1 UNITED STATES OF AM ERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:
KAREN B FERRANTE (“APPLICANT”) 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, and Yuneec Typhoon Q500 ( “ AIRCRAFT ” )
UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF
THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112

- 95)

Submitted on October 2 1 , 2015

Karen B. Ferrante
7B Sunflower Court Ayer, MA 01432 ( 978 ) 314

- 4032 karen@pointerpals.com2 TABLE OF CONTENTS

Page

GLOSSARY OF ABBREVIATIONS 3

SUMMARY AND INTRODUCTION AND INTERESTS OF APPLICANT 4

BACKGROUND 5

BASIS FOR PETITION 6

NAME AND ADDRESS OF PETITIONER 7

SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH
APPLICANT SEEKS EXEMPTION 8

EXTENT OF RELIEF APPLICANT SEEKS AND THE REA SON
APPLICANT SEEKS SAID R ELIEF 1 2

REASONS WHY GRANTING APPLICANT ’S REQUEST
W OULD BE IN THE PUBLIC INTEREST 15

REASONS WHY THE AIRCRAFT MEET THE CONDITIONS OF THE FAA
MODERNIZATION AND REFORM ACT OF 2012 (FMRA) Section 333 17

REASONS WHY EXEMPTION S FROM THE STATED REQUIREMENTS
W OULD NOT ADVERSELY AFFECT SAFETY 24

THE FAA MAY PRESCRIBE ANY OTHER CONDITIONS FOR
SAFE OPERATION 26

SUMMARY THAT CAN BE PUBL ISHED IN THE FEDERAL REGISTER 27

ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS
AVAILABLE TO SUPPORT APPLICANT ’S REQUEST 27

CONCLUSION AND LINKS 283 GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level
AOI Area of Interest
ATC Air Traffic Control
ATO Air Traffic Organi zation
AV Aerial Vehicle
CFR Code of Federal Regulations
COA Certificate of Authorization
FAA Federal Aviation Administration
FAR Federal Aviation Regulation
GCS Ground Control Station
GPS Global Positioning System
LOL Loss of Link
NAS National Airspace System
NOTAM Notice to Airman
PIC Pilot In Command
Section 333 F AA Mod and Re form Act of 2012 (FMRA) Section 333
SO Safety Observer
SOP Standard Operating Procedures
UA V Unmanned Aircraft Vehicle
UAS Unmanned Aircraft System
VFR Visual Flight Rules
VLOS Visual Line of Site
VMC Visual Meteorological Conditions
V TOL Vertical Takeoff and Landing4 SUMMARY

Karen B. Ferrante ( “ APPLICANT ” ) 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
A P P LICANT to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography of construction sites, real estate, and landscape over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

APPLICANT intends to provide clients with a service they othe rwise do not have easy

access to in their daily business practices. I n addition to APPLICANT’S flight expertise and knowledge in advanced technologie s, APPLICANT is a Private Pilot with 286 flight hours in a single engine plane , which includes 191 High Performance hours. APPLICANT
holds a valid U.S. driver ’ s license issued by the state of Massachusetts. APPLICANT is an active amateur photographer and videographer (including underwater photography) for
both recreational and hobby

. APPLICANT desires to move her skills and knowledge of flying into a new direction, to provide high quality imaging for a variety of commercial, public, and residential uses, specifically targeting:

• Real

- estate marketing

• Construction sites before and after

• Appraisals

• Motion Picture Filming

• Aerial acquisitions for inspections of public and private structures.

• Building Inspection operations5 BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 3

, and 

### Yuneec Typhoon Q500 (“ AIRCRAFT ”)

APPLICANT seeks an exemption to operate AIRCRAFT for compensation or hire within
the NAS. The AIRCRAFT are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic visual screens

.

The DJI Phantom 3 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of approximately 30 knots.

The 

### Yuneec Typhoon Q5 0 0 has a maximum gross weight of 7 pound s , a length of 17 inches, width of 17 inches, height of 10 inches, and a maximum speed of approximately
30 knots.

The AIRCRAFT are equipped with four main rotors; driven by Lithium Polymer battery powered electric motors.

The AIRCRAFT will be operated by APPLICANT and 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

.6 BASIS FOR PETITION

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

In consideration of the speed, weight, size, and limited operating area associated with the
UAV and its operation, APPLICANT meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certif icate in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, APPLICANT 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 ai rcraft with an airworthiness certificate.

