UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No.

_

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

WILLIAM J CAMP FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL

OPERATION OF DJI Phantom 3 Professional UNMANNED AIRCRAFT

SYSTE MS PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112

- 95)

Submitted on June 28, 2015

WILLIAM J. CAMP

76321 OVERSEAS HWY ISLAMORADA, FL 33036

305

- 879

- 8243

RGEP RODUCTIONS @GMAIL .COMTABLE OF CONTENTS

Page

GLOSSARY OF ABBREVIATIONS

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

SUMMARY

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

INTRODUCTION AND INTERESTS OF PETITIONER

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

BACKGROUND

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

BASIS FOR PETITION

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

NAME AND ADDRESS OF PETITIONER

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

THE SPECIFIC SECTIO NS OF 14 C.F.R. FROM WHICH WILLIAM J CAMP

SEEKS EXEMPTION

........................................................................ 8

THE EXTENT OF RELIEF WILLIAM J CAMP SEEKS AND THE REASON WILLIAM

J CAMP SEE KS THE RELIEF....................................... 12

THE REAS ONS WHY GRANTING WILLIAM J CAMP ’S REQUEST

WOULD BE IN THE PUBLIC INTEREST

.......... ................................ .............. 15THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

ADVERSELY AFFECT SAFETY

................................ ................................ ......... 18

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER

............. 33

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS

AVAI LABLE TO SUPPORT WILLIAM J CAMP ’S REQU EST............ 34

CONCLUSION

................................ ................................ ................................ ................... 35

APPENDICES........................................................................................3 6

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 Certi ficate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

MSL Mean Sea Level NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In C ommand

Section 333 Faa Modernization and Reform act of 2012 (FMRA)

SO Safety Observer

SOP Standard Operating Proceedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Sight

VMC Visual Meterological Co nditions

VTOL Vertical Takeoff and LandingSUMMARY

WILLIAM J CAMP 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 Unman ned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit WILLIAM J CAMP to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography of construction sites, real estate, farmland, and landscape over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

WILLIAM J CAMP provides his clients with expertise and knowledge in advanced technologies and solutions to increase efficiency, productivity and effectiveness. WILLIAM J CAMP has completed Flight Training Ground School and logged over 45

hours of flying experience. He has over 10 years recreational/hobby experience in all aspects of aerial video and photograph y. The objective of WILLIAM J CAMP and his aerial operations is to safely provide high quality imaging for a variety of commercial, public, and residential uses, specifically targeting:

• General aerial still photos

• Commercial Media Applications i.e.

Weddi ng Videography and Business

Promotional Video

• Wildlife population surveys

• Real Estate marketing

• Aerial inspections of public and private

structures.

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 3 Professional UASs

WILLIAM J CAMP seeks an exemp tion to operate DJI Phantom 3 Professional for compensation orhire within the NAS. The DJI Phantom 3 Professional is a vertical takeoff and landing

(VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing

electronic tablet or smart pho ne systems. The DJI Phantom 3 Professional has a maximum gross weight of approximately 2 pounds 11 ounces, while having a length of 16 inches,

width of 16 inches, height of 8 inches, and a maximum speed of approximately 29 knots.

The DJI Phantom 3 Professi onal UA is equipped with four main rotors, driven by Lithium Polymer battery powered electric motors.

The DJI Phantom 3 Professional UA that will be operated by WILLIAM J CAMP will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft

, as well as 14

C.F.R Part 47, Aircraft Registration , and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking

.

BASIS FOR PETITION

Petitioner, WILLIAM J CAMP , 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 3 Professional UA in the National Airspac e 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 a rea associated with the

unmanned aircraft a nd its operation, WILLIAM J CAMP ’s operation of the DJI Phantom 3 Professional UA 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, WILLIAM J CAMP 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 c ertificate.

WILLIAM J CAMP submits that the requested relief is proper since an equivalent level of safety will be ensured. WILLIAM J CAMP will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the U ASs using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Professional Instruction Manual). Furthermore, WILLIAM J CAMP will document and maintain all maintenance records for

th e DJI Phantom 3 Professional UA.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private PilotPrivileges and Limitations: Pilot in Command , is requested by WILLIAM J CAMP to the

extent necessary to allow a Pilot in Command (PIC) h olding 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 3 Professional UA in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles, and structures.

