2

seeks Exemption **TABLE OF CONTENTS**  Page GLOSSARY OF ABBREVIATIONS.
................................ ................................ .................. 3 SUMMARY.
................................ ................................ ................................ ......................... 4 IN TRODUCTION AND INTERESTS OF PETITIONER
................................ .................... 4 BACKGROUND
................................ ................................ ................................ .................... 4 BASI S FOR PETITION.
................................ ................................ ................................ ....... 5 NAME AND ADDRESS OF PETITIONER
................................ ............................ 7 THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHI CH KETCHAM AERIAL IMAGING SEEKS EXEMPTION.
................................ ................................ ........... 8 THE EXTENT OF RELIEF KETCHAM AERIAL IMAGING SEEKS AND THE REASON KETCHAM AERIAL IMAGING SEEKS THE RELIEF..............
..... 11 THE REASONS WHY GRANTING KETCHAM AERIALIMAGING ’S REQUEST WOULD BE IN THE PUBLIC INTEREST
......... ............................ 15 THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY
................................ ................................ ......... 19 SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER.
.... 34 ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT KETCHAM AERIALIMAGING ’S REQUEST... 34 CONCLUSION
................................ ................................ ................................ ................... 35 APPENDICES........................................................................................373

seeks Exemption **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 LO L Lo ss of Link NAS National Airspace System NOTAM Notice to Airman PIC Pilot In Command Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Se ction 333 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 Landing4

seeks Exemption **SUMMARY** Ketcham Aerial Imaging 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 Ketcham Aerial Imaging to operate an Unmanned Aircraft S ys tem (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** Ketcham Aerial Imaging provides its clients with expertise and knowledge in advanced technologies and solutions to increase efficiency , productivity and ef fectiveness. Ketcham Aerial Imaging is experienced in all aspects of aerial video and photography. The objective of Ketcham Aerial Imaging ’s aerial video and photography operations is to provide low cost, high quality imaging for a variety

of commercial and residential customers. **BACKGROUND** Unmanned Aircraft Systems: DJIPhantom 2 Vision+, DJ I Inspire 1 UASs Ketcham Aerial Imaging seeks an exemption to operate DJ I s ys tems for compensation or hire within the NAS. The DJ I Phantom 2 Vision+ and DJ I In spire 1 are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The DJ I Phantom 2 Vision+ has a maximum gross weight of approximately 2 pounds 11 ounces, while having
a length of 16 inches width of 16 inches, height of 8 inches, and a maximum speed of5

seeks Exemption approximately 29 knots. The DJ I Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of approximately 42 knots. The DJIPhantom 2 Vision+ and DJI Inspire 1UAs are equipped with four main rotors; driven by Lithium Poly mer battery powered electric motors. The DJ I Phantom 2 Vision+ and DJ I Inspire 1 UAs that will b e operated by Ketcham Aerial Imaging 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, Ketcham Aerial Imaging , 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 , hereb y petitions the Administrator to commerciall y operate the DJ I Phantom 2 Vision+, DJI Inspire 1 UASs in the National Airspace S ys tem (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, Ketcham Aerial Imaging ’s operation of DJ I Phantom 2 Vision+ and DJIInspire 1 UASs meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.6

seeks Exemption Accordingl y, Ketcham Aerial Imaging requests relie f 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 onl y appl y to aircraft with an airworthiness certificate. Ketcham Aerial Imaging submits that the requested relief is proper since an equivalent level of safety will be ensured. Ketcham Aerial Imaging 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 (i.e., the Ketcham Aerial Imaging Aerial Operations Manual, Monthly Maintenance Lo g, and DJI Phantom 2 Vision+ and DJ I Inspire 1 Instruction Manual). Furthermore, Ketcham Aerial Imaging will document and maintain all maintenance records for the DJ I Phantom 2 Vision+ and DJ I Inspire 1 UASs. Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested by Ketcham Aerial Imaging 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, b y meeting minimum flight