APPLICANT submits that the requested relief is proper since an equivalent level of safety
will be ensured. APPLICANT will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents of the AIRCRAFT

. Furthermore, APPLICANT will document and maintain all maintenance records for the
AIRCRAFT.

Relief from certain requirements of S ection 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command , is requested by APPLICANT to the extent necessary to allow a Pilot in Command (PIC) with significant experience in the field of
UAV’s holding FAA ground school c ertificate, 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 AIRCRAFT in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

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

, because the AIRCRAFT do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, APPLICANT submits that s he will ensure the
AIRCRAFT are in an airworthy condition, prior to every flight, by determining that the UASs are in compliance w ith the AIRCRAFT’S operating documents and that the
AIRCRAFT are in a condition for safe flight.

APPLICANT also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , as the AIRCRAFT will not have a typical barometric alt imeter onboard. However, altitude information of the AIRCRAFT will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This7 altitude information, combined with APPLICANT operation of the AIRCRAFT within vis ual line of sight, at or below 4 00 feet AGL, will ensure a level of safety equivalent to Section
91.121.

Additionally, APPLICANT seeks an exemption from the requ irements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions

. APPLICANT submits that safety will not be affected by operation of the AIRCRAFT during daylight hours in visual meteorological conditions (VMC) under visual flight rule s (VFR), with enough battery power to fly for a total duration of approximately 15 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 5
minutes.

In accordance with 14 C.F.R. § 11.81, APPLICANT provides the following information in support of its petition for exemption:

N AME AND ADDRESS OF PETITIONER

The name and address of the APPLICANT is:



### Karen B. Ferrante
7B Sunflower Court Ayer, MA 01432 karen@pointerpals.com (978) 314

- 40328 SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH
APPLICANT S EEKS AN EXEMPTION

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

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

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

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

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or emp loyment 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. APPLICANT 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. APPLICANT 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; or9 (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 depart ure.

4. APPLICANT Seeks 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 cond itions 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. APPLICANT Seeks Exemption From The Requirement Of Section 91.405(a).

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

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

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

Section 91.407, entitled Operat ion 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 ha s been approved for return to service by a person authorized under § 43.7 of this chapter[.]

7. APPLICANT 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; or10 (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.

8. APPLICANT Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b).

Section 91.417, entitled Maintenance records , subsections (a) and (b), state the following:

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

(1) Records of the maintenance, preventive maintenance, and alteration
and records of the 100

- hour, annual, progressive, and other required or

a pproved 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 wor k 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 servi ce 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 inspection program under which the aircraft and its appliances are maintained.

(v) The c urrent 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 w hen the next action is required.11 (vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in 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 chapte r shall be retained until the defects are repaired and the aircraft is approved for return to service.12 EXTENT OF RELIEF APPLICANT S EEKS
AND THE REASON APPLICANT SEEKS SAID RELIEF

1. Extent Of Relief APPLICANT Seeks And The Reason APPLICANT 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 met certain flight

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

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or 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 fully below, APPLICANT submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the AIRCRAFT unless that PIC has met certain flight

- ho ur and currency requirements, demonstrating that the PIC is able to safely operate either the AIRCRAFT in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaini ng appropriate distances from people, vessels, vehicles
and structures.

Further, APPLICANT submits that all flights of AIRCRAFT conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to APPLICANT’S business; and (2) will
not ca rry passengers or property for compensation or hire.

2. Extent Of Relief APPLICANT Seeks And The Reason APPLICANT Seeks Relief From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to the extent required t o allow APPLICANT to determine that the AIRCRAFT are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., the Operations Manual s , Maintenance Log s , and Instruction Manual s ).

APPLICANT seeks the requested relief because the AIRCRAFT do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore,
APPLICANT will ensure that the AIRCRAFT are in airworthy condition based upon its compliance with the op erating documents (i.e., the Operations Manual s and Instruction
Manual s) prior to every flight, and further, determine that the AIRCRAFT are in condition for safe flight, as stated in the conditions and limitations below.13 3. Extent Of Relief APPLICANT Seek s And The Reason APPLICANT Seeks
Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings , may be required to allow flight operations of the AIRCRAFT , which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any
altitude information co ncerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), APPLICANT seeks the requested relief because the
AIRCRAFT ‘S altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure o r field altitude, before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply with the applicable conditions and limitations stated below. As more fully set forth h erein, an equivalent level of safety will be
maintained since the AIRCRAFT are equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and prov ides the PIC with altitude information of the UA on
the heads

- up display of the GCS.

