UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No.

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Feather Light Media LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIRE MENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 61.101(e)(4) & (5), 61.113(a) & (b), 61.23(a) , 61.315(a), 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 INSPIRE 1

UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112

- 95)

Submitted on April 30, 2015

Jason R. Oppenheimer

Feather Light Media LLC

780 Vine Hill Way

Martinez, CA 94553

T el: (510) 532

- 3200

Email: jason@featherlight.mediaTABLE OF CONTENTS

Page

GLOSSARY OF ABBREVIATIONS

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

SUMMARY

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

INTRODUCTION AND INTERESTS OF PETITIONER.

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

BACKGROUND

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

BASIS FOR PETITION

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

NAME AND ADDRESS OF PETITIONER.

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

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH FEATHER LIGHT

MEDIA LLC SEEKS EXEMPTION

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

THE EXTENT OF RELIEF FEATHER LIGHT MEDIA LLC SEEKS AND THE

REASON FEATHER LIGHT MEDIA LLC SEEKS THE RELIEF...............

. 11

THE REASONS WHY GRANTING FEATHER LIGHT MEDIA LLC’S

REQUEST WOULD BE IN THE PUBLIC INTEREST

.......... ........................... 15

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

ADVERSELY AFFECT SAFETY

................................ ................................ ......... 19

SUMMARY THAT C AN BE PUBLISHED IN THE FEDERAL REGISTER.

.... 34

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS

AVAILABLE TO SUPPORT FEATHER LIGHT MEDIA LLC’S REQUEST....

................................ ................................ ................................ .............................. 34

CONCLUSION

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

APPENDICES........................................................................................37

2GLOSSARY OF AB BREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certi f icate of A uthorizati on

FAA Federal Aviation Administration

FAR Federal Aviation Regula tion

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

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

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

3SUMMARY

Jason R. Oppenheimer seeks exemption from the requireme nts of 14 C.F.R §§

61.101(e)(4) and (5)

, 61.315(a), 6 1.23(a)

, 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 Feather Light Media LLC to operate an Unmanned

Aircraft System (UAS) for the commercial purpose of conducting aerial video and

photography of construction sites, building inspections, agricultural land s, wineries, outdoor

recreational facilities, real estate, special events, and landscape s within the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Feather Light Media LLC will provide its clients with the highest quality digital

content for use in their commercial, personal, and non

- profit multimedia projects. Feather

Light Media LLC will bring together years of professional marketing expertise

, a ward

- winning

production talent and state

- of

- the

- art technology to make studio quality productions within

reac h for organizations of any size. Feather Light Media LLC will also leverage years of

professional civil engineering experience to become a leading provider of geomapping and

image analysis services to the civil engineering and environmental mon itoring industries.

Fea ther Light Media LLC has over 2 years recreational/hobby experience in all aspects of

aerial video and photography. The objective of Feather Light Media LLC aerial video and

photography operations is to provide high quality imaging f or a variety of commercial,

public, and residential uses, specifically targeting:

• Aerial event filming and photography

• Promotional videos for businesses, non

- profits & government entities

• Agricultural surveys and environmental monitoring

• Civil engineering inspection and documentation

4BACKGROUND

Unmanned Aircraft Systems: DJI Inspire 1 UAS

Feather Light Media LLC seeks an exemption to operate DJI systems for

c ompensation or hire within the NAS. The DJI Inspire 1 (Inspire 1) is a vertical takeoff

and land ing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS)

utilizing electronic tablet or smart phone systems. The Inspire 1 is an electric powered

r otary wing UAS that is capable of transmitting live airborne video images and location

informati on to a Ground Control Station (GCS). The Inspire stores the photographs and

data on board and makes them available for download after completion of the flight. The

Inspire is 22 in x 22 in x 8 in and weighs 6.4 pounds, well under the 55 lbs mandated in

th e FMRA. The Inspire can conduct hovering flight and has a maximum cruising speed of

42 knots. It is battery powered, has a flight endurance of 22 minutes and can operate in

temperatures ranging from 0° to 40° C. The Inspire’s omni

- directional antenna has a

range of 2.1 km and operates in the 2.420

– 2.483 GHz frequency range.

The Inspire 1 that will be operated by Feather Light Media LLC will be registered in

accordance with 49 U.S.C. 44103, Registration of Aircraft

, as well as 14

C.F.R Part 47, Aircraft Re gistration

, and marked in accordance with 14 C.F.R. Part 45,

Identification and Registration Marking

.