- hour and currency requirements, that the PIC is a ble to safel y operate the DJ I Phantom 2 Vision+ and DJ I Inspire 1 UASs in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Ketcham Aerial Imaging seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness , because the DJ I Phantom 2 Vision+ and DJ I Inspire 1 UASs do not require
an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Ketcham Aerial Imaging submits that it will ensure that the DJ I Phantom 2 Vision+ and7

seeks Exemption DJI Inspire 1UASs are in an airworthy condition, prior to every flight, by determining that the UASs are in compliance with the operating documents (i.e., the Ketcham Aerial Imaging Aerial Operations Manual, Monthly Maintenance Log, and DJ I Phantom 2 Vision+ and DJ I Inspire 1 Instruction Manual), and that the aircraft are in a condition for safe flight. Ketcham Aerial Imaging also seeks an exemption from the requirement s of Section 91.121, entitled Altimeter Settings , as the DJ I Phantom 2 Vision+ and DJ I Inspire 1 UAs will not have a ty

pical barometric altimeter onboard. However, altitude information of the DJIPhantom 2 Vision+ and DJIInspire 1UAs will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with Ketcham Aerial Imaging ’s operation of the DJI Phantom 2 Vision+ and DJ I Inspire 1 UASs within visual line of sight, at or below 4 00 feet AGL, will ensure a level of safety equivalent to Section 91.121. Additionally, Ketcham Aerial Imaging seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions

. Ketcham Aerial Imaging submits that safety will not be affected b y operation of the DJI Phantom 2 Vision+ and DJ I Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly

for a total duration of approximately 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.8

seeks Exemption In accordance with 14 C.F.R. § 11.81, Ketcham Aerial Imaging provides the following information in support of its petition for exemption: **A. Name And Address Of Th**  **e Petitioner** The name and address of the Petitioner and point of contact is: Anthony H. Ketcham Ketcham Aerial Imaging 2500 Deer Valley

Rd. #1421 San Rafael, CA 94903 Tel: (415) 342

- 9381 Email : ketcham99@comcast.net **B. The**  **Specific Sections Of 14 C.F.R. From Which**  **Ketcham Aerial Imaging seeks**  **Exemption 1.**  **Ketcham Aerial Imaging seeks**  **Exemption From The Requirements**  **Of Section 61.113(a) a**  **nd (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 emplo ym ent if

— (1) The flight is onl y incidental to that business or employment; and (2) The aircraft does not carry passengers or property

for compensation or hire. **2. Ketcham Aerial Imaging**  **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.9

seeks Exemption **3. Ketcham Aerial Imaging**  **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, b y 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. Ketcham Aerial Imaging**  **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 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. Ketcham Aerial Imaging**  **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[.]10

seeks Exemption **6. Ketcham Aerial Imaging**  **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 b y a person authorized under § 43.7 of this chapter[.] **7. Ketcham Aerial Imaging**  **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. Ketcham Aerial Imaging**  **seeks Exemption From The Requirements**  **Of Sections 91.417(a) And**  **91.417(b).** Section 91.417, entitled Maintenance records , subsections (a) and (b), state the following: (a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preventive maintenance, and alteration and records of the 100

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

--11

seeks Exemption (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 b y § 43.9(d) of this chapter for each major alteration to the airframe and currentl y 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 chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.12

seeks Exemption **C. The Extent Of Relief**  **Ketcham Aerial Imaging seeks**  **And The Reason Ketcham**  **Aerial Imaging seeks**  **The Relief.**  **1. Extent Of Relief**  **Ketcham Aerial Imaging seeks**  **And The Reason Ketcham**  **Aerial Imaging 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 emplo ym ent if: (1) The flight is only incidental to that business or employ

ment; and (2) The aircraft does not carry passengers or property for compensation or hire. As set forth more full y below, Ketcham Aerial Im aging submits that an equivalent level of safety

will be maintained because no PIC will be allowed to operate the DJ I Phantom 2 Vision+ UAS or DJ I Inspire 1 UAS unless that PIC has met certain flight

- hour and currency

requirements, demonstrating that the PIC is able to safely operate either the DJIPhantom 2 Vision+ or DJ I Inspire 1 UAS in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures. Further, Ketcham Aerial Imaging submits that all flights of the DJ I Phantom 2 Vision+ and DJ I Inspire 1 UASs, conducted b y the PIC pursuant to the grant of this13