WILLIAM J CAMP seeks relief from Section 91.7(a), entitled Civil Aircraft

Airworthiness

, because the DJI Phantom 3 Professional UA does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such,

WILLIAM J CAMP submits that he will ensure that the DJI Phantom 3 Professional UA

is in an airworthy condition , prior to every flight, by determining that the UA is in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Professional Instruction Manual), and that the aircraft is in a condition for safe flight.

WILLIAM J CAMP al so seeks an exemption from the requirements of Section 91.121,

entitled Altimeter Settings , as the DJI Phantom 3 Professional UA will not have a typical barometric altimeter onboard. However, altitude information of the DJI Phantom 3

Professional UA will b e provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA

to the GCS for active monitoring of the flight path. This altitude information, combined

with WILLIAM J CAMP ’s ope ration of th e DJI Phantom 3 Professional UA within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section

91.121.

Additionally, WILLIAM J CAMP seeks an exemption from the requirements of Section 91.151(b), entit led Fuel Requirements for Flight in VFR Conditions

. WILLIAM J CAMP submits that safety will not be affected by operation of the DJI Phantom 3 Professional

UA during daylight hours in visual meteorological conditions (VMC) under visual flight

rules (VFR), with enough battery power to fly for a total duration of approximately 13.5

minutes to the first point of intended landing and, assuming normal cruising speed, to fly

after that for at least 4.5 minutes.

In accordance with 14 C.F.R. § 11.81, WILLIAM J CAMP provides the following information in support of his petition for exemption:Name And Address Of The Petitioner.

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

WILLIAM J. CAMP

76321 OVERSEAS HWY ISLAMORADA, FL 33036

305

- 879

- 8243

RGEP RODUCTIONS @GMAIL .COMThe Specific Sections Of 14 C.F.R. From Which WILLIAM J CAMP

Seeks Exemption.

1. WILLIAM J CAMP Seeks Exemption From The Requirements Of Section 61.113(a) And (b).

Section 61.113, entitled Private Pilot Privileges and Limitations: Pi lot 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.

2. WILLIAM J CAMP 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. WILLIAM J CAMP 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 o perating 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 alo ng 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. WILLIAM J CAMP Seeks Exemption From The Requirements Of Section 91.151(b).

Section 91.151, entitled Fuel Requirements for Flig ht 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 landi ng and, assuming normal cruising speed, to fly after that for at least 20 minutes.

5. WILLIAM J CAMP 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 thi s chapter[.]

6. WILLIAM J CAMP 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 opera te 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. WILLIAM J CAMP 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 wit h part 21 of this chapter.

1. WILLIAM J CAMP 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, prog ressive, 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 th e 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 i n 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 requir ed to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next
acti on 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 per iods prescribed:

(1) The records specified 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 b e retained

and transferred with the aircraft 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 ret urn to service.The Extent Of Relief WILLIAM J CAMP Seeks And The Reason

WILLIAM J CAMP Seeks The Relief.

1. Extent Of Relief WILLIAM J CAMP Seeks And The Reason
WILLIAM J CAMP Seeks Relief From 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 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 me t certain flight

- hour and currency requirements, to conduct the proposed UAS flight operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation

or hire.

As set forth more fu lly below, WILLIAM J CAMP submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the DJI Phantom 3 Professional UA unless that PIC has met certain flight

- hour and currency requirements, demonstrating that t he PIC is able to safely operate either the DJI Phantom 3 Professional

UA 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, WILLIAM J CAMP submits that all flights of the DJI Phantom 3 Professional UA, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to
WILLIAM J CAMP ’s business; and (2) wi ll not carry passengers or property for compensation or hire.2. Extent Of Relief WILLIAM J CAMP Seeks And The Reason

WILLIAM J CAMP Seeks Relief From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to the e xtent required to allow WILLIAM J CAMP to determine that the DJI Phantom 3 Professional

UA is in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., Monthly Maintenance Log and DJI

Phantom 3 Professional Instruction Manual).