BASIS FOR PETITION

Petitioner, Feather Light Media LLC, 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 Inspire 1 in the National

Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§

561.101(e)(4) and (5) , 61.315(a), 61.23(a)

, 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 associate d

with the unmanned aircraft and its operation , Feather Light Media’s operation of the DJI

Inspire 1 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, Feather Light Media LLC requests relief from Sections 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth

requirements for maintenance that only apply to aircraft with an airworthiness certificate.

Feather Light Media LLC submits that the requested relief is proper since an

equivalent level of safety will be ensured. Feather Light Media LLC 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., Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual).

Furthermore, Feather Light Media LLC will document and maintain all maintenance

records for the DJI Inspire 1 UAS.

Relief from certain requirements of Section 61.101(e)(4) and (5) entitled

Recreational pilot privileges and limitations: Pilot in command

, and from Section

61.315(a) entitled What are the privileges and limits of my sport pilot certi ficate , and from

Section 61.23(a) entitled Medical certificates: Requirements and duration

, is requested by

Feather Light Media LLC to the extent necessary to allow a Pilot in Command (PIC)

holding a sport pilot or higher level certificate, as well as a va lid driver’s license

, and who

has demonstrated, by meeting minimum flight

- hour and currency requirements, that the

PIC is able to safely operate the DJI Inspire 1 UAS in a manner consistent with this

6exemption, including evasive and emergency maneuvers an d maintaining appropriate

distances from people, vessels, vehicles and structures.

Feather Light Media LLC seeks relief from Section 91.7(a), entitled Civil aircraft

airworthiness

, because the DJI Inspire 1 UAS do not require an airworthiness certificate i n

accordance with 14 C.F.R. Part 21, Subpart H. As such, Feather Light Media LLC submits

that it will ensure that the DJI Inspire 1 UAS are in an airworthy condition, prior to every

flight, by determining that the UASs are in compliance with the operating documents (i.e.,

Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual), and that the aircraft are

in a condition for safe flight.

Feather Light Media LLC also seeks an exemption from the requirements of

Section 91.121, entitled Altimeter Settings

, as the DJI Inspire 1 UA will not have a typical

barometric altimeter onboard. However, altitude information of the DJI Inspire 1 UA will

be provided to the PIC via Global Positioning System (GPS) equipment and radio

communications telemetry data link, whi ch downlinks from the UA to the GCS for active

monitoring of the flight path. This altitude information, combined with Feather Light

Media LLC’s operation of the DJI Inspire 1 UAS within visual line of sight, at or below

500 feet AGL, will ensure a level o f safety equivalent to Section 91.121.

Additionally, Feather Light Media LLC seeks an exemption from the requirements

of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions

. Feather Light

Media LLC submits that safety will not be aff ected by operation of the DJI Inspire 1 UA

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

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

to the first point of intended l anding and, assuming normal cruising speed, to fly after that

for at least 4.5 minutes.

7In accordance with 14 C.F.R. § 11.81, Feather Light Media provides the following

information in support of its petition for exemption:

A. Name And Address Of The Petition er.

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

Jason Oppenheimer

Feather Light Media LLC

780 Vine Hill Way

Martinez, CA 94553

Tel: ( 510) 532

- 3200

Email: jason@featherlight.media

B. The S pecific Sections Of 14 C.F.R. From Which Feather Light Media LLC

Seeks Exemption.

1. Feather Light Media LLC Seeks Exemption From The Requirements Of

Section 61.101(e)(4) and (5 ).

Section 61.101

, entitled Recreational pilot privileges and limitations: Pilot in

command , subsection (e ) (4) and (5) prescribe the following, in relevant part:

(e) Except as provided in paragraphs (d) and (i) of this section, a recreational pilot

may not act as pilot in command of an aircraft

--

(4) For compensation or hire;

(5) In furtheranc e of a business;

2. Feather Light Media LLC Seeks Exemption From The Requirements Of

Section 61.23(a)

.

Section 61.23(a), entitled Operations requiring a m edical certificate: Requirements

and duration , subsection (a) prescribe the following, in relevant par t:

(f) Except as provided in paragraphs (d) and (i) of this section, a recreational pilot

may not act as pilot in command of an aircraft

--

83. Feather Light Media LLC Seeks Exemption From The Requirements Of

Section 61.315(a).

Section 61.315(a), entitled What a re the privileges and limits of my sport pilot

certificate , subsection (a) prescribe the following, in relevant part:

(c) You may not act as pilot in command of a light

- sport aircraft:

(2) For compensation or hire.

(3) In furtherance of a b usiness.

--

4. Feather Light Media LLC 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 co ndition.

5. Feather Light Media LLC 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 fli ght

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 airp ort or an appropriate altimeter setting available before

departure.

96. Feather Light Media LLC Exemption From The Requirements Of

Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions

, subsection

(b), states the followin g:

(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.