seeks Exemption Petition: (1) will be incidental to Ketcham Aerial Imaging ’s business; and (2) will not carry passengers or property for compensation or hire. **2. Extent Of Relief**  **Ketcham Aerial Imaging seeks**  **And The Reason Ketcham**  **Aerial Imaging 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 Ketcham Aerial Imaging to determine that the DJ I Phantom 2 Vision+ and DJ I Inspire 1 UASs are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., the Ketcham Aerial Imaging Operations Manual, Monthly Maintenance Log, and DJ I Phantom 2 Vision+ and DJ I Inspire 1 Instruction Manual). Ketcham Aerial Imaging seeks the requested relief because the DJ I Phantom 2 Vision+ and DJ I Inspire 1 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Ketcham Aerial Imaging will ensure that the DJIPhantom 2 Vision+ and DJIInspire 1 UASs are in airworthy condition based upon its compliance with the operating documents (i.e., the Ketcham Aerial Imaging Operations Manual, Monthly Maintenance Log, and DJ I Phantom 2 Vision+ and DJ I In spire 1 Instruction Manual) prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated in the conditions and limitations below. **3. Extent Of Relief**  **Ketcham Aerial Imaging Seeks And The Reason**  **Ketcham Aerial Imaging**  **Seeks Relief From Section 91.121.**  Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the DJIPhantom 2 Vision+ and DJIInspire 1 UASs, 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 operations14

seeks Exemption be reported to air traffic control (ATC) in feet above ground level (AGL), Ketcham Aerial Imaging seeks the requested relief because the DJ I Phantom 2 Vision+ and DJI Inspire 1 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 2 Vision+ and DJ I Inspire 1 UAs are equipped with a barometric pressure sensor and GPS equipment, which automaticall y 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**  **Ketcham Aerial Imaging Seeks And The Reason**  **Ketcham Aerial Imaging**  **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 DJ I Phantom 2 Vision+ and DJIInspire 1 UAs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruis ing speed, to fly after that for at least 4.5 minutes. Ketcham Aerial Imaging seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered DJ I Phantom 2 Vision+ and DJIInspire 1 UAs will s everel y constrain the practicality of any aerial video or still photo flight operations that Ketcham Aerial Im aging proposes to conduct pursuant to this Petition.15

seeks Exemption Significantl y, as set forth below, the technical specifications of the DJ I Phantom 2 Vision+ and DJI Inspire 1 UASs, the DJI Phantom 2 Vision+ and DJ I Inspire 1 operating documents, and Ketcham Aerial Imaging ’s proposed operating limitations, ensure that Ketcham Aerial Imaging will safely operate the battery

powered DJ I Phantom 2 Vision+ and DJ I Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. **5. Extent Of Relief**  **Ketcham Aerial Imaging Seeks And The Reason**  **Ketcham Aerial Imaging**  **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 appl y to aircraft with an airworthiness certificate, Ketcham Aerial Imaging requests relief from these Sections because the DJ I Phantom 2 Vision+ and DJ I Inspire 1 UASs do

not require airworthiness certificates. As set forth more fully below, the DJI Phantom 2 Vision+ and DJ I Inspire 1 UASs meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingl y, Ketcham Aerial Imaging will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the Ketcham Aerial Imaging Aerial Operations Manual, Monthl y Maintenance Lo g, and DJ I Phantom 2 Vision+ and DJ I Inspire 1 Instruction Manual). Furthermore, Ketcham Aerial Imaging will document and maintain all maintenance records for the DJIPhantom 2 Vision+ and DJ I Inspire 1 UASs. **D. The Reasons Why Granting**  **Ketcham Aerial Imaging**  **’s Request Would Be In The Public Interest; That Is, How It Would Benefit The Public As A Whole.** 16

seeks Exemption Granting the present Petition will further the public interest by allowing Ketcham Aerial Im aging 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 DJIPhantom 2 Vision+ and DJIInspire 1 UASs will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the
economy. Notabl y, the benefits of Ketcham Aerial Imaging ’s proposed operation of the DJIPhantom 2 Vision+ and DJIInspire 1 UASs will be realized without implic ating any privacy issues. **1. The Public Will Benefit From Decreased Congestion Of The NAS.**  The DJ I Phantom 2 Vision+ and DJ I Inspire 1 UAs are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally uti lized to obtain aerial imagery . By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJ I Phantom 2 Vision+ or DJ I Inspire 1 UAS would reduce the amount of manned aircraft in the NAS, reduce noi se and air pollution, as well as increase the safety of life and property in the air and on the ground. Furthermore, b y reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The DJIPhantom 2 Vision+ and DJIInspire 1 UAs do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations. **2. The Public Will Benefit From The Safety And Efficiency Of The**  **DJI Phantom 2 Vision+ and DJI Inspire 1**  **UASs.**17

