1

Sept 2 2015

Attn:

U. S. Department of Transportation Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Ave, SE Washington, DC 20590

RE: Worldwide Communication Consultants, Inc.

REQUEST AN EXEMPTION 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 UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Matthew Ruedlinger

VP-Installations

Worldwide Communication Consultants, Inc.

3298 Commerce Drive

Newburgh, IN 47630

Matt@wctower.com

812.455.8540
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TABLE OF CONTENTS

Page

GLOSSARY OF ABBREVIATIONS...................................................................................3

SUMMARY...........................................................................................................................4

INTRODUCTION AND INTERESTS OF PETITIONER....................................................4

BACKGROUND....................................................................................................................4

BASIS FOR PETITION.........................................................................................................5

NAME AND ADDRESS OF PETITIONER.........................................................................6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH WORLDWIDE

COMMUNICATION CONSULTANTS, INC. SEEKS

EXEMPTION.........................................................................................................................7

THE EXTENT OF RELIEF WORLDWIDE COMMUNICATION CONSULTANTS SEEKS

AND THE REASON WORLDWIDE COMMUNICATION CONSULTANTS SEEKS THE

RELIEF...............................................................................................................................10

THE REASONS WHY GRANTING WORLDWIDE COMMUNICATION CONSULTANTS

REQUEST WOULD BE IN THE PUBLIC

INTEREST...................................................................................................................12

THE REASONS WHY GRANTING THE EXEMPTION TO WORLDWIDE

COMMUNICATION CONSULTANTS WOULD NOT ADVERSELY AFFECT

SAFETY...............................................................................................................................13

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER...................23

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO

SUPPORT WORLDWIDE COMMUNICATION CONSULTANTS

REQUEST............................................................................................................................23

CONCLUSION.....................................................................................................................24

APPENDICES......................................................................................... 25
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GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

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

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing
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SUMMARY

Worldwide Communication Consultants, Inc. hereafter referred to as WWC 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

(DJI Phantom 3) pursuant to Section 333 of the FAA Modernization and Reform Act of 2012

(FMRA). This exemption will permit WWC to operate an Unmanned Aircraft System (UAS) for

the commercial purpose of conducting aerial video and photography inspections of communication

tower sites over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

WWC has for over ten years provided their clients (which include private sector businesses and

non-profits, along with local state and federal agencies) with expertise and knowledge in Broadcast

TV, Radio and Cellular Communication services. WWC has worked on Hundreds of

communication sites over the last 10 years in all types of locations with a perfect client and

employee safety record. In the past we have supplied our client’s aerial video and photography

using tower climbers. The objective of WWC and our Unmanned Aircraft System (DJI Phantom

3) aerial operations is to provide a safer, more affordable, high-quality inspection system for a

variety of governmental, commercial, public, and residential uses, specifically targeting

• Communication tower sites before and after proposed installations or modifications

• Inspection of FAA lighting systems on all towers ranging from 200’-1500’ to ensure

they are within compliance.

• Inspection of FAA paint color conditions to ensure they are in compliance.

• Inspections of top mounted TV antennas that do not other 100% tie off points for

personnel to manually climb.

I have flown small RC electric quadcopters recreationally for approximately 5 years without incident.

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 3, UAS

WWC seeks an exemption to operate DJI Phantom 3 system for compensation or hire within the

NAS. The DJI Phantom 3 is vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a

Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The DJI Phantom

3 has a maximum gross weight of approximately 2.26 lb. while having a diagonal dimension of

23.2”, a maximum speed of approximately 34mph and a maximum flying height of 5000'. The DJI

Phantom 3 is equipped with four main rotors; driven by Lithium Polymer battery powered electric

motors.
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The DJI Phantom 3 that will be operated by WWC 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, WWC, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. §

11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules

for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially

operate the DJI Phantom 3, 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), 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

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

unmanned aircraft and its operation, WWC operation of DJI Phantom 3 UAS meets the conditions

of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance

with 14 C.F.R. Part 21, Subpart H.