7. Feather Light Media LLC 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 in spected 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[.]

8. Feather Light Media LLC From The Requireme nts 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

main tenance, rebuilding, or alteration unless

--

(1) It has been approved for return to service by a person authorized under §

43.7 of this chapter[.]

9. Feather Light Media LLC Seeks Exemption From The Requirements Of

Sections 91.409(a)(1) a nd 91.409(a)(2).

Sectio n 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

10with part 21 of this chapter.

10. Feather Light Media LLC Exemption From The Requirements Of

Sections 91.417(a) a nd 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 o r 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

ins pections, 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; an d

(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, e ach 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

11major 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 specif ied 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 th e 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.

C. The Extent Of Re lief Feather Light Media LLC Seeks And The Reason Feather

Light Media LLC Seeks The Relief.

1. Extent Of Relief Feather Light Media LLC Seeks And The Reason

Feather Light Media LLC Seeks Relief From Section 61.113(a) a nd

(b).

Relief from Section 61.113(a) a nd (b) entitled Private pilot privileges and

limitations: Pilot in command

, is requested to the extent necessary to allow a PIC holding a

private pilot or higher level certificate, as well as a current and valid airman medical

certificate, and who has met certain flight

- hour and currency requirements, to conduct the

proposed UAS flight operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b)

state that a private pilot may, for compensation or hire, act as PIC of an aircraft in

connection with any business or employment if: (1) The flight is only incidental to that

business or employment; and (2) The aircraft does not carry passengers or property for

compensation or hire.

As set forth more full y below, Feather Light Media LLC submits that an equivalent

level of safety will be maintained because no PIC will be allowed to operate the DJI Inspire

1 UAS UA unless that PIC has met certain flight

- hour and currency requirements,

12demonstrating that the PIC is able to safely operate either the DJI 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, vessel s, vehicles and structures.

Further, Feather Light Media LLC submits that all flights of the DJI Inspire 1 UAS,

conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to Feather

Light Media LLC business; and (2) will not carry passengers or property for compensation

or hire.

2. Extent Of Relief Feather Light Media LLC Seeks And The Reason Feather

Light Media LLC Seeks Relief From S ection 6 1.23(a)

.

Relief from Section 61.23(a), entitled Operations requiring a medical certificate:

Requirements and duration, is requested to the extent required to necessary to allow a PIC

holding a sport pilot certificate or higher level certificate, as well as a current and valid

driver ’ s license, to conduct the proposed UAS flight operations for compensation or hire.

This relief is req uested since the limita tions set forth in Section 61.2 3(a) otherwise

require the PIC of an y flight for compensation or hire to hold a comprehensive FAA i ssued

medical certificate

. In E xemption No. 11213 to Aeryon Labs, Inc., the FAA “ finds that,

beca use of the risk mitigations established in the conditions and limitations of this

exemption, a person that holds a U.S. issued driver’s license who is operating a UAS will

not adversely affect safety. The FAA is granting relief from § 61.23(a) to allow any pilot

that holds one of the pilot’s certificates discussed above to operate a UAS under this

exemption with a U.S. issued driver’s license, in lieu of an FAA

- issued medical certificate.

The FAA is also granting relief from § 61.23(c) to allow sport pilot certificate holders to

operate aircraft other than LSA with a U.S. issued driver’s license under this exemption. ”

133. Extent Of Relief Feather Light Media LLC Seeks And The Reason Feather

Light Media LLC Seeks Relief From Section 61.315(a).

Relief from Section 61.315 (a) entitled What are the privileges and limits of my

sport pilot certificate

, is requested to the extent necessary to allow a PIC holding a s port

pilot or higher level certificate to conduct the proposed UAS flight operations for

compensation or hire.

This relief is requested since the limitat ions set forth in Section 61.315 (a) restric t a

sport p ilot from acting as the PIC of any flight for compensation or hire, or for the

furtherance of any business.

In E xemption No. 1121 3 to Aeryon Labs, Inc., the FAA re

- assessed the level of

pilot cert ificate that would be appropriate for the petitioner’s operations. In evaluating this

petition, similar to the evaluation of the private and commercial pilot certificates in

Exemption No. 11062, the agency compared the aeronautical knowledge requirements o f

the recreational and sport pilot certificates to those of th e private pilot certificate. They

found that the aeronautical knowledge requirements that would be applicable to a UAS

operation for a recreational pilot and sport pilot certi ficate are substantially similar as those

for a private pilot certificate.

Additionally, similar to the private and commercial pilot certificates, holders of

recreational and sport pilot certificates are subject to security screening by the Department

of Homeland Security (DHS).

