**UNITED STATES OF AMERICA**

**DEPARTMENT OF TRANSPORTATION**

**FEDERAL AVIATION ADMINISTRATION**

**WASHINGTON, DC** 

**IN THE MATTER OF THE PETITION FOR EXEMPTION OF:**



### Dronz **Plus LLC**

**FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF**

**TITLE 14 OF THE CODE OF FEDERAL REGULATION**

**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 THE**

**Yuneec Q500 Yuneec Q500+**  **DJI Inspire DJI Phantom 3**  **Advanced DJI Professional**  **DJI Phantom Standard**

**UNMANNED AIRCRAFT SYSTEM**

**PURSUANT TO SECTION 333 OF**

**THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112**

**- 95)** 

### TABLE OF CONTENTS

page

Glossary of Abbreviations ....................................................... 3 Summary

........................................................................... 4 Introduction and Interests of Petitioner ....................................... 5 Background ........................................................................ 6 Basis for Petition .................................................................. 7 Name and Address of Petitioner ......... ....................................... 8 Specific sections of 14 C.F.R from which DronzPlus LLC seeks Exemption .......................................................................... 9 The extent of relief DronzPlus LLC seeks relief and the reason DronzPlus LLC seeks relief........................................... 10 The reasons why granting DronzPlus LL C ’s request would be Inthe public’s interest........................................................... 11 The reasons why granting the exemptions would not adversel y affect Safety.............................................................................. 12 Summary that can be published in the Federal Register..................... 13 Any additional information, views, or arguments available to support DronzPlus LLC ’s request.............................................. Conclusion......................................................................... Attachments .............................................................................................. DJIPhantom manual (covers all models for operation) Exhibit A Yuneec manual (covers all models for operation) Exhibit B**GLOSSARY OF ABBREVIATIONS**

AGL Above Ground Level AOI Area of Interest ATC Air Traffic Control ATO Air Traffic Organization AV Aerial Vehicle C.F.R. Code of Federal Regulations COA Certificate of Authorization FAA Federal Aviation Administration FAR Federal Aviation Regulation GCS Ground Control Station GPS Global Positioning System LOL Loss of Link NAS National Airspace System NOTAM Notice to Airman PIC Pilot In Command Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333 SOP Standard Operating Procedures UA Unmanned Aircraft UAS Unmanned Aircraft System VFR Visual Flight Rules VL OS Visual Line of Site VMC Visual Meteorological Conditions VO Visual Observer VTOL Vertical Takeoff and Landing 4**SUMMARY**

**DronzPlus LLC** seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit **DronzPlus LLC** to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial photographs and video over certain public roadways and public areas of the United States.

**INTRODUCTION AND INTERESTS OF THE PETITIONER** The petitioner, **DronzPlus LLC**  is a licensed S.C. unmanned aircraft sales and testing business as listed with the Anderson S.C. Governmental Agencies. Sales, repairs, flight training, routine testing, and aerial photography are a part of the routine business operation process for DronzPlus LLC

. Primarily

, DronzPlus LLC is a sales and drone repair/fight training facility that provides extensive repairs and intensive drone flight operation training after the sale operation

. Secondary UAS operations include operation of UAS drones for aerial photography under 400 feet and line of sight for non

- commercial usage but for testing and demonstrations exc lusively.

**BACKGROUND** 

### DronzPlus LLC seeks an exemption to operate the DJI Phantom Product and Yuneec UAV Product UAS for compensation within the NAS. The DJI Phantom products & Yuneec Products are comprised of a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) and a transportable Ground Control Station (GCS). The DJI Phantom products & Yuneec Products have a maximum gross weight of approximately 6.6 pounds, while having a diameter of 31 in ches, height of 13 inches, and maximum speed of 23 mph. The DJI Phantom Products UA S & Yuneec Products UAS are equipped with four propellers, each being driven by an electric motor powered by Lithium Polymer battery

. The DJI Phantom Products UAV & Yuneec Products UAV that will be operated by DronzPlus LLC 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, DronzPlus LLC is pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012, Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereby petitions the Administrator to operate the DJI Phantom Products UAS & Yuneec Products UAS in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.4 05(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, DronzPlus LLC operation of the DJI Phantom Products & Yuneec Products UAS meets the conditions of Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 6

