LockheedMartin Aeronautics Company 86 South Cobb Drive Marietta, GA 30063


### Coleen Thornton 

### LOCKHEED MARTIN=* August 24,2015


### Reference CAP 15-052

Aviation Safety andAirworthiness- Engineering and Technical Operations
U.S. Department ofTransportation, Docket Operations West Building Ground Floor, Room W12-140 1200 New Jersey Avenue, SE Washington, DC 20590

Subject: Lockheed MartinAeronautics Exemption Request for Section 333 ofFAA Modernization and Reform Act of2012
Dear Sir or Madam,
LockheedMartin Aeronautics 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)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b), to operate an UnmannedAircraft System (UAS) pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA). This exemption will permit Lockheed Martin Aeronautics to operate a UAS for the purpose ofconducting aerial video and photography over certain areas ofthe United States.


### Use And Interests OfThe Petitioner
The objective ofLockheed Martin Aeronautics' aerial video and photography operations is to provide high quality imaging for a variety ofcommercial uses. 

### Background Lockheed Martin Aeronautics seeks an exemption to operate DJI systems within the national air space (NAS). DJI Inspire 1 is a vertical takeoffand landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smartphone systems. The DJI Inspire 1has a maximum gross weight of6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed ofapproximately 45 knots. The DJI Inspire 1 UAS is equipped with four main rotors; driven by Lithium Polymerbatterypowered electric motors.
The DJI Inspire 1that will be operatedby Lockheed Martin Aeronautics will be registered in accordance with 49 U.S.C. 44103, 

### Registration of Aircraft, as well as 14 C.F.R Part 47,

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

### Identification andRegistration Marking.


### Basis For Petition Petitioner, Lockheed Martin Aeronautics, pursuant to the provisions ofthe Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of2012 (FMRA), Section 333, Special 

### Rules for Certain UnmannedAircrqftSystems, hereby petitions the Administratorto commercially operate the DJI Inspire 1UAS inthe 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)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b). In consideration ofthe speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, Lockheed Martin Aeronautics operation of the DJI Inspire I UAS meets the conditions ofFMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.


### 1Accordingly, Lockheed Martin Aeronautics requests relieffrom Sections 91.405(a), 91.407(a)(1), 91.409(a)(l) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate.
Lockheed Martin Aeronautics submits that the requested reliefis proper since an equivalent level ofsafety will be ensured. Lockheed Martin Aeronautics will use experiencedpersonnel ortechnicians to perform maintenance, alterations, orpreventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, Lockheed Martin Aeronautics will document and maintain all maintenance records for the DJI Inspire 1UAS.
Relieffrom certain requirements ofSection 61.113(a) and 

### (b), entitled 

### Privatepilotprivileges and limitations: Pilot in command, is requested by Lockheed Martin Aeronautics to the extent necessary to allow a Pilot in Command (PIC) holding a private pilot orhigher level certificate, as well as an airman medical certificate, and who has demonstrated, bymeeting 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 exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, aircraft, vehicles and structures.
Lockheed Martin Aeronautics seeks relieffrom Section 91.7(a), entitled 

### Civil aircraft airworthiness, because the DJI Inspire 1UAS does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, LockheedMartin Aeronautics submits that we will ensure that the UAS is in an airworthy condition, prior to every flight, by determining that the UAS is 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.
Lockheed Martin also seeks an exemption from the requirements ofSection 91.121, entitled

### Altimeter Settings, as the DJI Inspire 1UAS will not have a typical barometric altimeter onboard. However, altitude information ofDJI Inspire 1 UAS will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UAS to the GCS for active monitoring ofthe flight path. This altitude information, combined with Lockheed Martin Aeronautics' operation ofthe DJI Inspire 1 UAS within visual line ofsight, at or below 500 feet AGL, will ensure a level ofsafety equivalent to Section 91.121. Additionally, Lockheed Martin Aeronautics seeks an exemption from the requirements ofSection 91.151(b), entitled 

### Fuel requirements for flight in VFR conditions. Lockheed Martin Aeronautics submits that safety will notbe affected by operation ofthe DJI Inspire 1 UAS during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enoughbattery powerto fly for a total duration ofapproximately 13.5 minutes to the first point ofintended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.
In accordance with 14 C.F.R. 

### § 11.81, Lockheed Martin Aeronautics provides the following information in support ofits petition for exemption:


### A. Name And Address OfThePetitioner. Lockheed Martin Aeronautics Aviation Safety and Airworthiness 86 South Cobb Drive Marietta, GA 30063-0579



## 2

### B. The Specific Sections Of 14 C.F.R. From Which Lockheed Martin Aeronautics Seeks Exemption. B.l. Lockheed Martin Aeronautics Seeks Exemption From The Requirements OfSection 61.113(a) And (b). Section 61.113, entitled Private pilot privileges and limitations: 

### Pilot in command, subsections (a) and (b) prescribe the following, in relevant part: (a) No person who holds a private pilot certificate may act as a pilot in command (PIC) ofan aircraft that is carrying passengers orproperty for compensation orhire; nor may that person, for compensation orhire, act as PIC ofan aircraft. 

### (b) A private pilot may, for compensation orhire, act as PIC ofan aircraft in connection with any business oremployrnentif-- (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers orproperty for compensation orhire. 

### B.2. Lockheed Martin Aeronautics Seeks Exemption From The Requirements OfSection 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. 