Therefore, because they must demonstrate aeronautical knowledge relevant to UAS

operations and are subject to DHS screening, factors that were considered by the FAA in

allowing private pilot operations under previous exemptions, t he FAA now determines that

holders of recreational and sport pilot certificates may serv e as the PIC for UAS

operations.

144. Extent Of Relief Feather Light Media LLC Seeks And The Feather Light

Media LLC Seeks Relief From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness

, is requested to the

ext ent required to allow Feather Light Media LLC to determine that the DJI Inspire 1 UAS

are in airworthy condition prior to every flight by ensuring that the UAS is in compliance

with the operating documents (i.e., the DJI Inspir e 1 Maintenance Manual

, Monthly

Maintenance Log, and DJI Inspire 1 Instruction Manual).

Feather Light Media LLC seeks the requested relief because the DJI Inspire 1 UAS

do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Therefo re, Feather Light Media LLC will ensure that the DJI Inspire 1 UAS are in

airworthy condition based upon its compliance with the operating documents (i.e., Monthly

Maintenance Log, and DJI Inspire 1 Instruction Manual) prior to every flight, and further,

d etermine that the aircraft are in condition for safe flight, as stated in the conditions and

limitations below.

5. Extent Of Relief Feather Light Media LLC Seeks And The Reason Feather

Light Media LLC Seeks Relief From Section 91.121.

Relief from Section 91. 121, entitled Altimeter settings, may be required to allow

flight operations of the DJI Inspire 1 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), Feather Light Media LLC seeks the

requested relief becau se the 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.

15Considering the limited altitude of the proposed operations, relief from 14 CFR

91.121 is soug ht 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 Inspire 1 UAs are equipped with a barometric pressure sensor

an d 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.

6. Extent Of Relief Feather Light Media LL C Seeks And The Feather Light

Media LLC 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

Inspire 1 UAs dur ing daylight hours in visual meteorological conditions (VMC), under

visual flight rules (VFR), for a total duration of 13.5 minutes to the first point of intended

landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

Feat her Light Media LLC seeks the requested relief because without an exemption from

Section 91.151(b), the flight time duration of the battery powered DJI Inspire 1 UA will

severely constrain the practicality of any aerial video or still photo flight operatio ns that

Feather Light Media proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the DJI Inspire 1

UAS, the DJI Inspire 1 operating documents, and Feather Light Media LLC’s proposed

operating lim itations, ensure that Feather Light Media LLC will safely operate the battery

powered DJI Inspire 1 UAs during daylight hours in visual meteorological conditions

(VMC), under visual flight rules (VFR), with enough battery p ower 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.

167. Extent Of Relief Feather Light Media LLC Seeks And The Reason Feather

Light Media LLC Seeks Relief From Sections 91.405 (a), 91.407 (a)(1),

91.409(a)(1) & (a)(2), a nd 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, Feather Light Media LLC requests

relief from these Sections because the DJI Inspire 1 UAS does not require airworthiness

certificates. As set forth more fully below, the DJI Inspire 1 UAS meets the conditions of

FMRA Section 333 for operation without an airworthiness certificate. Accordingly, Feather

Light Media LLC 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 DJI Inspire 1 Maintenance Manual,

Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, Feather

Light Media will document and maintain all maintenance records for the DJI Inspire 1

UAS.

D. The Reasons Why Granting Feather Light Media LLC Request Would Be In

The Publi c Interest; That Is, How It Would Benefit The Public As A Whole.

Granting the present Petition will further the public interest by allowing Feather

Light Media LLC to safely, efficiently, and economically conduct aerial video and

photography of construction sites, building inspections, agricultural lands, wineries, outdoor

recreational facilities, real estate, special events, and landscapes over certain areas of the United

States.

Additionally, use of the DJI Inspire 1 UAS will decrease congestion of the NAS,

reduce pollution, and provide significant benefits to the economy. Notably, the benefits of

Feather Ligh t Media LLC’s proposed operation of the DJI Inspire 1 UAS will be realized

without implicating any privacy issues.

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

The DJI Inspire 1 UA S are battery powered and serve as a safe, efficient, and

economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery.

By reducing the amount of manned aircraft needed to perform aerial acquisitions, an

exemption allowing the use of a DJI Inspire 1 UAS would reduce the amount of manned

aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and

property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS,

congestion around airports caused by arriving and departing aircraft will be reduced. The

DJI Inspire 1 UA S 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 handle d 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

Inspire 1 UAS.

Conducting aerial acquisitions with the DJI Inspire 1 UAS, i nstead of manned

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

pollution generated during traditional aerial video and still photography flight operations.