. Accordingly, DronzPlus LLC requests relief from Sections 91.405(a), 91.407( a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate. DronzPlus LLC submits that the requested relief is proper since an equivalent level o f safety will be ensured. DronzPlus LLC will use its authorized technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practicesprescribed in the manufacturer’s maintenance manual. Furtherm ore, DronzPlus LLC will document

and maintain all maintenance records for the DJI Phantom Products & Yuneec Products UAS. Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested by DronzPlus LLC to the extent necessary to allow a Pilot in Command (PIC) who has completed the DJI Phantom Products & Yuneec Products UAS training and currency requirements, to conduct the proposed UAS flight operations. DronzPlus LLC submits that the conditions and limitations set forth herein will ensure the safety of the NAS, as well as the safety

of persons or property

on the ground. DronzPlus LLC seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the DJI Phantom Products & Yuneec Products UAS does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, DronzPlus LLC submits that it will ensure that the DJI Phantom Products & Yuneec Products UAS is in an airworthy con dition, prior to every flight, by determining that the UAS is in compliance with the DJI Flight Manual & Yuneec Flight Manual , and that the aircraft is in a condition for safe flight. DronzPlus LLC also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , as the DJI Phantom Product and Yuneec UAV Product UA will not have a typical barometric altimeter onboard. However, altitude information of the DJI Phantom Produc t and Yuneec UAV Product UAS will be provided to the PIC via Global Positioning System (GPS) equipment and a 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 DronzPlus LLC operation of the DJI Phantom Product and Yuneec UAV Product UA within visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121. Additionally

, DronzPlus LLC seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions

. DronzPlus LLC submits that safety will not be affected by

terminating flights of the battery powered DJI Phantom Product and Yuneec UAV Product UA after 3 0 minutes of continuous flight, which would allow for five minutes of battery power remaining. In accordance with 14 C.F.R. § 11.81, DronzPlus LLC provides the following information in support of its petition for exemption:

**A. Name a nd Address Of The Pet** **itioner.** The name and address of the Petitioner is: DronzPlus LLC 

### Francisco Farray 304 Hopewell Ridge Anderson, South Carolina

**Contact; Francisco Farray**  **DronzPlus LLC B. The Specific Sections Of 14 C.F.R. From Which**  **DronzPlus LLC Seeks Exemption. 1.**  **DronzPlus LLC 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: 8 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 th at person, for compensation or hire, act as PIC of an aircraft. (a) 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. DronzPlus LLC**  **Seeks Exemption From The Requirements Of Section 91.7(a).** Section 91.7, entitled Civil a ircraft airworthiness , subsection (a), states the following: (a) No person may

operate a civil aircraft unless it is in an airworthy condition. **3. DronzPlus LLC**  **, Seeks Exemption From The Requirements Of Section 91.121.** Section 91.121, entitled Altimeter settings , subsection (a), states the following, in part: (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

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

-- (i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure; **4. DronzPlus LLC**  **S eeks Exemption From 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 landing and, assuming normal cruising speed, to fly after that for at least 20 minutes. **5. DronzPlus LLC**  **Seeks Exemption From The Requirem ent Of Section 91.405(a).**  Section 91.405, entitled Maintenance required, subsection (a), states the following: Each owner or operator of an aircraft

— (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.] **6. DronzPlus LLC**  **Seeks Exemption From The Requirements Of Section 91.407(a)(1).** Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration , subsection (a)(1), states the following: (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

-- (1) It has been approved for return to service by a person authorized under § 43.7 of this chapter[.] **7. DronzPlus LLC**  **Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2).**  Section 91.409, entitled Inspections , subsection (a), stat es the following: (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

-- (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by

a person authorized by

§ 43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.**8. DronzPlus LLC**  **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: 10 (1) Records of the maintenance, preventive maintenance, and alteration and records of the 100

- hour,

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

-- (i) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of completion of the work performed; and (iii) The signature, and certificate number of the person approving the aircraft for return to service. (2) Records containing the following information: (i) The total time in service of the airframe, each engine, each propeller, and each rotor. (ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the time since the last inspection required by the insp ection 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 revis ion 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 rec ords 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 be 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 return to servi ce. **C. The Extent Of Relief DronzPlus LLC**  **Seeks And The Reason**  **DronzPlus LLC Seeks The**  **Relief. 1. Extent of Relief**  **DronzPlus LLC Seeks And The Reason**  **DronzPlus LLC 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 certificate and a third

- class airman medical certificate, and who has completed the DJI training and currency requirements, to conduct the proposed UAS flight operations for compensation. This relief is requested s ince 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 employ ment if