### B.3. Lockheed Martin Aeronautics Seeks Exemption From The Requirements OfSection 91.121. Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: (a) Eachperson operating an aircraft shall maintainthe cruising altitude or flight level ofthat aircraft, as the case may be, byreference to an altimeter that is set, when operating-- (!) Below 18,000 feet MSL, to-- (i) The currentreported altimeter setting ofa station along the route and within 100 nautical miles ofthe aircraft; (ii) Ifthere is no station within the area prescribed in paragraph (a)(1)(i) ofthis section, the current reported altimeter setting ofan appropriate available station; or (iii) In the case ofan aircraft not equipped with a radio, the elevation ofthe departure airport or an appropriate altimeter setting available before departure. 

### B.4. Lockheed Martin Aeronautics Seeks Exemption From The Requirements OfSection 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 ofintended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes. 

### B.S. Lockheed Martin Aeronautics Seeks Exemption From The Requirement OfSection 91.405(a). Section 91.405, entitled 

### Maintenance required, subsection (a), states the following: Each owner or operator ofan aircraft-- (a) Shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter[.] 

### B.6. Lockheed Martin Aeronautics Seeks Exemption From The Requirements OfSection 91.407(a)(1) Section 91.407, entitled 

### Operation after maintenance,preventive maintenance, rebuilding, or alteration, subsection (a)(l), states the following: (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless-- (!) Ithas been approved for return to service by a person authorized under§ 43.7 ofthis chapter[.] 

### B.7. Lockheed Martin Aeronautics Seeks Exemption From The Requirements OfSections 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) ofthis section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

--


### 3(1) An annual inspection in accordance with part43 ofthis chapter andhas been approved for return to service by a person authorizedby§ 43.7 ofthis chapter; or (2) An inspection for the issuance ofan airworthiness certificate in accordance with part 21 ofthis chapter. 

### B.S. Lockheed Martin Aeronautics Seeks Exemption From TheRequirements OfSections 91.417(a) And 91.417(b). Section 91.417, entitledMaintenance records, subsections (a) and (b), state the following: (a) Except for work performed in accordance with§§ 91.411 and 91.413, eachregistered owner or operator shall keep the following records for the periods specified inparagraph (b) ofthis section: (1) Records ofthe maintenance, preventive maintenance, and alteration andrecords ofthe 100-hour, annual, progressive, and otherrequired or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance ofan aircraft. The records must include-- (i) A description (orreference to data acceptable to the Administrator) ofthe workperformed; and (ii) The date ofcompletion ofthe workperformed; and (iii) The signature and certificate number ofthe person approving the aircraft for return to service. (2) Records containing the following information: (i) The total time in service ofthe airframe, each engine, eachpropeller, and eachrotor. (ii) The current status oflife-limitedparts ofeach airframe, engine, propeller, rotor, and appliance. (iii) Thetime since last overhaul ofall items installed onthe aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status ofthe aircraft, including thetime since the last inspectionrequired by the inspection programunder which the aircraft and its appliances are maintained. (v) The current status ofapplicable airworthiness directives (AD) and safety directives including, for each, the method ofcompliance, the AD or safety directive number andrevision date. Ifthe AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies ofthe forms prescribedby§ 43.9(d) ofthis chapter for eachmajor alteration to the airframe and currently installed engines, rotors, propellers, and appliances. (b) The owner or operator shallretain the following records for the periods prescribed: (1) The records specified inparagraph (a)(l) ofthis section shall be retained until the work is repeated or supersededby other work or for 1year after the work is performed. (2) The records specified inparagraph (a)(2) ofthis section shall be retained and transferred with the aircraft at the time the aircraft is sold. (3) A list ofdefects furnished to a registered owner or operatorunder § 43.11 ofthis chapter shall be retained until the defects are repaired and the aircraft is approved for return to service. 

### C. TheExtent OfReliefLockheed Martin Aeronautics Seeks And TheReason Lockheed Martin Aeronautics Seeks TheRelief. C.l. Extent OfReliefLockheed Martin Aermiautics Seeks And The Reason Lockheed Martin Aeronautics Seeks ReliefFrom Section 61.113(a) And (b). Relieffrom Section 61.113(a) and (b) entitledPrivatepilot privileges andlimitations: Pilot in command, is requestedto the extent necessary to allow a PIC holding a private pilot orhigher 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 orhire.
This reliefis requested since the limitations set forth in Section 61.1 13(a) and (b) state that a private pilot may, for compensation orhire, act as PIC ofan 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 orproperty for compensation orhire.
As set forth more fully below, Lockheed Martin Aeronautics submits that an equivalent level ofsafety will be maintained because no PIC will be allowedto operate the UAS unless that PIC has met certain flighthour and currencyrequirements, demonstrating thatthe PIC is able to safely operate the DJI Inspire 1 UAS in a manner consistent withthe operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures.



### 4Further, Lockheed Martin Aeronautics submits that all flights ofa 

## Dn Inspire 1 UAS, conductedbythe PIC pursuant to the grant ofthis Petition: (1) will be incidental to Lockheed Martin Aeronautics business; and (2) will not carry passengers orproperty for compensation orhire.