By using battery power and electric motors, the DJI Inspire 1 UAS produce no air

pollution, and is the most viable environmentally conscious alternative to the cabin class,

six cylinder internal combustion engine aircraft that are typically utilized for aerial video

and photography, while burning approximat ely 20

- 30 gallons per hour of leaded aviation

fuel. The DJI Inspire 1 UA S

, while reducing the carbon footprint of aerial acquisitions,

also eliminates noise pollution, as the UA S s are propelled by battery powered electric

motors, rather than an internal com bustion engine.

18By using the DJI Inspire 1 UAS 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 re duced or completely

eliminated. Aside from the lack of flight crew members located onboard the aircraft, the

DJI Inspire 1 UA S (weighing approximately 6 .5 pounds maximum gross weights with a

length of 17.3 inches

, width of 17.7 inches

, and with no fuel on board), has less physical

potential for collateral damage to life and property on the ground, and in the air, compared

to the manned aircraft that t ypically 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).

3. Performing Aerial Video and Photography Operations With The DJI

Inspire 1 UAS Will Benefit The Economy.

In addition to being safe and efficient, the DJI Inspire 1 is also an economical

alternative to using manned aircraft to conduct similar aerial operations. As such, operation

of the DJI Inspire 1 UAS will allow United States based co mpanies, like Feather Light

Media LLC, to remain competitive and contribute to growth of the U.S. economy.

Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency

(“EPA”) regulatory actions phasing out leaded aviation fu els, U.S. owned and operated

companies must adopt new and alternative technology in order to remain competitive.

Operating the battery powered DJI Inspire 1 UAS is one such technology that not only

allows companies greater operational flexibility compared to manned aircraft, but provides

such flexibility without the high operational cost of a traditional manned aircraft.

By operating the DJI Inspire 1 UAS, companies such as Feather Light Media LLC,

can remain competitive and profitable, and therefore, prov ide greater job stability to

employees and contractors, which will ultimately contribute to growth of the U.S.

19economy. Improved financial performance of U.S. companies, through commercial use of

the DJI Inspire 1 UAS, provides a stable workforce that incr eases 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 ae rial acquisition flight operations that have been conducted for

decades, Feather Light Media LLC proposed operation of the DJI Inspire 1 UAS will not

implicate any privacy issues. Specifically, the DJI Inspire 1 UAS will be operated only in

compliance with the conditions set forth in any exemption granted under this petition

.

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

Prov ided By The Rule From Which Feather Light Media LLC Seeks Exemption.

1. Reasons Why The DJI Inspire 1 UA Meet The Conditions Of The FAA

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

In consideration of the size, weight, speed, and limited operati ng area associated

with the unmanned aircraft and its operation, Feather Light Media LLC operation of the

DJI Inspire 1 UAS meet the conditions of FMRA Section 333, and will not require an

airworthiness certificate in accordance with 14 C.F.R. Part 21, Sub part H.

S ection 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 securit y.

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 ce rtain 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.

20(b) Assessment of Unmanned Aircraft System s.

-- 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 are as, 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 certific ation 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 ai rcraft 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, Feather Light Media LLC submits that the DJI Inspire 1

UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by:

(a) the characteristics of the DJI Inspire 1 UAS; (b) the pilot certification requirement; and

(c) the specific operating limitations.

a. The Specifications Of The DJI Inspire 1 UAS Demonstrate Its Safe

Characteristics.

The DJI Inspire 1 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 capabilit y.

i. Technical Specifications Of The DJI Inspire 1 UAS.

The technical specifications of the DJI Inspire 1 UAS is set forth by the DJI Inspire

1 Specifications and Data Sheet, attached hereto as Exhibit A.

ii. The DJI Inspire 1 UAS Autonomous Flight And Navigati on Modes

Enable The UAS To Remain Within A Defined Operational Area.

The DJI Inspire 1 UAS may be operated in both manual and fully autonomous flight

modes. A complete description of the flight and navigational modes of the DJI Inspire 1

21UAS is provided i n the DJI Inspire 1 User Manual, attached hereto as Exhibit B.

iii. The DJI Inspire 1 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 Ins pire 1 UA will remain stationary, in

flight, for 3 seconds or more. If, after 3 seconds, the DJI Inspire 1 UA does not reacquire

control link data from the GCS, the UA will assume that the Control Link is lost and the

UA will return to the home position (i .e., failsafe mode) via GPS, and will descend to the

takeoff position and shutdown.

A complete description of the Failsafe Functions of the DJI Inspire 1 UAS are set

forth i n the DJI Inspire 1 User Manual, attached hereto as B.

iv. The DJI Inspire 1 GCS And Its Operation.