4. Extent Of Relief APPLICANT Seeks And The Reason APPLICANT 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 AIRCRAFT during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR),
for a total duration of 15 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 5 minutes. APPLICANT seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered AIRCRAFT will severely constrain the practicality of any aerial video or still photo flight operations that APPLICANT proposes to conduct pursuant
to this Petition.

Significantly, as set forth below, the technical specifications of the AIRCRAFT operating documents, and APPLICANT proposed operating limitations, ensure that APPLICANT w ill safely operate the battery powered AIRCRAFT during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total duration of 15 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 5 minutes.

5. Extent Of Relief APPLICANT Seeks And The Reason APPLICANT Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91 .409(a)(1) & (a)(2), And 91.417(a) & (b).14 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, APPLICANT requests relief from these
Sections because the AIRCRAFT do not require airworthiness certificates. As set forth more fully below, the AIRCRAFT meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, APPLICANT will use trained technicians to perform maintenance, alte rations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the AIRCRAFT operating documents (i.e., Operations Manual s
, and Instruction Manual s ). Furthermore, APPLICANT will
document and maintain all maintenanc e records for the AIRCRAFT.15 REASONS WHY GRANTING APPLICANT ’S REQUEST
WOULD BE IN THE PUBLIC INTEREST.

Granting the present Petition will further the public interest by allowing APPLICANT 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 AIRCRAFT will decrease congestion of the NAS, reduce pollutio n, and provide significant benefits to the economy. Notably, the benefits of APPLICANT proposed operation of the AIRCRAFT will be realized without implicating any privacy
issues.

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

The AIRCRA FT are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a AIRCRAFT 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 operatin g in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The AIRCRAFT do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would r esult 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 AIRCRAFT.

Conducting aerial acquis itions with the AIRCRAFT , 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 an d electric motors, the AIRCRAFT produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically utilized for aerial video and photography, while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The AIRCRAFT, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAs are propelled by battery powered electric motors, rather than an int ernal combustion engine.

By using the AIRCRAFT to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from
the l ack of flight crew members located onboard the aircraft, the AIRCRAFT (weighing approximately less than 8 pounds respectively, at their maximum gross weights with lengths of less than 18 inches respectively, widths of less than 18 inches respectively,16 an d with no fuel on board), has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan o f approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations With The AIRCRAFT w ill Benefit The Economy.

In addition to being safe and efficient, the AIRCRAFT are also an econom ical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the
AIRCRAFT will allow United States based companies, like APPLICANT , to remain competitive and contribute to growth of the U.S. economy. Specifically, w ith 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
AIRCRAFT 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 AIRCRAFT

, APPLICANT’S business can remain competitive and profitable, and therefore, provide greater job stability, which will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through
commercial us e of the AIRCRAFT 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 decades, APPLICANT’S proposed operation of the AIRCRAFT will not implicate any privacy issues. Specifically, the AIRCRAFT will be operated only in compliance with operating documents (i.e., Operations Manual s and Instruction Manual) which requires property owner involvement, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.17 REASONS WHY THE AIRCRAFT MEET THE CONDITIONS OF THE FAA

MODERNIZATION AND REFORM ACT OF 2012 (FMRA) Section 333.

In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, APPLICANT operation of the AIR CRAFT meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requir ements 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 requirem ent 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 before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by
section 334 of this Act.

(b) Assessment of Unmanned Aircraft Systems.

-- In making the determination under subsection (a), the Secretary shall determine, at a minimum

--

(1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspac e 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 unmann ed 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 establ ish requirements for the safe operation of such aircraft systems in the national airspace system.

In seeking this exemption, APPLICANT submits that the AIRCRAFT can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the
AIRCRAFT ; (b) the pilot certification requirement; and (c) the specific operating limitations.

a. Specifications Of The AIRCRAFT Demonstrate Its Safe Characteristics.18 The AIRCRAFT do not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability.

i. Technical Specifications o f AIRCRAFT

.

The te chnical specifications of the AIRCRAFT are set forth in the AIRCRAFT User
Manuals

, whose latest Links are documented at the end of this Petition

.

ii. The AIRCRAFT Flight And Navigation Modes Enable The AIRCRAFT To Remain Within A Defined Operational Area.

The AIRCRAFT may be operated in both manual and fully autonomous flight modes. A complete description of the flight and navigational modes of the AIRCRAFT are provided
in the User Ma nuals, whose latest Links are documented at the end of this Petition.

iii. The AIRCRAFT a re 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 AIRCRAFT will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, t he AIRCRAFT do not reacquire control link data from the GCS, the AIRCRAFT will presume that the Control Link is lost and the AIRCRAFT will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown.