- (1) The flight is only incidental to that business or employm ent; and (2) The aircraft does not carry

passengers or property for compensation or hire. As set forth more fully below, DronzPlus LLC submits that an equivalent level of safety will be maintained because no person who is not an employee of DronzPlus LLC will have operation rights to fly or maintain the DJI Phantom Products & Yuneec Products and fly the UAS in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures.Further, DronzPlus LLC submits that all flights of the DJI Phantom Products & Yuneec Products

conducted by the PIC pursuant to the grant of this Petition

- (1) will be incidental to DronzPlus LLC ’s business; and (2) will not carry passengers or property

for compensation or hire. 12 **2. Extent of Relief DronzPlus LLC**  **Seeks And The Reason DronzPlus LLC**  **Seeks Relief From Section 91.7(a).**  Relief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to the extent required to allow American Drones L.L.C. to determine that the DJI Phantom Product and Yuneec UAV Product UAS is in an airw orthy condition prior to every flight by ensuring that the UAS is in compliance with the DJI Flight Manual & Yuneec Flight Manual and that the aircraft is in a condition for safe flight. DronzPlus LLC seeks the requested relief because the DJI Phantom Product and Yuneec UAV Product UAS does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, DronzPlus LLC will ensure that the DJI UAS & Yuneec UAS is in an airworthy condition based upon its compliance with the operating documents (i.e., the DJI Flight Manual & Yuneec Flight Manual ) prior to every flight, and as stated in the conditions and limitations below. **3. Extent of Relief DronzPlus LLC**  **Seeks And The Reason DronzPlus LLC**  **Seeks Relief From Section 91.12**  **1.** Relief from Section 91.121 entitled Altimeter settings , may be required to allow flight operations of the DIJ UAS, which utilizes GPS equipment and a radio communications telemetry data link to downlink altitude information to the PIC from the UA to the GCS. As more fully set forth below, safety will be maintained as a result of the DIJ Phantom Product & Yuneec Product UA’s altitude readout via GPS equipment, and DronzPlus LLC ’s operation of the DJI Phantom Product and Yuneec UAV Product UA within visual line of sight, at or below 400 feet AGL. **4. Extent Of Relief DronzPlus LLC**  **Seeks And The Reason DronzPlus LLC**  **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 UA during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR) conditions, to continue for a total duration of 30 minutes, which will ensure that the UA will land with five minutes of battery power remaining. DronzPlus LLC seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered DJI UA & Yuneec UA will severely constrain the practicality of any aerial acquisition and research flight operations that DronzPlus LLC proposes to conduct pursuant to this Petition. Significantly, as set forth below, the technical specifications of the DJ I Phantom Product and Yuneec UAV Product UAS, the DJI Flight Manual & Yuneec Flight Manual , and DronzPlus LLC ’s proposed operating limitations, ensure that DronzPlus LLC will safely operate the battery powered DJ I UA & Yuneec UA during daylight hours in VFR conditions, for a total flight duration of 30 minutes, landing with five minutes of battery power remaining. **5. Extent Of Relief DronzPlus LLC**  **Seeks And The Reason DronzPlus LLC**  **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, DronzPlus LLC requests relief from these Sections because the DJI Phantom Product and Yune ec UAV Product UAS does not require an airworthiness certificate. As set forth more fully below, the DJI Phantom Product and Yuneec UAV Product UAS meets the conditions of Section 333 of the FMRA for operation without an airworthiness certificate. Accordingly, DronzPlus LLC will use authorized technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the manufacturer’s maintenance manual. Furthermore, DronzPlus LLC will document and maintain allmaintenance records for the DJI Phantom Product and Yuneec UAV Product UAS.

**D. The Reasons Why Granting DronzPlus LLC**  **’s Request Would Be In The Public**  **Interest; That Is, How It Would Benefit The Public As A Whole.** Granting the present Petition will further the public interest by allowing DronzPlus LLC to safely

, efficiently , and economically perform aerial photographs and video over public areas of the United States, commercially, in support of go vernment entities, flight training

, scientific studies, and sales demonstrations

. Additionally, use of the DJI Phantom Product and Yuneec UAV Product UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy

. Notably , the benefits of DronzPlus LLC ’s proposed operation of the DJI Phantom Product and Yuneec UAV Product UAS will be realized without implicating any privacy issues. **1. The Public Will Benefit From The Aerial Acquisition ed Photographs and Video**  **Per formed.**  DronzPlus LLC submits this Petition to commercially operate the DJI Phantom Product and Yuneec UAV Product UAS and perform aerial acquisition s and research throughout areas of the United States, in support of government entities

, private entities

, sales

, aerial mapping, tests of products, and flight instruction pursuant to UAV drone training . The DJI Phantom Product and Yuneec UAV Product UAS will provide safe, efficient, and economical aerial acquisition and research operations to further each of these fields, all of which are critical to the well