A complete description of the operation and specifications of the DJI Inspire 1 GCS

and flight control software is provided i n the DJI Inspire 1 User Manual. DJI Inspire 1 User

Manual is attached hereto as Exhibit B.

b. Flight Operations Of DJI Inspire 1 UAS Are Limited To The Line Of

Sight Of A Certificated Pilot in Command With A Safety Observer.

Feather Light Media LLC will only utilize certificated pilots who possess a current

and valid airman m edical certificate to act as a pilot in command (PIC) of the DJI Inspire 1

UAS. Additionally, a safety observer will assist all pilots during flight time.

c. Flights Of DJI Inspire 1 UAS Will Be Conducted Pursuant To Specific

Operating Limitations.

In seekin g this exemption, proposes to commercially operate DJI Inspire 1 UAS for

the special purpose of conducting aerial video and photography over certain areas of United

States, pursuant to the following specific operating limitations:

1. Operations authorized by this grant of exemption will be limited to the following

aircraft described in the operating documents, rotorcraft UASs weighing less than

55 pounds maximum gross weight: DJI Inspire 1 Unmanned Aircraft System.

22Proposed operations of any other aircraft wil l 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 500 feet above ground

level (AGL), as indicated by the procedures specified in the operating

documents unless a special request is made and approved by ATC. All 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

cer tificate.

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 fli ght. 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/obstructio ns 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 condi tions 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 t he 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 op erator 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 op erator 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 ens ure that it is in a

23condition 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

co ndition 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 UA S

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 accou nt 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, replac ement, 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 al l manufacturer

Safety Bulletins.

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

corrective action taken against discrepancies discovered between inspections.

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

third

- class medical certificate.

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

operator’s qualification criteria and demonstrates the ability to safely operate the

UAS in a manner consistent with how the UAS will be ope rated 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). Fligh ts 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 pe rsons 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

24conditions (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

c onducted 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 fee t

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 ac cordance 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 weat her 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, reg istered 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 opera tion

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 C ontrol 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.

2529. The UA must remain clear and yield the right of way to all manned aviation

operations and act ivities 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 person s),

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/c ontroller 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 represent ative.

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.

Feather Light Media LLC submits that the equivalent level of safety established by

Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the

DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight

- hour and

currency requirements, that the PIC is able to safely operate the DJI 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.

26Considering Feather Light Media LLC proposed area of operations, and the

operating limitations set forth

- above; t he parallel nature of sport pilot aeronautical

knowledge requirements to those of commercial pilot requirements ( See Exemption No.

11062); and the airmanship skills necessary to safely operate the DJI Inspire 1 UAS,

Feather Light Media LLC submits that the additional manned airmanship experience of a

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

Feather Light Media LLC 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, 11 161).

Feather Light Media LLC will not allow any PIC to operate the DJI Inspire 1 UAS

unless that PIC has demonstrated, by meeting minimum flight

- hour requirements or the

DJI Inspire 1 UAS training and currency requirements, that the PIC is able to safely

operate the DJI Inspire 1 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 additi on 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

27experience that was obtained in compliance with applicable regulations will ensure an

equivalent level of safety during Feather Light Media LLC proposed operations. The

Administrator has held that prior documented flight experience that was obtained in

compliance with applicable regulations would ensure safe opera tions, 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

op erating 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 hour s 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 tha t 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, Feather Light Media will ensure safe operations by not allowing any

PIC to operate the DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting

minimum flight

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

DJI 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.

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

28because prior to every flight, Feather Light Media LLC will ensure that the 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 by Section 91.121 will be maintained

because the altitude information of the DJI Inspire 1 UA S will be provided to the PIC via

GPS equipment and a radio communications telemetry data link, which downlinks from

the UA S to the GCS for active monitoring of the flight path and a ltitude. This altitude

information, combined with Feather Light Media LLC’s operation of the DJI Inspire 1

UA S 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 b e generated by GPS

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

is automatically established by the UASs at ground level.

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

circ umstances 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 Fro m 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

2914 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJI Inspire

1 UAs; (2) the limitations on the proposed flight operations; and (3) the location of the

proposed flight operations. Accordingly, Feather Light Media will ensure that it will safely

operate the battery powered DJI Inspire 1 UA 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 specifi cations of the DJI Inspire 1

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 t he DJI Inspire 1 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. A t the critically low battery level, the DJI

Inspire 1 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 characteristic s 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 r elief

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, 111 53, 11156,

11157, 11158, 11159, 11160, 11161).

306. 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, Feather Light Med ia LLC submits that the equivalent

level of safety with regard to the regulatory maintenance and alteration requirements

established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b)

will be met because Feather Light Media LLC 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 DJI Inspire 1

Maintenance Manual

, Monthly Main tenance Log, and DJI Inspire 1 Instruction Manual).