A complete description of the Failsafe Functions of the AIRCRAFT are set forth in the
User Manuals , whose latest Links are documented at the end of this Petition.

b. Flight Operations Of DJI 3, and Yuneec Typhoon Q500 UAS a re Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer.

APPLICANT will be the only person to act as a pilot in command (PIC) of AIRCRAFT

. Additionally, a safety observer will assist him during flight time.

c. Flights Of AIRCRAFT w ill Be Conducted Pursuant To Specific Operating Limitations.

In seeking this exemption, APPLICANT proposes to commercially operate AIRCRAFT for the special purpose of conducting aerial video and photography over certain areas of United States, pursuant to the following specific operating limitations:

1. Operations authorized by this grant of exemption will be limited to the following
AIRCRAFT described in the operating documents, rotorcraft UASs weighing less than 5519 pounds maximum gross weight

. Proposed operations of an y other aircraft will require a petition to amend this grant.

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

3. The AIRCRAFT may not be flown at an in dicated airspeed exceeding 45 knots.

4. The AIRCRAFT must be operated at an altitude of no more than 400 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved by ATC. All altitudes reported to ATC must be in
feet AGL.

5. The AIRCRAFT must be operated within visual lin e 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

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

7. All operatio ns must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permitt ed during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the SO can perform the functions prescribed in the operating documents.

8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is not permitted to operate the camera or other instruments.

9. The operating documents and the grant of exemption must be accessible during
AIRCRAFT 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 t he 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.

1 0. Prior to each flight the PIC must inspect the AIRCRAFT to ensure that it is in a condition for safe flight. If the inspection r eveals a condition that aff ects safe operation, the20 AIRCRAFT is prohibited from operating until the necessary maintenance has been performed and the AIRCRAFT is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All m aintenance and alterations must be properly documented in the aircraft records.

11. Any AIRCRAFT that has undergone maintenance or alterations that affect the
AIRCRAFT operation or flight characteristics, e.g. replacement of a flight critical component, mu st undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraft records.

12. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, n ot already covered in the relevant sections of the operating documents.

13. The operator must follow the AIRCRAFT manufacturer’s aircraft/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, alterations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total t ime in service, description of work accomplished

.

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

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

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

1 7

. AIRCRAFT 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 requir ed, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not
authorized.

1 8

. The AIRCRAFT may not operate within 5 nautical miles of an airport reference point
as den oted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance21 with a NOTAM as required by the operator’s COA. The letter of agreement with the airpor t management must be made available to the Administrator upon request.

19 . The UA V 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.

2 0 . If the UA V loses communications or loses its GPS signal, it must return to a pre

determined location within the planned operating area and land or be recovered in accordance with the operating documents.

2 1 . The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents.

2 2 . The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough po wer to fly at normal cruising speed to the intended landing point and land the UA V with 25% battery power remaining.

2 3 . The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder

req uirements.

2 4 . 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. Marki ngs must be as large as practicable.

2 5 . Before conducting operations, the radio frequency spectrum used for operation and
control of the UA V must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency req uirements.

2 6 . 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 AIRCRAFT any time the AIRCRAFT is operating. These documents must be made available to the Administrator or any la w enforcement official upon request.

2 7 . The AIRCRAFT must remain clear and yield the right of way to all manned aviation operations and activities at all times.

28 . Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are present that suffic iently protect nonparticipating persons from the UA V and/or debris in the event of an accident. The operator must22 ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or 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 does 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 per sons per § 91.119(a).

29 . All operations shall be conducted over private or controlled

- access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be
conducted.

3 0 . Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AF S

- 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.23 REASONS WHY AN EXEMPTION FROM THE REQUIREMENTS OF
SECTION 61.113(a) A ND (b) WOULD NOT ADVERSELY AFFECT SAFETY

APPLICANT 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 AIRCRAFT unless that PIC has demonstrated that the PIC is able to safely operate the AIRCRAFT i n a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

Considering APPLICANT proposed area of operations, and the oper ating 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 AIRCRAFT

, APPLICANT s ubmits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for AIRCRAFT proposed flight operations.

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

AP PLICANT will not allow any PIC to operate the AIRCRAFT unless the PIC has demonstrated that the PIC is able to safely operate the AIRCRAFT in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In addition to the hour requirements, t he PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes).