- being of the general public. The specific operations that DronzPlus LLC will perform with the DJI Phantom Product and Yuneec UAV Product UAS demonstrate how the requested exemption wil l directly benefit the above

referenced industries and the public. **2. The Public Will Benefit From Decreased Congestion Of The NAS.** The DJI Phantom 2 Vision UA is battery p owered and serves as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery

. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use Of a DJI Phantom Product and Yuneec UAV Product 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, conges tion around airports caused by arriving and departing aircraft will be reduced. The DJI Phantom Product and Yuneec UAV Product UA does not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial survey 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. **3. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 2 Vision UAS.** Conducting aerial acquisitions with the DJI Phantom Product and Yuneec UAV Product UAS, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial survey fli ght operations. By using battery

power and electric motors, the DJI Phantom Product and Yuneec UAV Product UAS produces no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six
cylinder internal combustion twin engine aircraft that are typically utilized for aerial acquisitions, while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The DJI Phantom Product and Yuneec UAV Product UA, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UA is propelled by battery powered electric motors, rather than an internal combustion engine. By using the DJ I Phantom Product and Yuneec UAV Product UAS to perform aerial acquisitions, the substantial risk to lif

e 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, th e DJ I Phantom Product and Yuneec UAV Product UA (weighing approximately 6.6 pounds at its maximum gross weight with a diameter of 31 inches, and with no fuel on board), has less physical potential for collateral damage to lifeand property on the ground, and in the air, compared to the manned aircraft that typically conduct aerial acquisitions (weighing approximately 6,500 pounds with a wingspan of approximately 40 feet, a length of 34 feet, and a fuel capacity of 180 gallons). **4. Performing**  **A erial**  **Acquisition Operations**  **With The**  **DJI Phantom**  **Product and**  **Yuneec UAV Product**  **UAS Will Benefit The Economy.** In addition to being safe and efficient, the DJI Phantom Product and Yuneec UAV Product UAS is also an economical alternative to using manned aircraft to conduct aerial acquisitions. As such, operation of the DJI Phantom Product and Yuneec UAV Product UAS will allow United States based companies, like DronzPlus L. L.C, 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 Product and Yuneec UAV Product UAS is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft. By operating the DJI Phantom Products & Yuneec Products UAS, companies such as DronzPlus L.L.C. can remain competitive and profitable, and therefore, provide grea ter 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 Product and Yuneec UAV Product UAS, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the United States and abroad. **5. There A**  **re No Privacy Issues.** Similar to the manned aerial acquisition flight operations that have been conducted for decades, DronzPlus L. L.C’s proposed operation of the DJI Phantom Product and Yuneec UAV Product UAS will not implicate any privacy issues. Specifically, the DJI Phantom Product and Yuneec UAV Product UAS will be operated only in rural areas, and in accordance with all Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F .R. § 91.119. Most significantly , the DJI Phantom Product and Yuneec UAV Product UA will not be operated closer than 500 feet to any person, vessel, vehicle, or structure, which is not directly involved in the operation. **E. The**  **Reasons Why**  **Granting The**  **Exe mption**  **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**  **DronzPlus L.L.C. Seeks Exemption.**  **1. Reasons Why The DJI Phantom**  **Products & Yuneec Products**  **UAS Meets The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333.**  In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, DronzPlus L. L.C’s operation of the DJI Phantom Products & Yuneec Products UAS meets the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Section 333 provides authority for a UAS to operate without airworthiness certific ation and sets forth requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part: (a) In General.

--Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system be fore 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

-- 18 (1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security; and(2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under

section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1). (c) Requirements for Safe Operation.

-- If the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establis h requirements for the safe operation of such aircraft systems in the national airspace system. In seeking this exemption, DronzPlus L. L.C submits that the DJI Phantom Product and Yuneec UAV Product UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by : (a) the characteristics of the DJI Phantom Product and Yuneec UAV Product UAS; (b) the pilot certification requirement; and (c) the specific operating limitations. **a. The Specifications Of The**  **DJI Phantom Product and Yuneec UAV Product UAS**  **Demonstrate Its Safe Characteristics.** The DJI Phantom Product and Yuneec UAV Product UAS does not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability. **i. Technical Specifications Of The DJI Phantom Product and Yuneec UAV Product**  **UAS.** The technical specifications of the DJI Phantom Product and Yuneec UAV Product UAS are set forth in Appendix C of the “Flight Manual For The DJI Phantom Products Unmanned Aircraft System (UAS),” & "Flight Manual For The Yuneec Products Unmanned Aircriaft System (UAS), attached hereto as Exhibit A. Exhibit A contains proprietary information and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b) 1

