Inspire_1_User_Manual_v1.0_en.pdf’

APPENDIX

– G

UAS	Check	L ist See	Attachment	‘Appendix

_ G_ UAS_checklists.pdf’

APPENDIX

- H

Client/Owner On

- Site Safety Acknowledgement	Form ‘ Appendix_H_Client_Owner_Safety ’