### C.2. Extent OfReliefLockheed Martin Aeronautics Seeks And TheReason Lockheed Martin Aeronautics Seeks ReliefFrom Section 91.7(a).
Relieffrom Section 91.7(a) entitled 

### Civil aircraft airworthiness, is requested to the extentrequired to allow Lockheed Martin Aeronautics to determine thatthe 

## Dn Inspire 1UAS is in airworthy conditionpriorto every flight by ensuring thatthe UAS is in compliance with the operating documents (i.e., Monthly Maintenance Log, and

## Dn Inspire 1 Instruction Manual).
Lockheed Martin Aeronautics seeks the requestedreliefbecause the 

## Dn Inspire 1 UAS does notrequire an airworthiness certificate in accordance with 14 C.F

### .R. Part 21, Subpart H. Therefore, LockheedMartin Aeronautics will ensure that the 

## Dn Inspire 1 UAS is in an airworthy conditionbasedupon its compliance with the operating documents (i.e., Monthly Maintenance Log, and 

## Dn Inspire 1Instruction Manual) prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated inthe conditions and limitations below.


### C.3. Extent OfReliefLockheed Martin Aeronautics Seeks And TheReason Lockheed Martin Aeronautics Seeks ReliefFrom Section 91.121.
Relieffrom Section 91.121, entitled Altimeter settings, may be required to allow flight operations ofthe 

## Dn Inspire 1UA, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UAS to the PIC atthe ground control station (GCS). Since the FAArequires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), Lockheed Martin Aeronautics seeks the requested reliefbecause 

## Dn Inspire 1UA's altimeter may be set on the ground to zero feet AGL, ratherthan the local barometric pressure or field altitude, before each flight. Consideringthe limited altitude ofthe proposed operations, relieffrom 14 CFR91.121 is sought to the extent necessary to comply with the applicable conditions and limitations statedbelow. As more fully set forth herein, an equivalent level ofsafety will be maintained since the DJI Inspire 1UA is equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be establishedprior to each flight, andprovides the PIC with altitude information ofthe UA on the heads-up display ofthe GCS.


### C.4. Extent OfReliefLockheed Martin Aeronautics Seeks And TheReason Lockheed Martin Aeronautics Seeks ReliefFrom Section 91.151(b).
Relieffrom Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extentrequiredto allow flights ofthe batterypoweredDJI Inspire I UA 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 ofintended landing and, assuming normal cruising speed, to fly afterthat for at least 4.5 minutes. Lockheed Martin Aeronautics seeks the requestedreliefbecause without an exemption from Section 91.151(b), the flight time duration ofthe batterypowered DJI Inspire 1 UA will severely constrain the practicality ofany aerial video or still photo flight operations that LockheedMartinAeronautics proposes to conductpursuantto this Petition. Significantly, as set forth below, the technical specifications and operating documents ofthe DJI Inspire I, and Lockheed Martin Aeronautics' proposed operating limitations, ensure that LockheedMartin Aeronautics will safely operate the battery powered DJI Inspire I UA during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough batterypowerto fly for a total duration of 13.5 minutes to the first point ofintended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.



### 5

### C.S. Extent OfReliefLockheed Martin Aeronautics Seeks And The Reason Lockheed Martin Aeronautics Seeks ReliefFrom Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & 

### (a)(2), And 91.417(a) &(b).
Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & 

### (b) only apply to aircraft with an airworthiness certificate, Lockheed Martin Aeronautics requests relieffrom these Sections because DJI Inspire 1 UAS does notrequire airworthiness certificates. As set forth more fully below, the DJI Inspire 1 UAS meet the conditions ofFMRA Section 333 for operation without an airworthiness certificate. Accordingly, Lockheed Martin Aeronautics will use trained technicians to perform maintenance, alterations, orpreventive maintenance on the UAS using the methods, techniques, andpractices prescribed inUAS operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1UserManual). Furthermore, Lockheed Martin Aeronautics will document and maintain all maintenance records for the DJI Inspire 1 UAS.



### D. The Reasons Why Granting Lockheed MartinAeronautics RequestWould Be In The Public Interest; That

### Is, How ItWould Benefit ThePublic As 

### A Whole. GrantingthepresentPetition will further thepublic interest by allowing LockheedMartin Aeronautics to safely, efficiently, and economically perform aerial video andphotography ofconstruction sites, real estate, and landscape over certain areas ofthe United States. Additionally, use ofthe DJI Inspire 1 UAS will decrease congestion ofthe NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits ofLockheed Martin Aeronautics' proposed operation ofthe DJI Inspire 1 UAS will berealized without implicating any privacy issues.


### D.l. The Public Will Benefit From Decreased Congestion OfThe NAS. DJI Inspire 1 UAs are batterypowered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. Byreducing the amount ofmanned aircraft needed to perform aerial video and photography, an exemption allowing the use ofa DJI Inspire 1 UAS would reduce the amount ofmanned aircraft inthe NAS, reduce noise and air pollution, as well as increase the safety oflife and property in the air and onthe ground. Furthermore, byreducing the number ofmanned aircraft operating inthe NAS, congestion around airports causedby arriving and departing aircraft will bereduced. The DJI Inspire 1 UAs do notrequire an airport totakeoffor land. Likewise, a reduction ofmanned aircraft conducting aerial video and photography missions wouldresult in fewer aircraft that mustbe handled by airtraffic control during the ground, takeoff, departure, arrival, and landing phases offlight operations.