. 1 Exhibits to this Petition contain proprietary information, and in accordance with 14 C.F.R. § 11.35(b), are not to be included in the Federal Docket Management System (FDMS )

. **ii. The DJI Phantom Product and Yuneec UAV Product**  **UAS Autonomous Flight And Navigation Modes Enable The UAS To Remain Within A Defined Operational Area.**  A complete description of the autonomous modes and methods of navigation of the DJI Phantom Produc t and Yuneec Product UAS is provided at pages 2, 4, 5, and 10 of the “Flight Manual For The DJI Phantom Products & Yuneec Product Unmanned Aircraft System (UAS),” attached hereto as Exhibit A. Exhibit A contains proprietary information and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b). **iii. The DJI Phantom Product and Yuneec UAV Product**  **UAS Is Designed For Automatic Return To Launch In The Even**  **t Of Loss Of The Control Link Or Navigation.** A complete description of the DJI Phantom Product and Yuneec UAV Product UAS’s automatic return to launch function in the event of a break in communication or loss of telemetry data is set forth on pages 2, 9, and 10 of the “Flight Manual For The DJI Phantom Product and Yuneec UAV Product Unmanned Aircraft System (UAS),” attached hereto as Exhibit A. Exhibit A contains proprietary

information and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b). **b. Flight Operations Of The**  **DJI Phantom Product and Yuneec UAV Product UAS Are Limited**  **To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer.** DronzPlus L. L.C will only utilize certificated pilots who possess a valid airman medical certificate to act as a pilot in command (PIC) of the DJI Phantom Product and Yuneec UAV Product UAS. Additionally , a safety

observer will assist all pilots. The PIC must complete the DJI Phantom Product and Yuneec UAV Product UAS training and qu alification, as set forth in the “Flight Manual For The DJI Phantom Product and Yuneec UAV Product Unmanned Aircraft System (UAS),” attached hereto as Exhibit A. Exhibit A contains proprietary information and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b). 20 **c. Flights Of The DJI Phantom Product and Yuneec UAV Product**  **UAS Will Be Conducted Pursuant To Specific Operating Limitations.**  In seeking this exemption, DronzPlus LLC proposes to commercially operate the DJI Phantom Product & Yuneec Product UAS for the special purpose of conducting aerial acquisitions over publicareas of United States, pursuant to the following specific operating limitations:

1) Operations authorized by this grant of exemption are limited to the following aircraft described in the operator’s manual which is a quad rotor aircraft weighing less than 10 pounds: DJI Phantom Products Unmanned Aircraft System & Yuneec Products Unmanned Aircraft System

. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant. 2) The UA may

not be flown at an indicated airspeed exceeding 25 MPH & the UA must be operated
at an altitude of no more than 400 feet above ground level (AGL), as indicated by the procedures specified in the operator’s manual. All altitudes reported to ATC must be in feet AGL. 3) The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate. 4) All operations must utilize a visual obser ver (VO). The VO may be used to satisfy the VLOS requirement, as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. 5) The operator’s manual and this grant of exemption must be maintained and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operator’s manual, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operator’s manual. The operator may update or revise its operator’s manual. 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. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for amendment to their exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if que stions arise regarding updates or revisions to the operator’s manual. 6) Prior to each flight the PIC must inspect the UAS to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records. 7) Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics (e.g. replacement of a flight critical component), must undergo a functional test flight in accordance with the operator’s manual. The PIC who conducts the functional test flight must make an entry in the UAS aircraft records of the flight. The requirements and procedures for a functional test flight and aircraft record entry must be added to the operator’s manual. 8) The preflight inspection must account for all discrepancies, i.e. inoperable components, items, or equipment, not covered in the relevant preflight inspection sections of the operator’s manual. 9) The operator must follow the manufacturer’s UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements, with particular attention to flight critical components that may not be addressed in the manufacturer’s manuals. 10) DronzPlus LLC must carry out their maintenance, inspections, and record keeping requirements in accordance with the operator’s manual. Maintenance, inspection, and alterations must be noted in the aircraft logbook, including total flight hours, description of work accomplished, and the signature of the authorized UAS technician or PIC returning the UAS to service. 11) DronzPlus LLC UAS technicians must receive and document training referenced in the operator’s manual. 12) Each UAS operated under this exemption must c omply with all manufacturer System and Safety Bulletins.13) DronzPlus LLC maintenance personnel must make a record entry in the UAS logbook or

equivalent document of the corrective action taken against discrepancies discovered between inspections. 15) The PIC must possess at least a private pilot certificate and a third