Accordingly, WWC 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.

WWC submits that the requested relief is proper since an equivalent level of safety will be ensured.

WWC will use experienced personnel or technicians to perform maintenance, alterations, or

preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the

operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual).

Furthermore, WWC will document and maintain all maintenance records for the DJI Phantom 3

UAS.

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

limitations: Pilot in command, is requested by WWC to the extent necessary to allow a Pilot in

Command (PIC) holding a private pilot or higher level certificate, as well as an airman medical

certificate, and who has demonstrated, by meeting minimum flight- hour and currency

requirements, that the PIC is able to safely operate the DJI Phantom UAS in a manner consistent

with this exemption, including evasive and emergency maneuvers and maintaining appropriate

distances from people, vessels, vehicles and structures.

WWC seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the DJI

Phantom 3 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21,

Subpart H. As such, WWC submits that they will ensure that the DJI Phantom 3 UAS is in an

airworthy condition, prior to every flight, by determining that the UAS are in compliance with the

operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual),

and that the aircraft are in a condition for safe flight.
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WWC also seeks an exemption from the requirements of Section 91.121, entitled Altimeter

Settings, as the DJI Phantom 3 UAS will not have a typical barometric altimeter onboard. However,

altitude information of the DJI Phantom 3 UAS 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. This altitude information, combined

with WWC operation of the DJI Phantom 3 UAS within visual line of sight, at or below 1500 feet

AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, WWC seeks an exemption from the requirements of Section 91.151(b), entitled Fuel

requirements for flight in VFR conditions. WWC submits that safety will not be affected by

operation of the DJI Phantom 3 UAS during daylight hours in visual meteorological conditions

(VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration of

approximately 23 minutes. Battery power indicators are also able to show exactly how much

battery power is left, as well as how much time is needed to return safely back to point of take off.

In accordance with 14 C.F.R. § 11.81, WWC provides the following information in support of its

petition for exemption:

A. Name And Address Of The Petitioner.

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

Matt Ruedlinger

VP-Installations

Worldwide Communication Consultants, Inc

3298 Commerce drive

Newburgh, IN 47630

812.455.8540 F-812.490.0730

Matt@wctower.com
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B. The Specific Sections Of 14 C.F.R. From Which WWC Seeks Exemption.

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

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

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

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

of an aircraft that is carrying passengers or property for compensation or hire; nor may

that person, for compensation or hire, act as PIC of an aircraft.

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

with any business or employment if—

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire.

2. WWC 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. WWC 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. WWC 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:
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(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. WWC 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. WWC 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. WWC Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And

91.409(a)(2).

Section 91.409, entitled Inspections, subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft

unless, within the preceding 12 calendar months, it has had --

(1) An annual inspection in accordance with part 43 of this chapter and has been

approved for return to service by a person authorized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance with

part 21 of this chapter.

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

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

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each

registered owner or operator shall keep the following records for the periods specified

in paragraph (b) of this section:

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

of the 100-hour, annual, progressive, and other required or approved inspections,
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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 inspection program under which the aircraft and

its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety

directives including, for each, the method of compliance, the AD or safety

directive number and revision date. If the AD or safety directive involves

recurring action, the time and date when the next action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major

alteration to the airframe and currently installed engines, rotors, propellers, and

appliances.

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

(1) The records specified in 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.
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(3) A list of defects furnished to a registered owner or operator under § 43.11 of

this chapter shall be retained until the defects are repaired and the aircraft is

approved for return to service.

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

1. Extent Of Relief WWC Seeks And The Reason WWC 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 flighthour 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, WWC submits that an equivalent level of safety will be maintained

because no PIC will be allowed to operate the DJI Phantom 3 UAS unless that PIC has met certain

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

Phantom 3 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, WWC submits that all flights of the DJI Phantom 3 UAS, conducted by the PIC pursuant

to the grant of this Petition: (1) will be incidental to WWC’s business; and (2) will not carry

passengers or property for compensation or hire.