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during APPLICANT proposed operations. The Administrator has held that pri or documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture fi lming (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 operat ions 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 the24 exemption. For clarification, the FAA considers these minimum hou r 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, t he PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight

- hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the petitioner’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience

- building fl ights 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 S with appropriate
distances in accordance with 14 C.F.R 91. 119.

Accordingly, APPLICANT will ensure safe operations by not allowing any PIC to operate
AIRCRAFT unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the AIRCRAFT, in a mann er consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

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, APPLICANT will ensure that AIRCRAFT is in an airworthy condition based upon the UAS’s compliance with its operating documents and as sta ted in the
conditions and limitations herein.

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

REASONS WHY AN EXEMPTION FROM THE REQUIREMENTS OF

SECTION 91.121 WOULD NOT ADVERSELY AFFECT SAFETY

The equivalent level of safety es tablished by Section 91.121 will be maintained because
the altitude information of the AIRCRAFT 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 th e flight path and altitude. This altitude information, combined25 with APPLICANT operation of the AIRCRAFT within visua l line of sight, at or below 4 00 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information will be gen erated by GPS equipment installed onboard the aircraft. Prior to each flight, 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
circumst ances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

REASONS WHY AN EXEMPTION FROM THE REQUIREMENTS OF
SECTION 91.151 (B) WOULD NOT ADVERSELY AFFECT SAFETY

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifi cations of the AIRCRAFT ; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, APPLICANT will ensure that it will safely operate the battery powered AIRCRAFT during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 15 minutes to the first point of intended landing and, assuming normal cruising speed, t o fly after that for at least 5 minutes.

Furthermore, safety will be ensured as the AIRCRAFT prov ide audible and visual warnings to the PIC at the GCS when the UAs experiences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery power. At the critically low batt ery level, the
AIRCRAFT will descend and land automatically.

P revious 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 consi dered. 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 ci rcumstances 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, 11158, 11159, 11160, 11161).

REASONS WHY AN EXEMPTION FROM THE REQUIREMENTS OF
SECTIONS 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), A ND 91.417(a) & (b)
WOULD NOT ADVERSELY AFFECT SAFETY

In seeking this exemption, APPLICANT 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 because26 APPLICANT will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the AIRCRAFT operating documents . Furthermore, APPLICANT will
document and maintain all maint enance records for the AIRCRAFT.

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the technical characteristi cs and operating limitations of the UAS
are considered.

In consideration of APPLICANT proposed operating limitations, the operating documents, and the technical aspects of the AIRCRAFT 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, 11 064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

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

, APPLICANT requests that the FAA prescribe special conditions for the intended operation of the AIRCRAFT , which contain such safety standards that the Administrator finds necessary to est ablish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAs for the limited purpose of conducting aerial video and photography over certain areas of the United States for compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard 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 in accordance with any requirements that must be established for the safe ope ration 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 AIRCRAFT , since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features of the AIRCRAFT . Section 21.16, entitled Special Conditions

, states the following:

If the FAA f inds 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 for27 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.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for operation of the AIRCRAFT which con tain 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 APPLICANT Seeks Exemption:

Karen B. Ferrante 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 APPLICANT Seeks:

This exemption will permit Karen B. Ferrante to commercially operate an
Unmanned Ai rcraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States.

Additional Information, Views, Or Argum ents Available To Support APPLICANT’S Request.

This Petition is made pursuant to the FAA Mode rnization 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, APPLICANT request for exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth
above.

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 airworth iness
certification.28 CONCLUSION

As set forth herein, APPLICANT 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 AIRCRAFT commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernizatio n and Reform Act of 2012, while also advancing the interests of the public, by allowing APPLICANT to safely, efficiently, and economically operate the AIRCRAFT commercially within the NAS.

WHEREFORE , in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, APPLICANT 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), 91.40 7(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit APPLICANT to operate the
AIRCRAFT commercially for the purpose of conducting aerial video and photography over
cert ain areas of the United States.

APPLICANT only utilizes safe and reliable UASs. AIRCRAFT are industry leader s in small UAS production. These AIRCRAFT contain software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit fligh t to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, AIRCRAFT software provides real

- time altitude and location
information to the PIC via the linked monitor ing.

R espectfully,



### Karen B. Ferrante
7B Sunflower Court Ayer, MA 01432 karen@pointerpals.com (978) 314

- 4032

Links to AIRCRAFT Operator’s Manuals :

DJI Phantom 3 Manual http://download.dji

innovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.0_ en.pdf

Yuneec Typhoon Q500 Manual http://www.yuneec.com/download/manuals/q500_4k_user_manual.pdf