Furthermore, Feather Light Media LLC will document and maintain all maintenance

records for the DJI Inspire 1 UAS.

Since the DJI Inspire 1 UAS will be inspected as prescribed by the operating

documents, F eather Light Media LLC 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

Inspire 1 User Manuals are attached hereto as Exhibit B; a copy of the DJI Inspire 1

Maintenance Manual is attached hereto as Exhibit C ; a copy of the DJI Inspire 1 UAS

Maintenance LO G is attached hereto as Exhibit D

.

Likewise, the exemption sought will not adversely affect safety because Feather

Light Media LLC will use trained technicians to perform maintenance, alterations or

preventive m aintenance on the UAS using the methods, tech niques, 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 Inspire 1 UAS will be pe rformed by trained technicians. Maintenance will be

documented and maintained utilizing the monthly maintenance log.

31Significantly, 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 Feather Light Media LLC proposed operating limitations, the

operating documents, and the technica l aspects of the DJI Inspire 1 UAS, Feather Light

Media LLC submits that safety will not be adversely affected by granting exemption from

14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b).

The FAA has previously gra nted 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, 111 60, 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, Feather Light Media LLC

requests that the FAA prescribe special conditions for the intended operation of the DJI

Inspire 1 UAS, which contain such safety standards that the Administrator finds necessary

to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H,

and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe

operation of the UAs for the limited purpose of conducting aerial video and photogra phy

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 fu rther, provides the

32authority 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 condition s pursuant to 14 C.F.R.

§ 21.16, for operation of the DJI Inspire 1 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 u nusual 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 Inspire

1 UAS, which contain such safety standards that the Administrator finds necessary to

establish a level of safety equivalent to that established by 14 C.F.R. Part 21,

Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a),

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

F. A Summary That Can Be Published In The Federal Register, stating: The Rules

From Which Feather Light Media LLC Seeks Exemption:

Feather Light Media LLC seeks exemption from the requirements of 14 C.F.R

Sections 61.101(e)(4) and (5), 61.315(a), 61.23(a), 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 T he Exemption Feather Light Media

LLC Seeks:

This exemption will permit Feather Light Media LLC to commercially operate an

33Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and

photography over certain areas of the United States.

G. A ny Additional Information, Views, Or Arguments Available To Support Feather

Light Media LLC 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 determ ine if certain

UAS may operate safely in the NAS. As such, Feather Light Media LLC 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 fo r 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 abo ve, Feather Light Media LLC will operate the 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, Feather Light Media LLC seek s 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 Inspire 1 UAS commercially,

without an airworthiness certificate, for the limited purpose of con ducting 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 Feather

Light Media LLC to safely, efficiently, and economically operate the DJI Inspire 1 UAS

34commercially within the NAS.

WHEREFORE

, in accordance with the Federal Aviation Regulations and the FAA

Modernization and Reform Act o f 2012, Section 333, Feather Light Media LLC

respectfully requests that the Administrator grant this Petition for an exemption from the

requirements of 14 C.F.R Sections 61.101(e)(4) and (5), 61.315(a), 61.23(a), 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

Feather Light Media LLC to operate the DJI Inspire 1 UAS commercially for the purpose

of conducting aerial video and photography over areas of the United States.

Dated: April 30, 2015

Respectfully submitted,

Jason Op penheimer

Jason R. Oppenheimer

Feather Light Media LLC

780 Vine Hill Way

Martinez, CA 94553

Tel: (510 ) 532

- 3200

Email: jason@featherlight.media

35E xhibits :

A

– DJI Inspire 1 Specifications Data Sheet

B

– DJI Inspire 1 Manufacturer’s User Manual

C

– DJI Inspire 1 M aintenance Manual

D

– Monthly Maintenance Log

E XHIBIT

– A

DJI Inspire 1 Specifications Data Sheet

36DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

Aircraft Model

T600

Weight (Battery Inclu ded)

2935 g

Hovering Accuracy (GPS Mode)

Vertical: 0.5 m

Horizontal: 2.5 m

Max Angular Velocity

Pitch: 300°/s

Yaw: 150°/s

Max Tilt Angle

35°

Max Ascent Speed

5 m/s

Max Descent Speed

4 m/s

Max Speed

22 m/s (ATTI mode, no wind)

Max Flight Altitude

4500 m

Max Wind Speed Resistance

10 m/s

Max Flight Time

Approximately 18 minutes

Motor Model

DJI 3510

Propeller Model

DJI 1345

Indoor Hovering

Enabled by default

Operating Temperature Range

- 10° to 40° C

Diagonal Distance

559 to 581 mm

Dimensions

438x451x301 mm

Gim bal Model

ZENMUSE X3

Output Power (With Camera)