### D.2. The Public Will Benefit From The Safety And Efficiency OfThe DJIInspire 1 UAS. Conducting aerial video and photography with the DJI Inspire 1 UAS, instead ofmanned aircraft, will greatly benefitthe public by drastically reducing the levels ofair and noise pollution generated during traditional aerial video and still photography flight operations. Byusing batterypower and electric motors, DJI Inspire 1 UAS produces no air pollution, and is the most viable environmentally conscious alternative tothe cabin class, six cylinder internal combustion engine aircraftthat are typically utilized for aerial video and photography, while burning approximately 20-30 gallons perhour ofleaded aviation fuel. The DJI Inspire 1UA, while reducing the carbon footprint ofaerial video and photography, also eliminates noise pollution, as the UA is propelledbybatterypowered electric motors, rather than an internal combustion engine. Byusing a DJI Inspire 1 UAS to perform aerial video andphotography, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack offlight crew members located onboard the aircraft, the DJI Inspire 1 UA (weighing approximately 2 pounds 11 ounces and 6 pounds 7.5 ounces respectively, at their maximum gross weights with lengths of 16 inches and 17.3 

## 6inches respectively, widths of 16 inches and 17.7 inches respectively, and with no fuel onboard), has less physical potential for collateral damage to life and property onthe ground, and in the air, comparedto the manned aircraftthat typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan ofapproximately 42 feet, a length of34 feet, and a fuel capacity of 180 gallons).


### D.3. PerformingAerial Video and Photography Operations With TheDJIInspire 1 UAS Will Benefit TheEconomy.
In addition to being safe and efficient, the DJI Inspire 1 UAS is also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation ofa DJI Inspire 1UAS will allow United States based companies, like Lockheed Martin Aeronautics, to remain competitive and contribute to growth ofthe U.S. economy. Specifically, with the rising cost ofaviation fuel and the Environmental ProtectionAgency ("EPA") regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery powered DJI Inspire 1UAS is one such technology that not only allows companies greater operational flexibility comparedto manned aircraft, butprovides such flexibility without the high operational cost ofa traditional manned aircraft.


### D.4. There Are No Privacy Issues. Similar to the manned aerial video and photography flight operations that have been conducted for decades, Lockheed Martin Aeronautics' proposed operation ofthe DJI Inspire 1 UAS will not implicate any privacy issues. Specifically, the DJI Inspire 1 UAS will be operated only in compliance with operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1Instruction 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, OrHow The Exemption Would Provide A Level OfSafety At Least Equal To That Provided By The Rule From Which Lockheed Martin Aeronautics Seeks Exemption.
E.l. Reasons Why DJIInspire 1 UAS MeetThe Conditions OfThe FAA Modernization and Reform Act of2012 (FMRA) Section 333.
In consideration ofthe size, weight, speed, and limited operating area associated with the unmanned aircraft (UA) and its operation, Lockheed Martin Aeronautics' operation ofa DJI Inspire 1 UAS meets the conditions ofFMRA 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 ofthe NAS orthe public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part: (a) In GeneraL--Notwithstanding any other requirement ofthis subtitle, and not later than 180 days after the date ofenactment ofthis Act, the Secretary ofTransportation shall determine ifcertain unmanned aircraft systems may operate safely in the national airspace system before completion ofthe plan and rulemaking required by section 332 ofthis Act orthe guidance required by section 334 ofthis Act. (b) Assessment ofUnmanned Aircraft Systems.--ln making the determination under subsection (a), the Secretary shall determine, at a minimum-- (1) which types ofunmanned aircraft systems, ifany, as a result oftheir size, weight, speed, operational capability, proximityto airports and populated areas, and operation within visual line ofsight do not create a hazard to users ofthe national airspace system orthe public or pose a threat to national security; and (2) whether a certificate ofwaiver, certificate ofauthorization, or airworthiness certificationunder section 44704 oftitle 49, United States Code, is required for the operation ofunmanned aircraft systems identified under paragraph (1).



### 7

### (c) Requirements for Safe Operation.--Ifthe 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 ofsuch aircraft systems in the national airspace system.
In seeking this exemption, Lockheed Martin Aeronautics submits that the DJI Inspire I UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics ofthe DJI Inspire I UAS; (b) 

### the pilot certificationrequirement; and (c) the specific operating limitations.



### a. The Specifications Ofthe DJI Inspire 1 UAS Demonstrate Its Safe Characteristics. The DJI Inspire I UAS does not create a hazard to users ofthe NAS orthe public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability.


### i. Technical Specifications Ofthe DJI Inspire 1 UAS. The technical specifications ofthe DJI Inspire I UAS are set forth by DJI Inspire I Specifications (Appendix A).


### ii. 

### DJI Inspire 1 UAS Autonomous Flight And Navigation Modes Enable TheUAS To Remain Within A Defined Operational Area. The DJI Inspire I UAS may be operated in both manual and fully autonomous flight modes. A complete description ofthe flight and navigational modes ofthe DJI Inspire I UAS is provided at pages 12-16 and 45-50 ofthe DJI Inspire I User Manual, attached hereto as Appendix B.


### iii. DJI Inspire 1 UAS Is Designed ForAutomatic Return To Home Point Or Hover In The Event OfLoss OfThe Control Link OrNavigation. When the Control Link is lost, the DJI Inspire I UA will remain stationary in flight, for 3 seconds or more. Ifafter 3 seconds, the UAS does not reacquire control link data from the GCS, the UAS 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 takeoffposition and shutdown. A complete description ofthe Failsafe Functions ofthe UAS are set forth at through pages 13 through 15 ofthe DJI Inspire 1User Manual.


### iv. DJI Inspire 1 GCS And Its Operation. A complete description ofthe operation and specifications ofDJI Inspire I GCS and flight control software is provided at pages 40 through 47 ofthe DJI Inspire I User Manual.