- class airman medical certificate. The PIC must also meet the flight review requirements specified in 14 C.F.R. § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 16) The operator may not permit any PIC to operate unless that PIC has demonstrated, through the training and currency requirements set forth in the operator’ s manual, that the PIC is able to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 22 17) 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). Flights under special visual flight rules (SVFR) are not authorized. 18) The UA may not operate within 5 nautical miles of the airport reference point as denoted on a current FAA

- published aeronautical chart. The UA may not operate within 3 nautical miles from any city or densely

populated area. 19) The UA may

not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 20) If the UAS loses communications or loses its GPS signal, the UA must return to a pre

- determined location within the pri vate or controlled

- access property and land, or be recovered in accordance with the operator’s manual. 21) The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operator’s manual. 22) The PIC is prohibited from beginning a UAS flight unless (considering wind and forecast weather conditions and assuming normal cruising speed) there is enough power to fly to the first point of intended landing prior to utilizing battery reserve power. 23) The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under this grant of exemption. This COA will also require the operator to request issuance of a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. 24) All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 C.F.R. Part 47, and have i dentification (N

-Number) markings in accordance with 14 C.F.R. Part 45, Subpart C. Markings must be as large as practicable. 25) 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. 26) The documents required under 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control S tation of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request. 27) The UA must remain clear and yield the right of way to all other manned aviation operation s and activities at all times. 28) The UAS may

not be operated by

the PIC from any

moving device or vehicle. 23 29) The UA may not be operated over congested or densely populated areas. These areas include but are not limited to the yellow areas depicte d on World Aeronautical Charts (WAC), Sectional Aeronautical Charts (Sectionals), or Terminal Area Charts (TAC). However, aeronautical charts may not reflect pertinent local information. Ultimately, it is the PIC’s responsibility to maintain the minimum s afe altitudes required by § 91.119. 30) Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than the PIC or VO), vessels, vehicles, and structures unless:a. Barriers or structures are present that sufficiently protect nonparticipating persons from debris in the

event of an accident. The operator must ensure that nonparticipating persons remain under suchprotection. If a situation arises where nonparticipating persons leave such protection and are

within 500 feet of the UA, flight operations must cease immediately and/or; b. the aircraft is operated near vessels, vehicles or structures where the land owner/controller has granted p ermission and the PIC has made a safety assessment of the risk of operating closer to those objects and;

c. operations near the PIC or VO do not present an undue hazard to the PIC or VO, per § 91.119(a). 31) All operations shall be conducted over private or controlled

- access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained prior to the beginning of every flight. 32) Any incident, accide nt, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA’s UAS Integration Office (AFS

- 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. **2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety.**  DronzPlus LLC 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 Product and Yuneec UAV Product UAS unless that PIC has demonstrated, through the DJI Phantom Products UAS or Yuneec Product UAS training and currency requirements, that the PIC is able to safely operate the DJI Phantom Product and Yuneec UAV Product UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 24 Considering DronzPlus LLC ’ 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 necessary to safely operate the DJI Phantom Product and Yuneec UAV Product UAS, DronzPlus LLC submits that the additional manned airmanship experience of a comm ercially certificated pilot would not correlate to the airmanship skills necessary for DronzPlus LLC ’s specific proposed flight operations. The DJI Phantom Products UAS was the subject of a previous Grant of Exemption from Section 61.113(a) and (b). In Ex emption No. 11109, the FAA granted relief from Section 61.113(a) and (b) concerning the operation of the DJI Phantom Product and Yuneec UAV Product UAS by a PIC holding a private pilot certificate and third class airman medical certificate, based upon the following analysis: The FAA has analyzed Clayco’s proposed operation and has determined that it does not differ significantly

from the situation described in Grant of Exemption No. 11062 (Astraeus Aerial). Clayc o plans to operate over private property with controlled access in the NAS. Given: 1) the similar nature of Clayco’s proposed operating environment to that of Astraeus’, 2) the parallel nature of private pilot aeronautical knowledge requirements to those of commercial requirements [ref: Exemption No. 11062], and 3) the airmanship skills necessary to operate the UAS, the FAA finds that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship ski lls necessary for Clayco’s specific proposed operations. Therefore, the FAA finds that a PIC holding a private pilot certificate and a third

- class airman medical certificate is appropriate for the proposed operations. With regard to the airmanship skills n ecessary to operate the UAS (item #3 stated above), Clayco has proposed a 100 hour training program and 6 month currency requirements. The conditions and limitations below stipulate that Clayco may not permit any PIC to operate unless that PIC has demonstrated through Clayco’s training and currency requirements that the PIC is able to safelyoperate the UAS in a manner consistent with how the UAS will be operated under this exemption,