WILLIAM J CAMP seeks the requested relief because the DJI Phantom 3 Professional

UA does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, WILLIAM J CAMP will ensure th at the DJI Phantom 3

Professional UA is in airworthy condition based upon its compliance with the operating

documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Professional Instruction Manual) prior to every flight, and further, determine that the aircraft is in condition for safe flight, as stated in the conditions and limitations below.

3. Extent Of Relief WILLIAM J CAMP Seeks And The Reason

WILLIAM J CAMP Seeks Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter Settings, ma y be required to allow flight operations of the DJI Phantom 3 Professional UA, which utilizes 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), WILLIAM J CAMP seeks the requested relief because the DJI Phantom 3 Professiona l UA’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 altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent nece ssary 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 3 Professional UA is equipped with a barometric

pressure sensor and GPS equi pment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the PIC with altitude

information of the UA on the heads

- up display of the GCS.4. Extent Of Relief WILLIAM J CAMP Seeks And The Re ason
WILLIAM J CAMP 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 allow flights of the battery powered DJI Phantom 3

Professional UA duri ng daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

WILLI AM J CAMP seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered DJI Phantom 3 Professional UA

will severely constrain the practicality of any aerial video or still photo flight opera tions that WILLIAM J CAMP proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the DJI Phantom 3 Professional UA, the DJI Phantom 3 Professional and WILLIAM J CAMP ’s proposed operating limitat io ns, ensure that WILLIAM J CAMP will safely operate the battery powered DJI Phantom 3 Professional UA during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a

total duration of 19 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least

4.5 minutes.

5. Extent Of Relief WILLIAM J CAMP Seeks And The Reason

WILLIAM J CAMP 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, WILLIAM J CAMP requests relief from

these Sections because the DJI Phantom 3 Professional UA does not require airworthiness certificates. As set forth more fully below, the DJI Phantom UAS meets the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly,

WILLIAM J CAMP will use trained techn icians 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 Monthly Maintenance Log, and DJI Phantom 3 Professional Instruction Manual). Furthermore, WILLIAM J CAMP will

document and maintain all maintenance records for the DJI Phantom 3 Professional UAS.The Rea sons Why Granting WILLIAM J CAMP’s Request Would Be In

The Public Interest; That Is, How It Would Benefit The Public As A Whol e.

Granting the present Petition will further the public interest by allowing WILLIAM J CAMP to safely, efficiently, and economically perform aerial video and photography of construction sites, real estate, and landscape over certain areas of

the United States.

Additionally, use of the DJI Phantom 3 Professional UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the

benefits of WILLIAM J CAMP ’s proposed operation of the DJI Phantom 3 Profes sional

UAS will be realized without implicating any privacy issues.

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

The DJI Phantom 3 Professional UA is battery powered and serves as a safe, efficient, and

economical alternative to the manne d aircraft traditionally utilized to obtain aerial imagery. By reducing the number of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJI Phantom 3 Professional UAS would reduce the

number of manned aircraft in the NAS and 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 depart ing aircraft will be reduced. The DJI Phantom 3 Professional UA does not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations.

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

Phantom 3 Professional UAS.

C onducting aerial acquisitions with the DJI Phanto m 3 Professional UAS, instead of

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

and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and el ectric motors, the DJI Phantom 3 Professional 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 p hotography, while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The DJI Phantom 3 Professional UA, whilereducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the

UAs are propelled by battery

- pow ered electric motors, rather than an internal combustion engine.

By using the DJI Phantom 3 Professional UAS to perform aerial acquisitions, the

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

associated with traditiona l 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 Professional UA (weighing approximately 2 pounds 11

ounces at its maximu m gross weight with a length of 16 inches and widths of 16 inches and with no fuel on board), has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically

conduct simil ar 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 Phantom 3 Professional UAS Will Benefit T he Economy.

In addition to being safe and efficient, the DJI Phantom 3 Professional UA is also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom 3 Professional UAS will allow Un ited States based companies, like WILLI AM J CAMP , 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 a viation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery powered DJI Phantom 3 Professional UAS is one such technology

that not only allows companies greater operationa l flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional

manned aircraft.