Static: 9 W

In Motion: 11 W

Operating Current

Station: 750 mA

Motion: 900 mA

Angular Vibration Range

±0.03°

Mounting

Detachable

Controllable Range

Pitch:

- 90° to +30°

37Pan: ±320°

Mechanical Range

Pitch:

- 125° to +45°

Pan: ±330°

Max Controllable Speed

Pitch: 120°/s

Pan: 180°/s

Camera Name

X3

Model

FC350

Total Pixels

12.76M

Effective Pixels

12.4M

Image Max Size

4000x3000

ISO Range

100

- 3200 (video)

100

- 1600 (photo)

Electronic Shutter Speed

8s

- 1/8000s

FOV (Field Of View)

94°

CMOS

Sony EXMOR 1/2.3”

Lens

20mm (35mm format equivalent)f/2.8 focus at ∞

9 Elements in 9 groups

Anti

- distortion

Still Photography Modes

Single shoot

Burst shooting: 3/5/7 frames

Auto Exposure Bracketing (AEB): 3/5 bracketed frames at 0.7EV B ias

Time

- lapse

Video Recording Modes

UHD (4K): 4096x2160p24/25, 3840x2160p24/25/30

FHD: 1920x1080p24/25/30/48/50/60

HD: 1280x720p24/25/30/48/50/60

Max Bitrate Of Video Storage

60 Mbps

Supported File Formats

FAT32/exFAT

Photo: JPEG, DNG

Video: MP4/MOV (MPEG

- 4 AVC/H.264)

Supported SD Card Types

Micro SD

Max capacity: 64 GB. Class 10 or UHS

- 1 rating required.

Operating Temperature Range

0° to 40° C

38Remote

Controller Name

C1

Operating Frequency

922.7~927.7 MHz (Japan Only)

5.725~5.825 GHz

2.400~2.483 GHz

Tran smitting Distance (Outdoor And Unobstructed)

2 km

EIRP

10dBm@900m, 13dBm@5.8G, 20dBm@2.4G

Video Output Port

USB, mini

- HDMI

Power Supply

Built

- in battery

Charging

DJI charger

Dual User Capability

Host

- and

- Slave connection

Mobile Device Holder

Tablet or Phon e

Max Mobile Device Width

170mm

Output Power

9 W

Operating Temperature Range

- 10° to 40° C

Storage Temperature Range

Less than 3 months:

- 20° to 45° C

More than 3 months: 22° to 28° C

Charging Temperature Range

0

- 40° C

Battery

6000 mAh LiPo 2S

Charger Mod el

A14

- 100P1A

Voltage

26.3 V

Rated Power

100 W

Battery

(Standard) Name

Intelligent Flight Battery

Model

TB47

Capacity

4500 mAh

Voltage

22.2 V

Battery Type

LiPo 6S High voltage battery

Energy

3999.9 Wh

Net Weight

570 g

Operating Temperature Range

- 10° to 40° C

Storage Temperature Range

Less than 3 months:

- 20° to 45° C

More than 3 months: 22° C to 28° C

Charging Temperature Range

0° to 40° C

Max Charging Power

180 W

Vision

Positioning Velocity Range

Below 8 m/s (2 m above ground)

Altitude Range

5

- 500 cm

Oper ating Environment

Brightly lit (lux > 15) patterned surfaces

Operating Range

0

- 250 cm

40E xhibits :

A

– DJI Inspire 1 Specifications Data Sheet

B

– DJI Inspire 1 Manufacturer’s User Manual

C

– DJI Inspire 1 M aintenance Manual

D

– Monthly Maintenance Log

E XHIBIT

– B

DJI Inspire 1 Manufacturer’s User Manual

41E xhibits :

A

– DJI Inspire 1 Specifications Data Sheet

B

– DJI Inspire 1 Manufacturer’s User Manual

C

– DJI Inspire 1 M aintenance Manual

D

– Monthly Maintenance Log

E xhibit

– C

DJI Inspire 1 M aintenance Manual

42E xhibits :

A

– DJI Inspire 1 Specifications Data Sheet

B

– DJI Inspire 1 Manufacturer’s User Manual

C

– DJI Inspire 1 M aintenance Manual

D

– Monthly Maintenance Log

E XHIBIT

– D

Monthly Maintenance Log

43EXHIBIT

– D

MON THLY 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:

Jason R. Oppenheimer

Feather Light Media LLC

780 Vine Hill Way

Martinez, CA 94553

Tel: (510) 532

- 3200

Email: jason@featherlight.media

44