seeks Exemption Conducting aerial acquisition s with the DJIPhantom 2 Vision+ and DJ I Inspire 1 UASs, instead of manned aircraft, will greatl y benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By using battery

power and electric motors, the DJ I Phantom 2 Vision+ and DJIInspire 1 UASs produce no air pollution, and is the most viable environmentall y conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typicall y utilized for aerial video and photography, while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The DJ I Phantom 2 Vision+ and DJIInspire 1 UAs, while reducing the carbon footprint ofaerial acquisitions, also eliminates noise pollution, as the UAs are propelled b y battery powered electric motors, rather than an internal combustion engine. By using the DJ I Phantom 2 Vision+ and DJ I Inspire 1 UASs 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 completel y eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJIP hantom 2 Vision+ and DJIInspire 1 UAs (weighing approximately

2 pounds 11 ounces and 6 pounds 7.5 ounces respectivel y, at their maximum gross weights with lengths of 16 inches and 17.3 inches respectively, widths of 16 inches and 17.7 inches respectivel y, and with no fuel on board), has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that ty pically conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).18

seeks Exemption **3. Performing Aerial Video and Photography Operations With The**  **DJI Phantom 2 Vision+ and DJI Inspire 1 UASs Will Benefit The**  **Economy.** In addition to being safe and efficient, the DJ I Phantom 2 Vision+ and DJ I Inspire 1 UASs are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJ I Phantom 2 Vision+ and DJIInspire 1 UASs will allow United States based companies, like Ketcham Aerial Imaging , to remain competitive and contribute to growth of the U.S. economy . Specificall y, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out lead ed aviation fuels, U.S. owned and operated companies must adopt new and alternative technology

in order to remain competitive. Operating the battery powered DJ I Phantom 2 Vision+ and DJIInspire 1 UASs 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 DJ I Phantom 2 Vision+ and DJ I Inspire 1 UASs, companies such
as Ketcham Aerial Imaging , can remain 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 u se of the DJI Phantom 2 Vision+ and DJIInspire 1 UASs, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the United States and abroad. **4. There Are No Privacy Issues.**  Similar to the manned aerial acquisition flight operations that have been conducted for decades, Ketcham Aerial Imaging ’s proposed operation of the DJ I Phantom 2 Vision+ and19

seeks Exemption DJIInspire 1 UASs will not implicate any privacy issues. Specificall y, the DJIPhantom 2 Vision+ and DJ I Inspire 1 UASs will be operated only in compliance with operating documents (i.e., the Ketcham Aerial Imaging Aerial Operations Manual, Monthly Maintenance Lo g, and DJIPhantom 2 Vision+ and DJIInspire 1 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**  **Ketcham Aerial Imaging Seeks**  **Exemption. 1.**  **Reasons Why The DJI Phantom 2 Vision+ and DJI Inspire 1 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 aircra ft and its operation, Ketcham Aerial Imaging ’s operation ofthe DJIPhantom 2 Vision+ and DJIInspire 1 UASs 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. Specificall y, 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 certa in unmanned aircraft systems may operate safely in the national airspace system before completion of theplan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act.20

seeks Exemption (b) Assessment of Unmanned Aircraft Systems.

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

-- (1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security; and (2) ) whether a certificate of waiver, certificate of 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, Ketcham Aerial Imaging submits that the DJ I Phantom 2 Vision+ and DJ I Inspire 1 UASs can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated b y: (a) the characteristics of the DJ I Phantom 2 Vision+ and DJ I Inspire 1 UASs; (b) the pilot certification requirement; and (c) the specific operating limitations.

**a. The Specifications Of The DJI Phantom 2 Vision+ and DJI Inspire**  **1 UASs Demonstrate Its Safe**  **Characteristics.** The DJ I Phantom 2 Vision+ and DJ I Inspire 1 UASs 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 Of The DJI Phantom 2 Vision+ and**  **DJI Inspire 1**  **UASs.** The technical specifications of the DJ I Phantom 2 Vision+ and DJ I Inspire 1 UASs are set forth b y the DJ I Phantom 2 Vision+ and DJIInspire 1 Specifications and Data Sheet, attached hereto as Exhibit A and B.21

seeks Exemption **ii. The DJI Phantom 2 Vision+ and DJI Inspire 1 UASs**  **Autonomous**

**Flight And Navigation Modes Enable The UASs To Remain Within A Defined Operational**  **Area.** The DJ I Phantom 2 Vision+ and DJ I Inspire 1 UASs may be operated in both manual and full y autonomous flight modes. A complete description of the flight and navigational modes of the DJ I Phantom 2 Vision+ and DJ I Inspire 1 UASs is provided at pages 25

- 35 of the DJ I Phantom 2 Vision+ and pages 12

- 16 and 45

- 50 of the DJ I Inspire 1 User Manuals, attached hereto as Exhibit C and D.