### b. Flight Operations OfDJIInspire 1 UAS Are Limited To The Line OfSight OfA Certificated Pilot in Command With A Safety Observer. Lockheed Martin Aeronautics will only utilize certificated pilots to act as a pilot in command (PIC) ofthe DJI Inspire 1UAS. Additionally, a safety observer will assist all pilots during flight time.



### c. Flights OfDJIInspire 1 UAS Will Be Conducted Pursuant To Specific Operating Limitations. In seeking this exemption, Lockheed Martin Aeronautics proposes to commercially operate the DJI Inspire 1UAS for the special purpose ofconducting aerial video and photography over certain areas ofUnited States, pursuant to the following specific operating limitations:
1. Operations authorized by this grant ofexemption will be limited to the following aircraft described in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: the DJI Inspire I Unmanned Aircraft Systems. Proposed operations ofany 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 ofaerial video and photography.
3. The UAS may notbe flown at an indicated airspeed exceeding 45 knots.



### 84. The UAS mustbe operated at an altitude ofno more than 500 feet above ground level (AGL), as indicated bythe procedures specified in the operating documents unless a special request is made and approved byATC.. All altitudes reported to ATC must be in feet AGL.
5. The UAS must be operated within visual line ofsight (VLOS) ofthe 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 onthe PIC's FAA-issued airman medical certificate.
6. The use offrrst person view (FPV) goggles by the PIC or safety observer (SO) is not**permitted~** 7. All operations must utilize a safety observer (SO). The SO maybe 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 ortexting is not permitted during flight operations. The PIC must be designated before the flight and cannottransfer his orher designation for the duration ofthe flight. The PIC must ensure that the SO canperform 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 notpermitted to operate the camera or flight instruments, but may relay radio communications.
9. The operating documents and the grant ofexemption mustbe accessible during UAS operations and made available to the Administrator upon request. Ifa discrepancy exists betweenthe conditions and limitations contained in the grant ofexemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant ofexemption take precedence and mustbe followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update orrevise its operating documents. Itis the operator's responsibility to track suchrevisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents ifit petitions for extension or amendment to the grant ofexemption. Ifthe 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 ofexemption. The FAA's UAS Integration Office (AFS-80) maybe contacted ifquestions arise regarding updates orrevisions to the operating documents.
10. Priorto each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. Ifthe inspection reveals a condition that affects the safe operation ofthe UAS, the aircraft is prohibited from operating until the necessary maintenance has beenperformed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records.
11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement ofa 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 ofthe operating documents.
13. The operator must follow the UAS manufacturer's aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements.
14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul componentparts mustbe noted in the aircraft records, including total time in service, description ofwork accomplished, and the signature ofthe authorized person returning the UAS to service.
15. Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins.



### 916. The authorized personmust make an entry in the aircraft record ofthe corrective action taken against discrepancies discovered between inspections.
17. The PIC must possess atleast a private pilot certificate and at least a currentthird- class medical certificate.
18. The operatormay notpermit any PICto operateunless the PIC meets the operator's qualification criteria and demonstrates the abilityto safely operate the UAS in a manner consistent with how the UAS will be operatedunderthe exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours mustbe logged in a manner consistentwith 14 C.F.R. 

### § 61.51

### (b). Flights for the purposes oftraining the operator's PICs are permittedunderthe terms ofthe exemption. However, training operations may onlybe conducted during dedicated training sessions. Duringtraining, proficiency, and experience-building flights, all persons not essential for flight operations are considerednonparticipants, and the PIC must operate the UAS with appropriate distance from nonparticipants in accordance with 14 C.F

### .R. § 91.119.
19. UAS operations may not be conducted during night, as defined in 14 C.F

### .R. § 1.1. All operations must be conductedunder visual meteorological conditions (VMC). Ifflight atnight is required, a special request will be made atthe FAA office closest to proposed area ofoperations. Flights under special visual flight rules (SVFR) are not authorized.
20. The UAS maynot operate within 

### 5nautical miles ofan airport reference point as denoted on a current FAA-published aeronautical chartunless a letter ofagreement with that airport's management is obtained, and the operation is conducted in accordance with a NOT AM as requiredbythe operator's COA. The letter ofagreement with the airport management mustbe made available to the Administrator uponrequest.
21. The UAS may notbe operated less than 500 feet below or less than 2,000 feet horizontally from a cloud orwhen visibility is less than 3 statute miles from the PIC.
22. Ifthe UAS loses communications or loses its GPS signal, it mustreturn to a pre- determined location within the planned operating area and land orbe recovered in accordance with the operating documents.
23. The PIC must abort the flight in the event ofunpredicted 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 enoughpowerto fly at normal cruising speed to the intended landing point and landthe UAS with 25% batterypowerremaining.
25. The operatormust obtain an Air Traffic Organization (ATO) issued Certificate ofWaiver or Authorization (COA) priorto conducting any operations under the grant ofexemption. This COA will also require the operator to request a Notice to Airman (NOT AM) not more than 72 hours in advance, but not less than48 hours priorto the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class ofairspace, altitude andpotential transponder requirements.
26. All aircraft operated in accordance with the exemptionmust be identified by serial number, registered in accordance with 14 C.F.R. part47, and have identification (N- Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings mustbe as large as practicable.
27. Before conducting operations, the radio frequency spectrum used for operation and control ofthe UAS must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.