2. Extent Of Relief WWC Seeks And The Reason WWC 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 WWC to determine that the DJI Phantom 3 UAS are in airworthy condition prior to every

flight by ensuring that the UAS is in compliance with the operating documents (i.e., WWC Aerial

Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual).

WWC seeks the requested relief because the DJI Phantom 3 UAS do not require an airworthiness

certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, WWC will ensure that the

DJI Phantom 3 UAS are in airworthy condition based upon its compliance with the operating

documents (i.e., Monthly Maintenance Log, and DJI Phantom 3) prior to every flight, and further,

determine that the aircraft are in condition for safe flight, as stated in the conditions and limitations

below.
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3. Extent Of Relief WWC Seeks And The Reason WWC Seeks Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations

of the DJI Phantom 3 UAS, which utilize a barometric pressure sensor, GPS equipment, and a

radio communications telemetry data link to downlink altitude information from the UA to the PIC

at the ground control station (GCS). Since the FAA requires that any altitude information

concerning UAS operations be reported to air traffic control (ATC) in feet above ground level

(AGL), WWC seeks the requested relief because the DJI Phantom 3 UA’s altimeter may be set on

the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each

flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought

to the extent necessary to comply with the applicable conditions and limitations stated below. As

more fully set forth herein, an equivalent level of safety will be maintained since the DJI Phantom

3 UAS 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 provides

the PIC with altitude information of the UA on the heads-up display of the GCS.

4. Extent Of Relief WWC Seeks And The Reason WWC Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested

to the extent required to allow flights of the battery powered DJI Phantom 3 UAS during daylight

hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total

duration of 23 minutes. The ALTEK MEDIA GROUP seeks the requested relief because without

an exemption from Section 91.151(b), the flight time duration of the battery powered DJI Phantom

3 UAS will severely constrain the practicality of any aerial video or still photo flight operations

that WWC proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the DJI Phantom 3 UAS, the DJI

Phantom 3 operating documents, and WWC proposed operating limitations, ensure that WWC will

safely operate the battery powered DJI Phantom 3 UAS during daylight hours in visual

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

fly for a total duration of 23 minutes.

5. Extent Of Relief WWC Seeks And The Reason WWC 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, WWC requests relief from these Sections because the

DJI Phantom 3 UAS do not require airworthiness certificates. As set forth more fully below, the

DJI Phantom 3 UAS meet the conditions of FMRA Section 333 for operation without an

airworthiness certificate. Accordingly, WWC will use trained technicians to perform maintenance,
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alterations, or preventive maintenance on the UAS using the methods, techniques, and practices

prescribed in the UAS operating documents (i.e., the WWC Aerial Operations Manual, Monthly

Maintenance Log, and DJI Phantom 3 Instruction Manual). Furthermore, WWC will document

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

D. The Reasons Why Granting WWC 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 WWC too safely,

efficiently, and economically perform aerial video and photography inspections of communication

towers in certain areas of the United States.

Additionally, use of the DJI Phantom 3 UAS will decrease the amount of time our employees are

exposed to falls from heights greater than 6’ AGL thus helping us to improve our overall safety

and health of our staff, and provide significant benefits to the economy. Notably, the benefits of

WWC proposed operation of the DJI Phantom 3 UAS will be realized without implicating any

privacy issues.

1. The Public Will Benefit From Decreased Chances of unstable towers toppling over during

a traditional manned climbing inspection.

The DJI Phantom 3 UAS are battery powered and serve as a safe, efficient, and economical

alternative to the tower climber traditionally utilized to obtain aerial inspection imagery.

Furthermore, by using the DJI Phantom 3 UAS to perform these inspections we are reducing

loading on potential unstable tower structures to zero and putting our employees and the

surrounding community in a much safer environment than we have previously been able too.

2. Performing Aerial Video and Photography Inspections With The DJI Phantom 3 UAS

Will Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 3 UAS are also an economical alternative

to using traditional tower climbers to conduct similar aerial inspections. As such, operation of the

DJI Phantom 3 UAS will allow United States based companies, like WWC, to remain competitive

and contribute to growth of the U.S. economy. U.S. owned and operated companies must adopt

new and alternative technology in order to remain safe and competitive. Operating the battery

powered DJI Phantom 3 UAS is one such technology that not only allows WWC greater

operational flexibility compared to traditional climbing operations, but provides such flexibility

without the high operational cost of a traditional safety gear and training of employees to perform

the dangerous pre-inspection climbs and allows us to safely inspect a structure before we put any

human life at risk.
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By operating the DJI Phantom 3 UAS, companies such as WWC, can remain safe, competitive

and profitable, and therefore, provide greater job stability to employees and contractors, which

will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S.

companies, through commercial use of the DJI Phantom 3 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.

3. There Are No Privacy Issues.

WWC’s proposed operation of the DJI Phantom 3 UAS will not implicate any privacy issues.

Specifically, the DJI Phantom 3 UAS will be operated only in compliance with operating

documents (i.e., the WWC Aerial Operations Manual, Monthly Maintenance Log, and DJI

Phantom 3 Instruction Manual) which requires property owner involvement as well as local law

enforcement notification, and in accordance with the Federal Aviation Regulations, including the

minimum altitude requirements of 14 C.F.R. § 91.119.

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

The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The

Rule From Which WWC Seeks Exemption.

1. Reasons Why The DJI Phantom 3 UAS 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, WWC operation of the DJI Phantom 3 UAS 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 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 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--
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(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 establish requirements for the safe operation of such

aircraft systems in the national airspace system.

In seeking this exemption, WWC submits that the DJI Phantom 3 UAS can operate safely in the

NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI

Phantom 3 UAS; (b) the pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The DJI Phantom 3 UAS Demonstrate Its Safe Characteristics.

The DJI Phantom 3 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 3 UAS.

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

Manual, attached hereto as Appendix A.

ii. The DJI Phantom 3 UAS Global Positioning Modes Enable The UAS To Remain

Within A Defined Operational Area.

The DJI Phantom 3 UAS may be operated in both manual and global positioning flight modes. A

complete description of the flight and navigational modes of the DJI Phantom 3 UAS is provided

at pages 11 of the DJI Phantom 3 User Manual attached hereto as Appendix A.

iii. The DJI Phantom 3 UAS Are Designed For Automatic Return To Home Point

Or Hover In The Event Of Loss Of The Control Link Or Navigation.

When the Control Link is lost, the DJI Phantom 3 UAS will remain stationary, in flight, for 3

seconds or more. If, after 3 seconds, the DJI Phantom 3 UAS does not reacquire control link data

from the GCS, the UAS will assume that the Control Link is lost and the 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 DJI Phantom 3 UAS are set forth at pages

12 through 14 of the DJI Phantom 3 User Manual, attached hereto as Appendix A.
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iv. The DJI Phantom 3 GCS And Its Operation.

A complete description of the operation and specifications of the DJI Phantom 3 GCS and flight

control software is provided at pages 23 through 29 of the DJI Phantom 3 User Manual. DJI

Phantom 3 User Manual is attached hereto as Appendix A.

b. Flight Operations Of DJI Phantom 3 UAS Is Limited To The Line Of Sight Of A

Certificated Pilot in Command With A Safety Observer.

WWC video inspection staff will be the only persons to act as a pilot in command (PIC) of the DJI

Phantom 3 UAS. Additionally, a safety observer will assist him at all times during flight time.

c. Flights Of DJI Phantom 3 UAS Will Be Conducted Pursuant To Specific Operating

Limitations.

In seeking this exemption, WWC proposes to commercially operate DJI Phantom 3 UAS for the

special purpose of conducting aerial video and photography tower inspections 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 UAS weighing less than 55

pounds maximum gross weight: DJI Phantom 3 Unmanned Aircraft Systems. Proposed

operations of any other aircraft will require a new petition or a petition to amend this

grant.

2. UAS operations under this exemption will be limited to conducting operations for the

purpose of aerial video and photography inspections of communication towers.

3. The UAS may not be flown at an indicated airspeed exceeding 20 knots.

4. The UA must be operated at an altitude of no more than 1500 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 UAS must be operated within visual line of sight (VLOS) of the PIC at all times.

This requires the PIC to be able to use human vision unaided by any device other than

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate.

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

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the

VLOS requirement as long as the PIC always maintains VLOS capability. The SO and

PIC must be able to communicate verbally at all times. Electronic messaging or texting

is not permitted during flight operations. The PIC must be designated before the flight

and cannot transfer his or her designation for the duration of the flight. The PIC must

ensure that the SO can perform the functions prescribed in the operating documents.
16

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 UAS

operations and made available to the Administrator upon request. If a discrepancy exists

between the conditions and limitations contained in the grant of exemption and the

procedures outlined in the operating documents, the conditions and limitations

contained in the grant of exemption take precedence and must be followed. Otherwise,

the operator must follow the procedures as outlined in its operating documents. The

operator may update or revise its operating documents. It is the operator’s responsibility

to track such revisions and present updated and revised documents to the Administrator

upon request. The operator must also present updated and revised documents if it

petitions for extension or amendment to the grant of exemption. If the operator

determines that any update or revision would affect the basis upon which the FAA

granted the exemption, then the operator must petition for amendment to its grant of

exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if questions

arise regarding updates or revisions to the operating documents.

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

for safe flight. If the inspection reveals a condition that affects the safe operation of the

UAS, the aircraft is prohibited from operating until the necessary maintenance has been

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.

11. 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. 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, not already covered in the relevant

sections of the operating documents.

13. The operator must follow the UAS 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 time in service, description of work accomplished, and

the signature of the authorized person returning the UAS to service.

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

Bulletins.
17

16. The authorized person must make an entry in the aircraft record of the corrective

action taken against discrepancies discovered between inspections.

17. The PIC must possess at least a private pilot certificate and at least a current thirdclass medical certificate.

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s

qualification criteria and demonstrates the ability to safely operate the UAS in a manner

consistent with how the UAS will be operated under the exemption, including evasive

and emergency maneuvers and maintaining appropriate distances from persons,

vessels, vehicles and structures. PIC qualification flight hours must be logged in a

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 only 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 from nonparticipants in accordance with 14 C.F.R. § 91.119.

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1.

All operations must be conducted under visual meteorological conditions (VMC). If

flight at night is required, a special request will be made at the FAA office closest to

proposed area of operations. Flights under special visual flight rules (SVFR) are not

authorized.

20. The UA may not operate within 5 nautical miles of an airport reference point as

denoted on a current FAA-published aeronautical chart unless a letter of agreement

with that airport’s management is obtained, and the operation is conducted in

accordance with a NOTAM as required by the operator’s COA. The letter of agreement

with the airport management must be made available to the Administrator upon request.

21. The UA may not be operated less than 500 feet below or less than 2,000 feet

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in

accordance with the operating documents.

23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies

in accordance with the operating documents.

24. The PIC is prohibited from beginning a flight unless (considering wind and forecast

weather conditions) there is enough power to fly at normal cruising speed to the

intended landing point and land the UA with 25% battery power remaining.

25. The operator must obtain an Air Traffic 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
18

(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 requirements.

26. All aircraft operated in accordance with the exemption must be identified by serial

number, registered in accordance with 14 C.F.R. part 47, and have identification (NNumber) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be

as large as practicable.

27. Before conducting operations, the radio frequency spectrum used for operation and

control of the UA must comply with the Federal Communications Commission (FCC)

or other appropriate government oversight agency requirements.

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

the PIC at the Ground Control Station of the UAS any time the UAS is operating. These

documents must be made available to the Administrator or any law enforcement official

upon request.

29. The UA must remain clear and yield the right of way to all manned aviation

operations and activities at all times.

30. The UAS may not be operated by the PIC from any moving device or vehicle.

31. Flight operations must be conducted at least 500 feet from all nonparticipating

persons (persons other than the PIC, SO, operator trainees or essential persons), vessels,

vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating

persons from the UA and/or debris in the event of an accident. The operator must

ensure that nonparticipating persons remain under such protection. If a situation

arises where nonparticipating persons leave such protection and are within 500

feet of the UA, flight operations must cease immediately and/or;

b. The 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 persons per § 91.119(a).

32. 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.
19

33. 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 (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.

WWC submits that the equivalent level of safety established by Section 61.113(a) and (b) will be

maintained because no PIC will be allowed to operate the DJI Phantom 3 UAS unless that PIC has

demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to

safely operate the DJI Phantom 3 UAS in a manner consistent with the exemption, including

evasive and emergency maneuvers and maintaining appropriate distances from people, vessels,

vehicles and structures.

Considering WWC 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 3 UAS, WWC submits that the additional manned airmanship experience of a

commercially certificated pilot would not correlate to the airmanship skills necessary for the WWC

specific 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).

WWC will not allow any PIC to operate the DJI Phantom 3 UAS unless that PIC has demonstrated,

by meeting minimum flight-hour requirements or the DJI Phantom 3 UAS training and currency

requirements, that the PIC is able to safely operate the DJI Phantom 3 UAS in a manner consistent

with this exemption, including evasive and emergency maneuvers and maintaining appropriate

distances from people, vessels, vehicles and structures.

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. §

61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those

hours 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, the PIC must accomplish 3 takeoffs and

landings in the preceding 90 days (for currency purposes).

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was

obtained in compliance with applicable regulations will ensure an equivalent level of safety during

WWC proposed operations. The Administrator has held that prior documented flight experience

that was obtained in compliance with applicable regulations would ensure safe operations, stating

as follows:
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In Exemption No. 11062, the FAA required that prior to conducting operations for the

purpose of motion picture filming (or similar operations), the PIC must have accumulated

and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS

rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor UAS.

Prior to operations under Exemption No. 11062, the PIC must also have accumulated and

logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS

to be used for operations under the exemption. For clarification, the FAA considers these

minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and

model time may be included in the 10 hours of multi-rotor time and the 10 hours may be

included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements,

the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency

purposes). The FAA finds that at a minimum, the flight-hour requirements in Exemption

No. 11062 are appropriate to practice and build proficiency in the skills 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 flights can also be

conducted under the grant of exemption to accomplish the required flight time. During

training, proficiency, and experience-building flights the PIC is required to operate the UA

with appropriate distances in accordance with 14 C.F.R 91.119.

Exemption No. 11138 at page 15.

Accordingly, WWC will ensure safe operations by not allowing any PIC to operate the DJI

Phantom 3 UAS unless that PIC has demonstrated, by meeting minimum flight-hour and currency

requirements, that the PIC is able to safely operate the DJI Phantom 3 UAS in a manner consistent

with the exemption, including evasive and emergency maneuvers and maintaining appropriate

distances from people, vessels, vehicles and structures.

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

Adversely Affect Safety.

The equivalent level of safety established by Section 91.7(a) will be maintained because prior to

every flight, WWC will ensure that the DJI Phantom 3 UAS is in an airworthy condition based

upon the UAS’s compliance with its operating documents and as stated in the conditions and

limitations herein.

Additionally, the FAA has previously granted relief from Section 91.7(a) 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).
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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 3 UAS 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 and altitude. This altitude information, combined with WWC

operation of the DJI Phantom 3 UAS within visual line of sight, at or below 1500 feet AGL, will

ensure a level of safety equivalent to Section 91.121. The altitude information will be generated

by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point

is automatically established by the UAS at ground level.

The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063,

11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157,

11158, 11159, 11160, 11161).

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

Adversely Affect Safety.

A 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 3 UAS; (2) the

limitations on the proposed flight operations; and (3) the location of the proposed flight operations.

Accordingly, WWC will ensure that it will safely operate the battery powered DJI Phantom 3 UAS

during daylight hours in VFR conditions, with enough battery power to fly for a total duration of

23 minutes.

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

limitations on the proposed flight operations; and the location of the proposed operations, will

ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore,

safety will be ensured as the DJI Phantom 3 UAS provide 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 battery level, the DJI Phantom 3 UAS will descend and land

automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that

safety is not adversely affected when the technical characteristics 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.

Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos.

8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110,

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).
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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, WWC 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 WWC will use

trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS

using the methods, techniques, and practices prescribed in the operating documents (i.e., the WWC

Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual).

Furthermore, WWC will document and maintain all maintenance records for the DJI Phantom 3

UAS.

Since the DJI Phantom 3 UAS will be inspected as prescribed by the operating documents, WWC

will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and

91.409(a)(2). A copy of the DJI Phantom 3 User Manuals are attached hereto as Appendix A

Likewise, the exemption sought will not adversely affect safety because WWC will use trained

technicians to perform maintenance, alterations or preventive maintenance on the UAS using the

methods, techniques, and practices prescribed by the operating documents.

Furthermore, the exemption sought would maintain an equivalent level of safety established by

Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI Phantom 3 UAS

will be performed by trained technicians. Maintenance will be documented and maintained

utilizing the monthly maintenance log.

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely

affected when the technical characteristics and operating limitations of the UAS are considered.

In consideration of WWC proposed operating limitations, the operating documents, and the

technical aspects of the DJI Phantom 3 UAS, WWC 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, 11150,

11153, 11156, 11157, 11158, 11159, 11160, 11161).

7. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and

14 C.F.R. § 21.16 entitled Special Conditions, WWC requests that the FAA prescribe special

conditions for the intended operation of the DJI Phantom 3 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,
23

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 inspections of communication towers over certain areas of the United States for

compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a

UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national

security; and further, provides the authority for such UAS to 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 DJI Phantom 3 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 Conditions, states the following:

If the FAA finds that the airworthiness regulations of this subchapter do not contain

adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller

because of a novel or unusual design feature of 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.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe

special conditions for Leading Edge’s intended operation of the DJI Phantom 3 UAS, which

contain such safety standards that the Administrator finds necessary to establish a level of safety

equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) &

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

(b).

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

Rules From Which WWC Seeks Exemption:

WWC 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 WWC Seeks:

This exemption will permit WWC to commercially operate an Unmanned Aircraft System

(UAS) for the purpose of conducting aerial video and photography inspections of

communication towers over certain areas of the United States.

• Any Additional Information, Views, Or Arguments Available To Support

WWC Request.
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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, WWC 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 airworthiness certification.

As discussed in detail above, WWC will operate the DJI Phantom 3 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, WWC seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of

the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the

DJI Phantom 3 UAS commercially, without an airworthiness certificate, for the limited purpose of

conducting aerial video and photography inspections of communication towers over certain areas

of the United States. By granting this Petition, the FAA Administrator will be fulfilling the

Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing

the interests of the public, by allowing WWC to safely, efficiently, and economically operate the

DJI Phantom 3 UAS commercially within the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA

Modernization and Reform Act of 2012, Section 333, WWC 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 Leading Edge to operate the DJI Phantom 3 UAS commercially for

the purpose of conducting aerial video and photography inspections of communication towers over

certain areas of the United States.

Dated: Sept 2 2015

Respectfully submitted,

Matt Ruedlinger

VP-Installations

Worldwide Communication Consultants, Inc.

3298 Commerce Drive

Newburgh, IN 47630

812.455.8540

Matt@wctower.com
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Appendices:

A – Link to DJI Phantom 3 Manual: Click on link below

http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Advanced_User_Manual_v1.2_en.pdf