**iii. The DJI Phantom 2 Vision+ and D**  **JI Inspire 1 UASs 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 DJIPhantom 2 Vision+ and DJ I Inspire 1 UAs will remain stationary, in flight, for 3 seco nds or more. If, after 3 seconds, the DJ I Phantom 2 Vision+ and DJ I Inspire 1 UAs do not reacquire control link data from the GCS, the UAs will assume that the Control Link is lost and the UAs will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown. A complete description of the Failsafe Functions of the DJ I Phantom 2 Vision+ UAS are set forth at pages 27 through 29 and for the DJ I Inspire 1 at pages 13 through 15 of the DJI Phantom 2 Vision+ and DJ I Inspire 1 User Manuals, attached hereto as Exhibit C and D. **iv. The DJI Phantom 2 Vision+ and DJI Inspire 1 GCS And**  **Its**

**Operation.** A complete description of the operation and specifications of the DJ I Phantom 2 Vision+ and DJ I Inspire 1 GCS and flight control software is provided at pages 32 through 43 of the DJ I Phantom 2 Vision+ User Manual and pages 40 through 47 of the DJ I Inspire22

seeks Exemption 1 User Manual. DJ I Phantom 2 Vision+ and DJ I In spire 1 User Manuals are attached hereto as Exhibits C and D.

**b. Flight Operations Of DJI Phantom 2 Vision+ and DJI Inspire 1**  **UASs Are Limited To The Line Of Sight Of A Certificated Pilot in**  **Command With A Safety**  **Observer.** Ketcham Aerial Imaging will only utilize certificated pilots who possess a current and valid airman medical certificate or a valid U.S. driver’s license issued by a state to act as a pilot in command (PIC) of the DJ I Phantom 2 Vision+ and DJ I Inspire 1 UASs. Additionally, a safety observer will assist all pil ots during flight time.

**c. Flights Of DJI Phantom 2 Vision+ and DJI Inspire 1 UASs Will**  **Be Conducted Pursuant To Specific Operating Limitations.**  In seeking this exemption, Ketcham Aerial Imaging proposes to commercially operate DJ I Phantom 2 Vision+ and DJ I Inspire 1 UASs 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 b y this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: DJ I Phantom 2 Vision+ and DJ I Inspire 1 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. 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 4 00 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.23

seeks Exemption 6. The use of first person view (FPV) b y 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 duratio n 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 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 perfor med 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 mainten ance 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.24

seeks Exemption 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 UASs operated under this exemption must comply with all manufacturer Safety Bulletins. 16. The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections. 17. The PIC must hold either an Airline Transport, Commercial, Private, Recreational, or Sport Pilot certificate

. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’ s license issued b y a state. 18. The operator may

not permit any

PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safel y 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. § 19.1. 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.25

seeks Exemption 21. The UA may

not be operated less than 500 feet below or less than 2,000 feet horizontally

from a cloud or when visibility is less than 3 statute miles from the PIC. 22. If the UA loses communications or loses its GPS signal, it must return to a pre determined location within 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 (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 (N

- Number) 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 PI C 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 yi eld the right of way to all manned aviation operations and activities at all times. 30. The UAS may

no t be operated b y 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:26

seeks Exemption 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 vess els, 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. 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.**  Ketcham Aerial Imaging 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 DJIPhantom 2 Vision+ and DJIInspire 1 UASs unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safel y operate the DJ I Phantom 2 Vision+ or DJ I Inspire 1 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering Ketcham Aerial Imaging ’s proposed area of operations, and the operating limitations set forth

- above; the parallel nature of private pilot aeronautical27

seeks Exemption knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the DJ I Phantom 2 Vision+ or DJ I Inspire 1 UAS, Ketcham Aerial Im aging submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for Ketcham Aerial Imaging ’s 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, 110 80, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). Ketcham Aerial Imaging will not allow any PIC to operate the DJ I Phantom 2 Vision+ or DJ I Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight

- hour requirements or the DJ I Phantom 2 Vision+ or DJ I Inspire 1 UAS training and currency requirements, that the PIC is able to safely operate the DJ I Phantom 2 Vision+ or DJIInspire 1 UAS in a manner consistent with this exemption, including evasive and
emergency

maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Specificall y, 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 9 0 days (for currency purposes).28

seeks Exemption 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 Ketcham Aerial Imaging ’s 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: 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 th e 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 app ropriate 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. Accordingl y, Ketcham Aerial Imaging will ensure safe operations by not allowing any PIC to operate the DJIPhantom 2 Vision+ or DJIInspire 1 UAS unless that PIC has demonstrated, b y meeting minimum flight

- hour and currency requirements, that the PIC is able to safel y operate the DJIPhantom 2 Vision+ or DJ I Inspire 1 UAS in a manner consistent with the exemption, including evasive and emergency man euvers and maintaining appropriate distances from people, vessels, vehicles and structures.29

seeks Exemption **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, Ketcham Aerial Imaging will ensure that the DJIPhantom 2 Vision+ or DJI Inspire 1 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). **4. Reasons Why An Exemption From The Requirements Of Section 91.121**  **Would Not Adversely Affect Safety.** The equivalent level of safety established b y Section 91.121 will be maintained because the altitude information of the DJ I Phantom 2 Vision+ and DJ I Inspire 1 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 Ketcham Aerial Imaging ’s operation of the DJI Phantom 2 Vision+ and DJ I Inspire 1 UAs within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information will be generated b y GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically established by

the UASs at ground lev el. 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. Exemption30

seeks Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 1 1136, 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 DJ I Phantom 2 Vision+ and DJIInspire 1 UASs; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingl y, Ketcham Aerial Imaging will ensure that it will safel y operate the battery powered DJI Phantom 2 Vision+ and DJ I Inspire 1 UAs during daylight hours in VFR conditions, with enough battery power to fly

for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. Here, as in Exemption No. 11109, the technical specifications of the DJ I Phantom 2 Vision+ and DJ I Inspire 1 UASs; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Phantom 2 Vision+ and DJ I Inspire 1 UASs 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 DJ I Phantom Vision+ and DJ I Inspire 1 UASs will descend and land automaticall y. Significantl y, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversel y affected when the technical characteristics and operatin g limitations of the UAS are considered. Relief has been granted for manned31

seeks Exemption 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). **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, Ketcham Aerial Imaging 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 Ketcham Aerial Imaging will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., the Ketcham Aerial Imaging Operations Manual, Monthly Maintenance Log, and DJ I Phantom 2 Vision+ and DJIInspire 1 Instruction Manual). Furthermore, Ketcham Aerial Imaging will document and maintain all maintenance records for the DJ I Phantom 2 Vision+ and DJIInspire 1 UASs. Since the DJ I Ph antom 2 Vision+ and DJ I Inspire 1 UASs will be inspected as prescribed b y the operating documents, Ketcham Aerial Imaging will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A cop y of the DJ I Phantom 2 Vision+ and DJ I Inspire 1 User Manuals are attached hereto as Exhibit C and D; a cop y of the DJIPhantom 2 Vision+ and DJIInspire 1 UAS Maintenance LOG is attached hereto as Exhibit E.32

seeks Exemption Likewise, the exemption sought will not adversel y affect safety because Ketcham Aerial Imaging will use trained technicians to perform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed b y 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 DJIPhantom 2 Vision+ and DJIInspire 1 UASs will be performed b y trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log. Significantl y, previous exemptions granted b y 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 Ketcham Aerial Imaging ’ s proposed operating limitations, the operating documents, and the technical aspects of the DJ I Phantom 2 Vision+ and DJ I Inspire 1 UASs, Ketcham Aerial Imaging submits that safety will not be adversel y 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, 11 158, 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, Ketcham Aerial Imaging33

seeks Exemption requests that the FAA prescribe special conditions for the intended operation of the DJ I Phantom 2 Vision+ and DJIInspire 1 UASs, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAs for the limited purpose of conducting aerial 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 UA S 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 DJ I Phantom 2 Vision+ and DJ I Inspire 1 UASs, 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. § 21.16.34