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

See Exemption No. 11109 at 12. Additionally , 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. 25 Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138). As in Exemption No. 11109, DronzPlus LLC will not allow any PIC to operate the DJI Phantom Product and Yuneec UAV Product UAS unless that PIC has demonstrated through the DJI Phantom Product and Yuneec UAV Product UAS training and currency requirements, that the PIC is able to safely

operate the DJI Phantom Product and Yuneec UAV Product UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. A complete description of the DJI Phantom Product and Yuneec UAV Produc t UAS Training and Qualification requirements is set forth at page 5 of the “Flight Manual For The DJI Phantom Product and Yuneec UAV Product Unmanned Aircraft System (UAS),” attached hereto as Exhibit A. Exhibit A contains proprietary information and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b). **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 becaus e prior to
every flight, DronzPlus LLC will ensure that the DJI Phantom Product and Yuneec UAV Product UAS is in an airworthy condition based upon the DJI Phantom Product and Yuneec UAV Product UAS’s compliance with its operating documents (i.e., the DJI P hantom Products Flight Manual), and as stated in the conditions and limitations herein. The DJ I Phantom Product and Yuneec UAV Product UAS was the subject of a previous Grant of Exemption from Section 91.7(a) (Exemption No. 11109). 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, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138). 26 **4. Reasons 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 Product and Yuneec UAV Product UA will be provided to the PIC via GPS equipment and a radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with DronzPlus L. L.C’s operatio n of the DJI Phantom Product and Yuneec UAV Product UA within visual line of sight, at or below 400 feet A GL, 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 flight, a zero altitude initiation point will be established and confirmed for accuracy by the UAS PIC. The DJI Phantom Product and Yuneec UAV Product UAS was the subject of a previous Grant of Exemption from Section 91.121 (Exemption No. 11109). Additionally, 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, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138).**5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would**

**Not Ad versely Affect Safety.**  A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJI Phantom Product and Yuneec UAV Product UAS; (2) the limitatio ns on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, DronzPlus LLC will ensure that it can safely operate the battery

powered DJI Phantom Product and Yuneec UAV Product UA during daylight hours, in VF R conditions, for a total flight duration of no more than 30 minutes, resulting in a landing with five minutes of battery power remaining. In a previous Petition for Exemption, in which an operator was utilizing a DJI Phantom Product and Yuneec UAV Product UAS identical in all material respects to the DJI Phantom Product and Yuneec UAV Product UAS

, DronzPlus LLC proposes to use, the FAA granted an exemption from the requirements of Section 91.151, stating as follows: In the event that the UAS should run out of power, it would simply land within the access controlled operating area. Given its weight and construction material, the risks are less than contemplated by the current regulation. Prior relief has been granted for manned aircraft to operate at less than the minimums prescribed in § 91.151 (a), including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS

- specific relief has been granted an Exemption Nos. 8811, 10808, and 10673 for day time, Visual Flight Rules (VFR) conditions. The DJI Phantom Product and Yuneec UAV Product provides a battery

failsafe that commands the UA’s return to the launch point when critical minimum voltage is reached. The UAS batteries provide approximately 35 minutes of powered flight. The FAA agrees with Clayc o’s proposal to limit UAS flights to not more than 30 minutes, or enough battery reserve to ensure that the UAS lands at the ground station with at least 20% battery reserve power, whichever happens first. Given the limitations on its proposed operations and the location of those proposed operations, a reduced minimum power reserve for flight in daylight VFR conditions is reasonable. See Exemption No. 11109 at 15. Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom Product and Yuneec UAV Product UAS; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure that DronzPlus LLC may safely operate the battery

powered DJI Phantom Product and Yuneec UAV Product UA during daylight h ours in VFR conditions for a total duration of not more than 30 minutes, and landing with five minutes of battery power remaining. Significantly , previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely

affected when the technical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreov er, 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. 288811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138). **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, DronzPlus LLC submits that the equivalent 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 DronzPlus LLC will use its trained technicians to perform maintenance, alterations, or preventive maintenance on the unmanned aircraft system using the methods, techniques, and practices prescribed in the manufacturer’s maintenance manual. Furthermore, DronzPlus LLC will document and maintain all maintenance records for the DJI Phantom Product and Yuneec UAV Product UAS.Since the DJI Phantom Product and Yuneec UAV Product UAS will be inspected as prescribed

by the manufacturer’s maintenance manual, DronzPlus LLC will maintain the equivalent level of safety established by

Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). The Flight Manual For The DJI Phantom Product and Yuneec UAV Product UAS sets forth airworthiness requirements for the UA, including preflight and post fli ght inspections, as well as scheduled maintenance in four categories: daily, weekly, monthly, and yearly. Likewise, the exemption sought will not adversely affect safety because DronzPlus LLC will perform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed by the manufacturer’s maintenance manual. The Flight Manual For The DJI Phantom Product and Yuneec UAV Product UAS details procedures for each component of the UA, including the components of the propulsion system, avionics system, and
payload system. A complete description of the DJI Phantom Product and Yuneec UAV Product UAS airworthiness and maintenance requirements is set forth at page 6 of the “Flight Manual For The DJI Phantom Products Unmanned Aircraft 29 System (UAS),” & "Flight Manual For The Yuneec Product (UAS)", attached hereto as Exhibit A. Exhibit A contains proprietary information and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b). 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 Product and Yuneec UAV Product UAS will be performed by DronzPlus LLC trained technicians, who will document and maintain maintenance records for the DJI Phantom Product and Yuneec UAV Product UAS. Significantly , previous exemptions granted by the FAA concerning the DJI Phantom Product and Yuneec UAV Product UAS and Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered. In Exemption No. 11109, the FAA stated the following concerning the DJI Phantom Product and Yuneec UAV Product UAS and the DJI Phantom Product and Yuneec UAV Product Flight Manual: Regarding the petitioner’s requested relief from 14 C.F.R 91.405 (a) Maintenance required

, 91.407(a)(1) O

peration after maintenance, preventive maintenance, rebuilding, or alteration

, 91.409(a)(2) Inspections , and 91.417(a) and (b) Maintenance records , the FAA has determined that relief from § 91.409(a)(1) is also necessary because it is an alternate inspecti on requirement of § 91.409(a)(2). The FAA has carefully evaluated the petitioner’s request and determined that cause for granting the exemption is warranted. The FAA notes that the petitioner’s DJI Phantom Product and Yuneec UAV Product UAS Flight Manual c ontain daily , preflight, monthly and yearly

checks for the UAS. The FAA finds that adherence to the DJI Phantom Product and Yuneec UAV Product Flight Manual, as required by the conditions and limitations below, is sufficient to ensure that safety is not adversely affected. In accordance with the petitioner’s UAS maintenance, inspection, and recordkeeping requirements, the FAA finds that exemption from 14 C.F.R. 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b) is warranted subject to the conditions and limitations below. In consideration of DronzPlus LLC ’s proposed operating limitations, the most recent DJI Phantom Product and Yuneec UAV Product Flight Manual, and the technical aspects of the DJI Phantom Product and Yuneec UAV Product UAS

, DronzPlus LLC 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 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).**7. The FAA May Prescribe Any Other 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

, DronzPlus LLC requests that the FAA prescribe special conditions for the intended operation of the DJI Phantom Product and Yuneec UAV Product 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 UAS for the limited purpose of conducting aerial acquisitions over certain rural areas of the United States. 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 operation of the D JI Phantom Product and Yuneec UAV Product 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 the 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 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. 31 Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for DronzPlus LLC ’ s intended operation of the DJI Phantom Product and Yuneec UAV Product 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). **F. A Summary That Can Be Published In The**  **Federal Register, stating:**  **The Rules From Which DronzPlus LLC**  **Seeks Exemption:** DronzPlus LLC 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 DronzPlus LLC**  **Seeks:** This exemption will permit DronzPlus LLC to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial acquisitions and rese arch over certain public areas of the United States. **G. Any Additional Information, Views, Or Arguments Available To Support DronzPlus LLC**  **’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, DronzPlus LLC ’s request for exemption may b e gr anted 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 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 indetail above, DronzPlus LLC will operate the DJI Phantom Product and Yuneec UAV Product 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. **CONCLUSION** As set forth herein, DronzPlus LLC seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI Phantom Product and Yuneec UAV Product UAS commercially, without an airworthiness certificate, for the limited purpose of conducting aerial acquisitions over certain public 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 DronzPlus LLC to safely , efficiently , and eco nomically operate the DJI Phantom Product and Yuneec UAV Product UAS commercially within the NAS. **WHEREFORE** , in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, DronzPlus LLC 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 DronzPlus LLC to operat e the DJ I Phantom Product and Yuneec UAV Product UAS commercially for the purpose of conducting aerial acquisitions

, training

, sales, research

, testing, demonstrations, and aerial photography over certain public areas of the United States.

Dated: December 6th 2015 Submitted on behalf of DronzPlus LLC



### Francisco Farray President DronzPlus LLC 304 Hopewell Ridge Anderson South Carolina 29621

Email 

### frank@carolinadronz .com