### 1028. The documents required fewer than 14 C.F.R. 91.9 and 91.203 mustbe available to the PIC at the Ground Control Station ofthe UAS any time the UAS is operating. These documents mustbe made available to the Administrator or any law enforcement official uponrequest.
29. The UAS mustremain clear andyield the right ofwayto all manned aviation operations and activities at all times.
30. The UAS maynotbe operatedbythe PIC from any moving device orvehicle.
31. Flight operations mustbe conducted at least 500 feet from all nonparticipating persons (persons other thanthe PIC, SO, operatortrainees or essentialpersons), vessels, vehicles, and structures unless:

a. Barriers or structures are presentthat sufficiently protectnonparticipating persons from the UAS and/or debris in the event ofan accident. The operatormust ensure that nonparticipating persons remain under such protection. Ifa situation arises where nonparticipating persons leave suchprotection and are within 500 feet ofthe UAS, flight operations must cease immediately and/or;
b. The aircraft is operated near vessels, vehicles or structures where the owner/controller ofsuch vessels, vehicles or structures has granted permission and the PIC has made a safety assessment ofthe risk of operating closer to those objects and determined that it does notpresent an undue hazard, and;

c. Operations nearer to the PIC, SO, operatortrainees or essential persons do notpresent an undue hazardto those persons per§ 91.119(a).
32. All operations shall be conducted overprivate orcontrolled-access propertywithpermission from the land owner/controller or authorizedrepresentative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted.
33. Any incident, accident, orflight operationthattransgresses the lateral or vertical boundaries ofthe operational area as defined bythe applicable COAmustbereported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must bereportedto the National Transportation SafetyBoard (NTSB) per instructions contained on the NTSB Web site: www.ntsb.!!ov.


### E.2. Reasons Why An Exemption From The Requirements OfSection 61.113(a) And (b) Would Not Adversely Affect Safety.
Lockheed Martin Aeronautics submits that the equivalent level ofsafety established by Section 61.113(a) and (b) will be maintainedbecause no PIC will be allowedto operate the DJI Inspire 1 UAS unless that PIC has demonstrated, bymeeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering Lockheed Martin Aeronautics' proposed area ofoperations and the operating limitations set forth-above; the parallel nature ofprivate pilot aeronautical knowledge requirements to those of commercial pilotrequirements (See Exemption No. 11062); and the airmanship skills necessaryto safely operate the UAS, LockheedMartin Aeronautics submits that the additional manned airmanship experience ofa commercially certificatedpilot would not correlate to the airmanship skills necessary for Lockheed Martin Aeronautics' specific proposed flight operations.
The FAAhas previously grantedrelieffrom Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presentedherein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).
Lockheed Martin Aeronautics will not allow any PIC to operate the DJI Inspire 1 UAS unless that PIC has demonstrated, bymeeting minimum flight-hour requirements orthe DJI Inspire I UAS training and


### 11currency requirements, thatthe PIC is able to safely operate 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 musthave accumulated and logged, in a manner consistentwith 14 C.F.R. § 61.51(b), 25 hours oftotal time as a UAS rotorcraft pilot (with a minimum of5 hours ofthose hours as a UAS pilot operating the same make and model of UAS to be used for operations underthe exemption). In addition to the hourrequirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes).
As inExemptionNos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level ofsafety during Lockheed Martin Aeronautics' proposed operations. The Administrator has heldthat prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows:
InExemptionNo. 11062, the FAArequiredthatpriorto conducting operations for the purpose ofmotion picture filming (or similar operations), the PIC musthave accumulated andlogged, in a manner consistent with 14 CFR61.51(b), 25 hours oftotal time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotorUAS. Priorto operations under ExemptionNo. 11062, the PIC must also have accumulated and logged a minimum of5 hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hourrequirements to be inclusive ratherthan additive; i.e. 5 hours make and model time maybe included in the 10 hours ofmulti-rotor time and the 10 hours maybe included in the total25 hours ofUAS rotorcraft time. In additionto the hourrequirements, the PIC must accomplish 3 takeoffs and landings inthe preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight-hour requirements inExemption No. 11062 are appropriate to practice and buildproficiency inthe 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 conductedunderthe grant ofexemption to accomplish the required flight time. Duringtraining, proficiency, and experience-building flights the PIC is required to operate the UAS with appropriate distances in accordance with 14 C.F.R91.119. ExemptionNo. 11138 at page 15. Accordingly, Lockheed Martin Aeronautics will ensure safe operations bynot allowing any PIC to operate the DJI Inspire 1 UAS unless that PIC has demonstrated, bymeeting minimum flight-hour and currency requirements, thatthe PIC is able to safely operate the UAS in a manner consistent withthe exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 

### E.3. Reasons Why An Exemption From TheRequirements OfSection 91.7(a) Would Not Adversely Affect Safety.
The equivalent level ofsafety establishedby Section 91.7(a) will be maintainedbecause prior to every flight, Lockheed Martin Aeronautics will ensure thatthe DJI Inspire 1 UAS is in an airworthy condition basedupon the UAS's compliance with its operating documents and as stated in the conditions and limitations herein. Additionally, the FAA has previously grantedrelieffrom Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presentedherein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).


### E.4. Reasons Why An Exemption From TheRequirements OfSection 91.121 Would Not Adversely Affect Safety. The equivalentlevel ofsafety establishedby Section 91.121 will be maintained because the altitude information ofDJI Inspire 1 UAS will be providedto the PIC via GPS equipment and a radio 

### 12

### communications telemetry data link, which downlinks from the UAS to the GCS for active monitoring of the flight path and altitude. This altitude information, combined with LockheedMartin Aeronautics' operation ofDJIInspire I UAS within visual UAS line ofsight, at orbelow 500 feet AGL, will ensure a level ofsafety equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed onboardthe aircraft. Priorto each flight, a zero altitude initiation point is automatically established bythe UAS at ground level.
The FAA has previously granted relieffrom Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067,11080,11109,11112,11136,11138,11150,11153,11156,11157,11158,11159,11160, 11161).


### E.5. Reasons Why An Exemption From TheRequirements OfSection 91.151(b) Would Not Adversely Affect Safety.
A grant ofthis exemption would ensure an equivalent level ofsafety establishedby 14 C.F.R. Section 91.151(b) as a result of(l)the technical specifications ofDJI Inspire 1UAS; (2) the limitations on the proposed flight operations; and (3) the location ofthe proposed flight operations. Accordingly, Lockheed Martin Aeronautics will ensure that it will safely operate the batterypoweredDJI Inspire 1UA during daylight hours in VFR conditions, with enough battery powerto fly for a total duration of 13.5 minutes to the frrst point ofintended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. Here, as inExemptionNo. 11109, the technical specifications ofDJI Inspire 1UAS; the limitations onthe proposed flight operations; andthe location ofthe proposed operations, will ensure an equivalent level of safety establishedby 14 C.F.R. Section 91.15l(b). Furthermore, safety will be ensured as DJI Inspire 1 UAS provides audible and visual warnings to the PIC at the GCS when the UA experiences low battery voltage, the first warning occurring at approximately 33%remaining battery power, and again at approximately 10%remaining battery power. Atthe critically lowbattery level, the DJI Inspire 1UAS will descend and land automatically. Significantly, previous exemptions granted bythe FAA concerning Section 91.151 establish that safety is not adversely affected whenthe technical characteristics and operating limitations ofthe UAS are considered. Reliefhas been granted for manned aircraft to operate at less than the minimums prescribedin Section 91.151, including ExemptionNos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relieffrom Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those presentedherein (e.g. ExemptionNos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).


### E.6. Reasons Why An Exemption From TheRequirements OfSections 91.405(a), 91.407(a)(l), 91.409(a)(l) & 

### (a)(2), And 91.417(a) & 

### (b) Would Not Adversely Affect Safety.
In seeking this exemption, Lockheed Martin Aeronautics submits that the equivalent level ofsafety with regard to the regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & 

### (a)(2), and 91.417(a) & 

### (b) will be metbecause Lockheed Martin Aeronautics will use trained technicians to perform maintenance, alterations, orpreventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1Instruction Manual). Furthermore, Lockheed Martin Aeronautics will document and maintain all maintenance records for the DJI Inspire 1UAS.
Since the DJI Inspire 1UAS will be inspected as prescribed by the operating documents, Lockheed Martin Aeronautics will maintain the equivalent level ofsafety establishedby Sections 91.405(a), 91.409(a)(l), and 91.409(a)(2). A copy ofDJI Inspire 1User Manuals are attached hereto as Appendix B; a copy ofDJI Inspire 1UAS Maintenance Log is attachedhereto as Appendix C.



### 13Likewise, the exemption sought will not adversely affect safety because LockheedMartinAeronautics will use trained technicians to perform maintenance, alterations orpreventive maintenance onthe UAS using the methods, techniques, and practices prescribedbythe operating documents. Furthermore, the exemption sought would maintain an equivalent level ofsafety establishedby Sections 91.407, 91.417(a) and 91.417(b), because all maintenance ofthe UAS will beperformedby trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log. Significantly, previous exemptions grantedbythe FAA concerning Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) 

### & (a)(2), and 91.417(a) 

### & (b) establishthat safety is not adversely affected whenthe technical characteristics and operating limitations ofthe UAS are considered.
In consideration ofLockheed Martin Aeronautics' proposed operating limitations, the operating documents, and the technical aspects ofthe DJI Inspire 1UAS, Lockheed Martin Aeronautics submits that safety will notbe adversely affectedby granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(l) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously grantedreliefspecific to UAS 

### in circumstances similar, in all material respects, to those presentedherein (e.g. ExemptionNos. 11062, 11063,11064,11065,11066,11067,11080,11109,11110,11112,11136,11138,11150,11153,11156, 11157,11158,11159,11160, 11161).
E.7. The FAAMay Prescribe Any Other Conditions For Safe Operation. In accordance with Section 333 ofthe FAAModernization and Reform Act of2012 (FMRA) and 14 C.F.R. 

### § 21.16 entitled Special Conditions, LockheedMartin Aeronautics requests that the FAAprescribe special conditions for the intended operation ofthe DJI Inspire 1 UAS, which contain such safety standards that the Administrator fmds necessary to establish a level ofsafety equivalent to that establishedby 14 C.F.R. Part 21, SubpartH, and 14 C.F.R 

### §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.15l(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation ofthe UAS for the limited purpose ofconducting aerial video andphotography over certain areas ofthe United States for compensation orhire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazardto users ofthe NAS orthe public, orotherwisepose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification in accordance with any requirements that mustbe established for the safe operation ofthe UAS in the NAS. Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. 