seeks Exemption 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 DJ I Phantom 2 Vision+ and DJIInspire 1 UASs, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121 , 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). **F. A Summary That Can Be Published In The Federal Register, stating: The**  **Rules From Which**  **Ketcham Aerial Imaging Seeks**  **Exemption:** Ketcham Aerial Imaging 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 Ketcham Aerial**  **Imaging Seeks:**  This exemption will permit Ketcham Aerial Imaging to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States. **G. Any Additional Information, Views, Or Arguments Available To**  **Support Ketcham Aerial Imaging**  **’s Request.**  This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely

in the NAS. As such, Ketcham Aerial Imaging ’s 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.35

seeks Exemption As discussed in detail above, Ketcham Aerial Im aging will operate the DJ I Phantom 2 Vision+ and DJI Inspire 1 UASs 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, Ketcham Aerial Imaging 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 DJIPhantom 2 Vision+ and DJIInspire 1 UASs commerciall y, without an airworthiness certificate, for the limited purpose o f conducting aerial video and photography over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by

allowing Ketcham Aerial Imaging to safel y, efficientl y, and economicall y operate the DJ I Phantom 2 Vision+ and DJI Inspire 1 UASs commerciall y within the NAS. **WHEREFORE** , in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, Ketcham Aerial Imaging respectfull y 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 DJ I Phantom 2 Vision+ and DJIInspire 1 UASs commerciall y for the purpose ofconducting aerial video and photography over certain areas of the United States. D ated: June 2 2, 201536

seeks Exemption Respectfully submitted, Ketcham Aerial Imaging

/s/ Anthony H. Ketcham Anthony H. Ketcham Ketcham Aerial Imaging 2500 Deer Valley

Rd. 1421 San Rafael, CA 94903 (415) 342

- 9381 ketcham99@comcast.net
Appendices : A

– DJ I Phantom 2 Vision+ Specifications Data Sheet B

– DJ I Inspire 1 Specifications Data Sheet C

– DJIPhantom 2 Vision+ Manufacturer’s User Manual D

– DJ I Inspire 1 Manufacturer’s User Manual E

– Monthly

Maintenance Lo g37

seeks Exemption APPENDIX

– A

**DJI PHANTOM 2 VISION+ TECHNICAL**  **SPECIFICATIONS** Ketcham Aerial Imaging only utilizes safe and reliable UASs. DJ I is an industry leader in small UAS production. DJIUASs are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJIsoftware provides real

- time altitude and loc ation information to the PIC via the linked monitor (smart phone/tablet devices) 1.1 DJIPhantom 2 Vision+ 1.1.1 Aircraft 1.1.1.1 Supported Battery

– DJ I 5200mAH LiPo Battery 1.1.1.2 Weight (Battery

& Propellers Included)

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

(Ready to Fly)

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

- 200 0/s 1.1.1.5 Max Tilt Angel

- 35 0 1.1.1.6 Max Ascent Speed

– 6m/s 1.1.1.7 Max Descent Speed

– 2m/s 1.1.1.8 Max Flight Speed

– 15m/s (NOT RECOMMENDED) 1.1.2 Gimbal 1.1.2.1 Working Current

– Static: 750mA; Dy namic: 900mA 1.1.2.2 Control Accuracy

- ±0.03 0 1.1.2.3 Controllable Range

– Pitch:

- 90 0
- 0 0 1.1.2.4 Maximum Angular Speed

– Pitch: 90 0/s 1.1.3 Camera 1.1.3.1 Operating Temperature Range

- 32 0 F
- 104 0 F (0 0 C

- 40 0 C) 1.1.3.2 Sensor Size

– 1/2.3” 1.1.3.3 Effective Pixels

– 14M 1.1.3.4 Resolution

– 4384x3288 4.1.3.5 HD Video Recording

– 1080p30 & 720p 4.1.3.6 Recording Field of View

- 110 0/85 0 1.1.4 Transmitter 1.1.4.1 Operating Frequency

– 5.728GHz

– 5.85GHz 1.1.4.2 Communication Distance (unobstructed)

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

- - 93dBm 1.1.4.4 Transmitter Power

– FCC Compliance: 100mW 1.1.4.5 Working Voltage

– 120mA@3.7V 1.1.5 Range Extender38

seeks Exemption

1.1.5.1 Operating Frequency

– 2412

- 2462MHz 1.1.5.2 Communication Distance (unobstructed)