By operating the DJI Phantom 3 Professional UAS, c ompanies such as WILLIAM J

CAMP

, can remain competitive and pro fitable, and therefore, provide greater job stability to employees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through

commercial use of the DJI Phantom 3 Professional U AS, provides a stable workforce

that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive

both in the United States and abroad.4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for d ecades, WILLIAM J CAMP ’s proposed operation of the DJI Phantom 3 Professional
UAS will not implicate any privacy issues. Specifically, the DJI Phant om 3 Professional UAS will be operated only in compliance with operating documents (i.e., The Monthly Maintenance Log, and DJI Phantom 3 Professional Instruction Manual) which requires property owner involvement as well as local law enforcement notificatio n, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or

How The Exemption Would Provide A Level Of Safet y At Least Equal To That Provided By The Rule From Which WILLIAM J CAMP Seeks Exemption.

1. Reasons Why The DJI Phantom 3 Professional UA Meets The

Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333.

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

unmanned aircraft an d its operation, WILLIAM J CAMP ’s operation of the DJI Phantom 3

Professional UAS meets the conditions of FMRA Section 333, and will not require an airworthiness certific ate 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, o r otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part:

(a) In General.

-- Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secr etary 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 capabili ty, 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, certifica te 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 determin es 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 e xemption, WILLIAM J CAMP submits that the DJI Phantom 3 Professional UAS can operate safely in the NAS pursuant to FMRA Section 333, as

demonstrated by: (a) ) the characteristics of the DJI Phantom 3 Professional UA; (b) the pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The DJI Phantom 3 Professional UAS

Demonstrates Its Safe Characteristics.

The DJI Phantom 3 Professional UAS does not create a hazard to users of the NAS or the public, or otherwise pose a th reat to national security considering its size, weight, speed, and operational capability.

i. Technical Specifications Of The DJI Phantom 3 Professional UAS

The technical specifications of the DJI Phantom 3 Professional UAS are set forth by the

DJI Phantom 3 Professional User Manual, attached hereto as Appendix A.

ii. The DJI Phantom 3 Professional UAS Autonomous Flight

And Navigation Modes Enable The UAS To Remain Within A Defined Operational Area.The DJI Phantom 3 Professional UAS may be operated in both ma nual and fully

autonomous flight modes. A complete description of the flight and navigational modes of the DJI Phantom 3 Professional UAS is provided at pages 25

- 35 of the DJI Phantom 3 Professional User Manual, attached hereto as Appendix A.

iii. The DJI Phant om 3 Professional 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 3 Professional UA will remain stationary, in flight, for 3 seconds or mo re. If, after 3 seconds, the DJI Phantom 3

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

that the Control Link is lost and the UA will return to the home position (i.e., failsafe mode) via GPS, and will descend to th e takeoff position and shutdown.

A complete description of the Failsafe Function of the DJI Phantom 3 Professional UAS

is set forth at pages 27 through 29 of the DJI Phantom 3 Professional User Manual, attached hereto as Appendix A.

iv. The DJI Phantom 3 Profe ssional GCS And Its Operation.

A complete description of the operation and specifications of the DJI Phantom 3 Professional GCS and flight control software is provided at pages 32 through 43 of the

DJI Phantom 3 Professional User Manual. DJI Phantom 3 Pr ofessional User Manuals are attached hereto as Appendix A.

b. Flight Operations Of DJI Phantom 3 Professional UAS Are

Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer.

WILLIAM J CAMP will be the only person to act as a p ilot in command (PIC) of the DJI Phantom 3 Professional UAS. Additionally, a safety observer will assist him during flight

time.

c. Flights Of DJI Phantom 3 Professional UAS Will Be Conducted

Pursuant To Specific Operating Limitations.In seeking this exemp tion, WILLIAM J CAMP proposes to commercially operate DJI

Phantom 3 Professional UAS for the special purpose of conducting aerial video and photography over certain areas of the United States, pursuant to the following specific operating limitations:

1. Operat ions authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: DJI Phantom 3 Professional Unmanned Aircraft System. Proposed oper ations of any

other aircraft will require a new petition or a petition to amend this grant.

2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photography.

3. The UA may not be flown at an indi cated 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 procedures specified in the operating documents unless a special request is made and approved by ATC. All

alt itudes reported to ATC must be in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the P IC’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 may be used to satisfy the VLOS requirement as long as the PI C 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

de signation 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 ot her ground based obstacles/obstructions and is not permitted to operate the camera or other

instruments.

9. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption take precedence

and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. If the operator determines that 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 (AFS

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

10. Prior to each fli ght the PIC must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been perfo rmed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly

documented in the aircraft records.

11. Any UAS that has undergone maint enance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight criticalcomponent, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraft recor ds.

12. The pre

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

13. The operator must follow the UAS manufacturer’s aircra ft/component, maintenance, overhaul, replacement, inspection, and life limit requirements.

14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alt erations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature of the authorized person returning the UAS to service.

15. Each UAS opera ted under this exemption must comply with all manufacturer Safety Bulletins.

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

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

third

- class medical certificate.

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

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

91.119.

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will be made at the FAA office closest to proposed area of o perations. 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 a irport’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 t he 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 begi nning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 25% battery power remaining.

25. The operator must obtain an Air Traffic Organiz ation (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 t han 48 hours prior to the operation. All operations shall be conducted in accordance with 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.

27. Before conduc ting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.

28. The documents required (fewer than 14 C.F.R . 91.9 and 91.203) must be available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

29. The 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 (pe rsons 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 aircra ft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it d oes not present an undue hazard, and;

c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a).

32. All operations shall be conducted over private or controlled

- access propert y 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 transgres ses 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 We b site: www.ntsb.gov.2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety.

WILLIAM J CAMP 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 Phantom 3 Professional UAS unless that PIC has demonstrated, by meeting minimum flight

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

evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles, and structures.

Considering WILLIAM J CAMP ’s proposed area of operations and the operating

limitations set forth

- above, the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062), and the airmanship skills nece ssary to safely operate the DJI Phantom 3 Professional UAS,

WILLIAM J CAMP submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for

WILLIAM J CAMP ’s specific pr oposed 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, 110 80, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

WILLIAM J CAMP will not allow any PIC to operate the DJI Phantom 3 Professional UAS unless that PIC has demonstrated, by meeting minimum flight

- hour requirements or

the DJI Phantom 3 Professional UAS training and currency requirements, that the PIC is

able to safely operate the DJI Phantom 3 Professional 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 a s a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes).

As in Exemption N os. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during WILLIAM J CAMP ’s proposed operations. The Administrator has held that prior doc umented flight experience that was obtained in compliance withapplicable 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 oper ations 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 model of UAS to be used for operations under the exemption. For clarification, the FAA considers these minimum h our 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 be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight

- hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the

skills necessar y to safely conduct the petitioner’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance 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

- building flights the PIC is required to operate the UA with appropriate

distances in accordance with 14 C.F.R 91 .119.

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, WILLIAM J CAMP will ensure that t he DJI Phantom 3

Professional UAS is in an airworth y condition based upon the UAS’ compliance with its operating documents and as stated in the conditions and limitations herein.

Additionally, the FAA has previously granted relief from Section 91.7(a) spec ific 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, 11157, 11158, 11159, 11160, 11161).

4. Rea sons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety.The equivalent level of safety established by Section 91.121 will be maintained because

the altitude information of the DJI Phantom 3 Professional UA will b e 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 informatio n, combined with WILLIAM J CAMP ’s operation of th e DJI

Phantom 3 Professional UA within visual line of sight, at or below 500 feet AGL, will

ensure a level of safety equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to each fli ght, a zero

altitude initiation point is automatically established by the UASs at ground level.

The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. E xemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

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

A g rant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJI Phantom 3 Professional UAS; (2) the limitations on the proposed flight operations; and ( 3) the

location of the proposed flight operations. Accordingly, WILLIAM J CAMP will ensure

that it will safely operate the battery

- powered DJI Phantom 3 Professional UA during daylight hours in VFR conditions, with enough battery power to fly for a total du ration 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.

Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 3
Professional UAS, the limitati ons 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 3

Professional UAS provides aud ible and visual warnings to the PIC at the GCS when the UA 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 leve l, the DJI Phantom 3 Professional UAS will descend and

land automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics andoperating lim itations 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 material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 1 1158, 11159, 11160, 11161).

6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety.

In seeking this exemption, WILLIAM J CAMP submits that the equiv alent level of safety with regard to the regulatory maintenance 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
because WILLIAM J CAMP will use trained technicians to perfor m maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e. The Monthly Maintenance Log and DJI Phantom 3 Professional Instruction Manual). Furthermore, WILLIAM J CAMP will

document and maintain all maintenance records for the DJI Phantom 3 Professional UAS.

Since the DJI Phantom 3 Professional UAS will be inspected as prescribed by the operating documents, WILLIAM J CAMP 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 Phantom 3 Professional User Manual is attached hereto as Appendix A; a copy of the DJI Phantom 3 Professional UAS Maintenance LOG is attached hereto as Appendix B.

Likewi se, the exemption sought will not adversely affect safety because WILLIAM

J CAMP will use trained technicians to perform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed by the operating d ocuments.

Furthermore, the exemption sought 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 Phantom 3 Professional UAS 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 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not
advers ely affected when the technical characteristics and operating limitations of the UAS

are considered.In consideration of WILLIAM J CAMP ’s proposed operating limitations, the operating

documents, and the technical aspects of the DJI Phantom 3 Professional UAS, WILLIAM

J CAMP submits that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted relief specific to UAS in circumsta nces 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, 11157, 11158, 11159, 11160, 11161).

7. The FAA May Prescribe Any Ot her Conditions For Safe Operation.

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, WILLIAM J CAMP requests that the FAA prescribe special conditions for the intended o peration of the DJI Phantom 3 Professional 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 §§ 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 UA for the limited purpose of conducting aerial video and photography over certain areas of the United St ates for compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness 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 op eration of the DJI Phantom 3 Professional 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 Co nditions, 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 th e 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 the aircraft, aircraft eng ine 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 prescribe special condi tions for Leading Edge’s intended operation of the DJI Phantom 3

Professional 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), 91.121, 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 WILLIAM J CAMP Seeks Exemptio n:

WILLIAM J CAMP 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 WILLIAM J

CA MP Seeks:

This exemption will permit WILLIAM J CAMP 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 Argumen ts Available To Support WILLIAM J CAMP ’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, WILLIAM J CAMP ’s request for exemption may be granted pursuan t 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 t o users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate
without airworthiness certification.

As discussed in detail above, WILLIAM J CAMP will operate the DJI Phantom

3 P rofessional UAS safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.

Listed in Appendix C is a link to a brief article outlining the environmental

benefits of commercial use of a UAS.CONCLUSION

As set forth herein, WILLIAM J CAMP 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 Phantom 3

Professional UAS commerci ally, 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 WILLIAM J

CAMP to safely, efficiently, and economically operate the DJI Phantom 3 Professional UAS commercially within the NAS.

WHEREFORE , in accordance wit h the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, WILLIAM J CAMP respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91 .7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit WILLIAM J CAMP to operate the DJI Phantom 3 Professional UAS commercially for the purpose of conducting aerial video and photography over certain areas of the United States.

Dated: June28

, 2015

Respectfully submitted,

WILLIAM J CAMP

WILLIAM J. CAMP

76321 OVERSEAS HWY ISLAMORADA, FL 33036

305

- 879

- 8243

RGEP RODUCTIONS @GMAIL .COMApendix

http://download.dji

inn ovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.2_en.pdf

A. DJI Phantom 3 Professional User ManualB. Proposed Maintenance Log

C. Link to a Supportive Article

http://rotordrone mag.com/can

- drones

- save - planet/ S er v i c e D ate Ai r c ra f t

Hours It e m s p e r f o r m ed It e m s Ne e d i ng A t t e n t i on