### § 21.16, for operation ofthe 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 orunusual design features ofthe aircraft. Section 21.16, entitled Special Conditions, states the following:
Ifthe FAA finds that the airworthiness regulations ofthis subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, orpropellerbecause ofa novel orunusual design feature ofthe 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 ofthis chapter and contain such safety standards for the aircraft, aircraft engine orpropeller as the FAA finds necessary to establish a level ofsafety equivalentto 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 Lockheed Martin Aeronautics intended operation ofthe DJI Inspire 1 UAS, which contain such safety standards that the Administrator finds necessary to establish a level ofsafety equivalent to that establishedby 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) 

### & (b), 91.7(a), 91.121, 91.15l(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b).



### 14

### F. A SummaryThat Can Be Published In The FederalRegister, stating: The Rules From Which Lockheed Martin Aeronautics Seeks Exemption:
The Rules From Which Lockheed Martin Aeronautics Seeks Exemption: LockheedMartinAeronauticsseeks 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), and91.417(a) & (b).


### A BriefDescription OfThe Nature OfTbeExemption Lockheed Martin Aeronautics Seeks:
This exemption willpermitLockheedMartinAeronautics to commercially operate an UnmannedAircraft System (UAS)for thepurpose of conductingaerialvideo and photography over certain areas of the United States. 

### Any Additional Information, Views, OrArguments Available To SupportLockheed Martin Aeronautics' Request.
This Petition is made pursuant to the FAAModernization and Reform Act of2012(FMRA) Section 333, which directs the Secretary ofTransportation to determine ifcertain UAS may operate safely inthe NAS. As such, Lockheed Martin Aeronautics' request for exemption maybe grantedpursuant 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 hazardto users oftheNAS orthe public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification.
As discussed in detail above, Lockheed Martin Aeronautics will operate the 

### Dn Inspire 1UAS safely in the NAS, without creating a hazardto users ofthe NAS, orthe public, or otherwisepose a threatto national security.



### 15

### Conclusion
As set forth herein, Lockheed Martin Aeronautics seeks an exemptionpursuantto 14 C.F.R. § 11.61 and Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA), which will permit safe operation ofthe DnInspire 1UAS commercially, without an airworthiness certificate, for the limitedpurpose of conducting aerial video and photography over certain areas ofthe United States. Bygranting this Petition, the FAA Administrator will be fulfilling the Congressional mandate ofthe FAAModernization and Reform Act of2012, while also advancing the interests ofthe public, by allowing Lockheed Martin Aeronautics to safely, efficiently, and economically operate the Dn Inspire 1UAS commercially within the NAS.
Inaccordance with the Federal Aviation Regulations and the FAA Modernization andReform Act of2012, Section 333, Lockheed Martin Aeronautics respectfully requests thatthe Administrator grantthis 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)(l) & 

### (a)(2), and 91.417(a) & 

### (b), and permit Lockheed Martin Aeronautics to operate the DnInspire 1UAS commercially for the purpose ofconducting aerial video and photography over certain areas ofthe United States.
Dated: August 24,2015

Appendices:
A- DJI Inspire 1 Specifications Sheet B- Dn Inspire 1UserManual C - DJI Inspire 1 Monthly Maintenance Log



### 16 Respectfully submitted,

Coleen Thornton
LockheedMartin Aeronautics Aviation Safety and Airworthiness 83 S. Cobb Drive Marietta, Georgia 30063-0579

### APPENDIX A

DJIINSPIRE 1 TECHNICAL SPECIFICATIONS
Lockheed Martin Aeronautics only utilizes safe and reliable UASs. DJI is an industry leader in small UAS production. DJI UASs are loadedwith ground breaking software enabling the userto set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit tlight to no higherthan a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJI software 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 7.529loz (2935g) 2.2.1.3 Hovering Accuracy (GPS Mode)- Vertical: 0.5m; Horizontal: 2.5m 2.2.1.4MaxAngularVelocity-Pitch: 300°/s; Yaw: 150°/s 2.2.1.5 Max Tilt Angle

- 35° 2.2.1.6 MaxAscent Speed- 5m/s 2.2.1.7 MaxDescent Speed- 4m/s 2.2.1.8 Max Speed- 22m/s (ATTlmode, no wind- NOT RECOMMENDED) 2.2.1.9 MaxFlight Altitude

- 4500m 2.2.1.10 Max Wind Resistance- lOm/s 2.2.1.11 MaxFlight Time -Approximately 18 minutes 2.2.1.12 Motor Model- DJI 3510 2.2.1.13 PropellerModel- DJI 1345 2.2.1.14 Operating Temperature Range -14°Fto 104°F (-10°C to 40°C) 2.2.1.15 Dimensions

- 17 

### W' x 17 %" 

### 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° 2.2.2.5 Mounting

- Detachable 2.2.2.6 Controllable Range- Pitch: -90° to +30°; Pan: ±320° 2.2.2.7 Mechanical Range- Pitch: -125° to 45°; Pan: ±330° 2.2.2.8 Max Controllable Speed- Pitch: 120°/s; Pan: 180°/s
2.2.3 Camera 2.2.3.1 Name- X3 2.2.3.2 Model- FC350 2.2.3.3 Total Pixels- 12.76M 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 ofView- 94° 2.2.3.8 CMOS- SonyEXMOR 112.3" 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°F- 104°F (0°C- 40°C)



### 17

### 2.2.4 Transmitter 2.2.4.1 Name- Cl 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°Fto 104°F (-10°C to 40°C) 2.2.4.6 Battery- 600mAh LiPo 2S



### 18

### APPENDIXB Inspire 1 User Manual (EN) 

### v1.4
http://www.dji.com/product/inspire-1/download



## 19

### APPENDIXC DJI INSPIRE 1 Maintenance Log

MONTHLY MAINTENANCE LOG

Other:



## 20