– 500

- 700m 1.1.5.3 Transmitter Power

– 20dBm 1.1.5.4 Power Consumption

– 2W39

seeks Exemption APPENDIX

– B

**DJI INSPIRE 1 TECHNICAL**  **SPECIFICATIONS** Ketcham Aerial Imaging only utilizes safe and reliable UASs. DJ I is an industry leader in small UAS production. DJIUASs are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJIsoftware provides real

- time altitude and location information to the PIC via the linked monitor (smart phone/tablet devices) 2.2	DJI	Inspire 1 2.2.1 Aircraft 2.2.1.1 Model

– T600 2.2.1.2 Weight	(Battery	Included)

– 6lbs	7.5291oz (2935g) 2.2.1.3 Hovering	Accuracy	(GPS	Mode)

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

– Pi tch:	300 0/s;	Yaw: 150 0/s 2.2.1.5	Max	Tilt	Angle
- 35 0 2.2.1.6	Max	Ascent	Speed

– 5m/s 2.2.1.7 Max	Descent	Speed

– 4m/s 2.2.1.8 Max	Speed

– 22m/s	(ATTI	mode,	no	wind

– NOT RECOMMENDED) 2.2.1.9 Max	Flight	Altitude

– 4500m 2.2.1.10	Max	Wind	Resistance

– 10m/s 2.2.1.11	Max	Flight Time

– Approximately	18 minutes 2.2.1.12	Motor	Model

– DJI 3510 2.2.1.13 Propeller	Model

– DJI 1345 2.2.1.14 Operating	Temperature	Range

– 14 0F	to	1040F	(

- 10 0C	to 40 0C) 2.2.1.15	Dimensions

– 17	1⁄4”	x	17	3⁄4”	x 12” 2.2.2	Gimbal 2.2.2.1 Model

– ZENMUSE X3 2.2.2.2 Output	Power	(with	camera)

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

– Static:	750mA;	In	Motion: 900mA 2.2.2.4	Angular	Vibration	Range
- ±0.03 0 2.2.2.5 Mounting

– Detachable 2.2.2.6 Controllable	Range

– Pitch:
- 90 0	to	+300;	Pan: ±320 0 2.2.2.7	Mechanical	Range

– Pitch:
- 125 0	to	450;	Pan: ±330 0 2.2.2.8	Max	Controllable	Speed

– Pitch:	120 0/s;	Pan: 180 0/s 2.2.3 Camera 2.2.3.1 Name

– X3 2.2.3.2 Model

– FC350 2.2.3.3	Total	Pixels

– 12.76M40

seeks Exemption

2.2.3.4 Effective	Pixels

– 12.4M 2.2.3.5 Image	Max	Size

– 4000x3000 2.2.3.6	ISO	Range

– 100
- 3200 2.2.3.7 Field	of	View
- 94 0 2.2.3.8 CMOS

– Sony	EXMOR 1/2.3” 2.2.3.9 HD	Video	Recording

– UHD(4K): 4096x2160p24/25, 3840x2160p24/25/30;	FHD:	1920x1080p24/25/30/48/50/60; HD: 1280x720p24/25/30/48/50/60 2.2.3.10 Operating	Temperature	Range
- 32 0F

- 104 0F	(00C

- 40 0C) 2.2.4 Transmitter 2.2.4.1 Name

– C1 2.2.4.2 Operating	Frequency

– 5.728
- 5.850GHz; 2.400
- 2.483GHz 2.2.4.3 Communicating	Distance	(unobstructed)

– 2000m 2.2.4.4 Output	Power

– 9W 2.2.4.5 Operating	Temperature	Range
- 14 0F	to	1040F	(

- 10 0C	to 40 0C) 2.2.4.6 Battery

– 600mAh	LiPo 2S41

seeks Exemption APPENDIX

– C

DJIPhantom 2 Vision+ Manufacturer’s User Manual

http://download.dji

innovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Plus_User_M anual_v1.6_en.pdf42

seeks Exemption APPENDIX

– D

DJIInspire 1 Manufacturer’s User Manual

http: //download.dji

innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.0_en.pdf43

seeks Exemption APPENDIX

– E

**MONTHLY$MAINTENANCE$LOG** month: (year: **UAS$#:$** Date(Issue( Discovered Date(Issue(

Addressed Issue(Description(&(Maintenance(Conducted Maintenance(Performed(By:((( Print(&(Sign Software(Updates Airframe( Engines Propellers Camera(Gimbal Landing(Gear Vibration(Dampening
Other: