### UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC Regulatory Docket No. _______________

**IN T HE M**  **AT TER OF THE PETITION FOR EXEMPT**  **ION OF:**

**CHRISTOPHER L MEYER FOR**  **AN EXEMPTION SEEKING RELIEF FROM THE** 

**REQUIREMENTS OF TI**  **TLE 14 OF THE CODE OF FEDER AL** **REGUL ATI**  **ONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.1**  **51(b), 91.405(a), 91.407(a)(1),**  **91.409(a)(1) & (a)(2), A ND 91.417**  **(a) & (b) CONCERNING COMMERCI**  **AL OPER** **ATI ON OF**  **DJI PH**  **AN TO**  **M 3 PROFESION AL**  **UNM AN**  **NED AI**  **RCR A** **FT SYSTEMS**  **PURSU AN**  **T TO SECTION 333 OF**  **TH E F**  **AA MODERNIZ** **ATI ON**  **AN D REFORM**  **AC T OF 2012** 

**(PUBLIC L AW** **112**

**- 95)** 

Submitted on July 2 9, 2015 Christopher L Meyer 38619 Wakefield Ct. Northville, Michigan 48167

## TA **BLE OF CONTENTS** Page

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

............................. .4 INTRODUCTION AND INTERESTS OF PET ITIONER................................................

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

............................... ......................4 BASIS FOR PETITION.................................................................................... 4 NAME AND ADDRESS OF PETITIO NER........................................

............ ................. . ..5 THE SPECIFIC SECTIONS OF 14 C.F.R. FROM W HICH CHRISTOPHER L MEYER SEEKS EXEMPTION.........................

................................... ........................ .............. ...... 6 TH E EXTENT OF RELIEF CHRISTOPHER L MEER SEEKS AND THE REASON HE SEEKS THE RELIEF.............................................................................. ....8 THE REAS ONS WH Y GRANTING CHRISTOPHER L MEYER’S REQUEST W OULD BE IN THE PUBLIC INTEREST ....

......... ............................. ............. .............................10 THE REASONS WH Y GRANTING THE EXEMPTION WO ULD NOT ADVERSELY AFFECT SAFETY...........

........... ................................ ..............................12 CONCLUSION..............................

............ ................... ..................... ..............................21

## GLOSS **AR Y OF A**  **BBREVIA TIONS** 

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

## SUMM **AR Y** 

Christopher L Meyer seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). T his exemption will permit Christopher L Meyer to operate an Unmanned Aircraft System s (UAS ) for the commercial purpose of conducting aerial v ideo and photography and training . Such commercial ventures include weddings, family photography, demonstrations, promotional advertisement, special events, sporting events, inspection s , and real estate over certain areas of the United States. This exemp tion would also include training students on h ow to safely operate Unmanned Aircraft Systems including the laws and regulations and how they apply to UAS’s for commercial applications

. 

## INTRODUCTION A **ND INTERESTS OF THE PETITIONER** My name is Christopher L Meyer, I am a 36 year old High School Teacher and Flight Instructor. I am also a former Regional Airline Pilot with over 5,000 hours of total time as a commercially rated pilot. I am interested in using UAV’s for multiple commercial ventures . I am also interested in adding a credited course to our high school curriculum to include all aspects of UAV’s.



## BA**CKGROUND** Christopher L Meyer seeks an exemption to operate DJI systems for compensation or hire within the NAS. The DJI Phantom 3 Professional is a vertic al takeoff and landing (VTOL) Unmanned Aircraft (UA ) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. T he DJI Phantom 3 Professional has a maximum gross weight of approxim ately 2 pounds 11 ounces, while having a length of 16 inches width of 16 inches, he ight of 8 inches, and a maximum speed of approximately 29 knots . The DJI Phantom 3 Professional is equipped with four main rotors; dr iven by Lithium Polymer battery powered electric motors. The DJI Ph antom 3 Profes sional will be operated by Christopher L Meyer and will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration , and marked in accordance with 14 C.F.R. Part 45, Identification and Regi stration Marking

. 

## BA**SIS FOR PETITION** Petitioner, Christopher L Meyer , 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 Unmann ed Aircraft Systems , hereby petitions the Administrator to commercially operate the DJI Phantom 3 Professional UAS in the National Airspace System (NAS) , and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, Christopher L Meyer operation of DJI Phantom 3 Professional UAS meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part21, Subpart H. Accordingly, Christopher L Meyer 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 wit h an airworthiness certificate. Christopher L Meyer submits that the requested relief is p roper since an equivalent level of safety will be ensured. Christopher L Meyer will perform maintenance, alterations, or preventive ma intenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Professional Instruction Manual). Furthermore, Christopher L Meyer will docume nt and maintain all maintenance records for the DJI Phantom 3 Professional UAS

. Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges a nd limitations: Pilot in command , is requested by Christopher L Meyer to the extent necessary to allow a Pilot in Command (PIC) ho lding a pilot certificate, as well as an airman medical certificat e, and who has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 Professional U AS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Christopher L Meyer seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness , because the DJI Phantom 3 Professional UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Christopher L Meyer submits that he will ensure that the DJI Phantom 3 Professional UAS is in an airworthy condition, prior to every flight, by determining t hat the UAS is in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI P hantom 3 Professional Instruction Ma nual), and that the aircraft is in a condition for safe flight. Christopher L Meyer also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , as the DJI Phantom 3 Professional UAS will not have a typical barometric altimeter onboard. However, altitude information of the DJI Phantom 3 Professional UAS will be provided to the PIC via Global Positioning System (GPS) equipment and radio comm unications telemetry data link, which downlinks from the UA to the GCS for active moni toring of the flight path. This altitude information, combined with Christopher L Meyer’s operation of the DJI Phantom 3 Professional UAS within vis ual line of sight, at or below 4 00 feet AGL, will ensure a level of sa fety equivalent to Section 91.121. Additionally, Christopher L Meyer seeks an exe mption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions . Christopher L Meyer submits that safety will not be affected by op eration of the DJI Phantom 3 Professional UAS during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with en ough battery power to fly for a total duration of approximately 13.5 minutes to the first point of intende d 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, Christopher L Meyer provides the following information in support of its petition for exemption:



## A. **Name A nd A** **ddress Of The P etitioner** 

**.** The name and address of the Petitioner and point of contact is:Christopher L Meyer

38619 Wa kefield Ct. Northville, Michigan 48167 (734) 730

- 1612 CMeyer789@Hotmail.com


## B. The Specific Sections Of 14 C.F.R. From Which **Christopher L Mey er**  **Seeks Exemption**

**.**

**1. Christopher L Meyer**  **Seeks Exemption From The Requirements Of Section**  **61.113(a) a nd (b).**  Section 61.113, entitled Private pilot privileges and limitations: Pilot in command

, subsections (a) and (b) prescribe the following, in relevant part: (a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PIC of an aircraft. (b) A p rivate 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 compens ation or hire. **2. Christopher L Meyer**  **Seeks Exemption F rom The Requirements Of Section**  **91.7(a).** Section 91.7, entitled Civil Aircraft A irworthiness , subsection (a), states the following: (a) No person may operate a civil aircraft unless it is in an airwort hy condition. **3. Christopher L Meyer**  **Seeks Exemption From The Requirements Of Section 91.121.**  Section 91.121, entitled Altimeter settings, subsectio n (a), states the following, in part: (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter t hat 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

na utical 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 alti meter setting of an appropriate available station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropri ate altimeter setting available before departure. **4. Christopher L Meyer**  **Seeks Exemption From The Requirements Of Section 91.151(b).**  Section 91.151, entitled Fuel requirements for flight in VFR conditions

, subsection (b), states the following: (b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditio ns) there is enough fuel to fly to the first point of intended landing and, ass uming normal cruising speed, to fly after that for at least 20 minutes. **5. Christopher L Meyer**  **Seeks Exemption From The Requirement Of Section 91.405(a).** 

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

— (a) Shall have that aircraft inspected as prescribe d 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 c hapter[.] **6. Christopher L Meyer**  **Seeks Exemption From The Requirements Of Section 91.407(a)(1)**  Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration , subsection (a)(1), states the following: (a) No person m ay operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

-- (1) It has been approved for return to service by a person authorized under § 43.7 of this chapter[.] **7. Christopher L Meyer**  **Seeks Exemption From The Requirements Of Sections**  **91.409(a)(1) A nd 91.409(a)(2).**  Section 91.409, entitled Inspections , subsection (a), states the following: (a) Except as provided in paragraph (c) of this se ction, 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 airworth iness certificate in accordance with part 21 of this chapter. **8. Christopher L Meyer**  **Seeks Exemption From The Requirements Of Sections 91.417(a) A** **nd 91.417(b).** Section 91.417, entitled Maintenance records , sub sections (a) and (b), state the following: (a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the fo llowing records for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preventive maintenance, an d alteration and records of the 100

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

- - (i) A description (or reference to data acce ptable to the Administrator) of the work performed; and (ii) The date of completion of the work performed; and (iii) The signature, and certificate num ber of the person approving the aircraft for return to serv ice. (2) Records containing the following information: (i) The total time in service of the airframe, each engine, ea ch 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 airworthine ss directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and rev ision 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 § 4 3.9(d) of this chapter for each major alteration to the airframe and curre ntly installed engi nes, rotors, propellers, and appliances. (b) The owner or operator shall retain the fo llowing records for the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by ot her work or for 1 year after the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be reta ined and transferred with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until t he defects are repaired and the aircraft is approved for return to service.



## C. The Extent Of Relief **Christopher L Mey er**  **Seeks A nd The**  **Reason Christopher L Mey** **er Seeks**  **The Relief**

**.**

**1. Extent Of Relief**  **Christopher L Mey er**  **Seeks A nd The Reason**  **Christopher L Mey** **er Seeks Relief From Section 61.113(a) A**  **nd (b).** Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command , is requested to the extent n ecess ary to allow a PIC holding a private pilot or higher level certificate, as well as a c urrent and valid airman medical certificate, and who has met certain flight

- hour and curren cy 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 fl ight is only inc idental to that business or employment; and (2) The aircraft does not c arry passengers or property for compensation or hire. As set forth more fully below, Christopher L Meyer subm its that an equivalent level of safety will be maintained because no PIC wil l be allowed to operate the DJI Phantom 3 Profe ssional UAS unless that PIC has met certain flight

- hour and currency requirements, demonstrating that the PIC is able to safely operate either the DJI Phantom 3 Professional UAS in a manner consistent with the operations and specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures. Further, Christopher L Meyer submits that all flights of t he DJI Phantom 3 Professional UAS , conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to Christopher L Meyer’s business; and ( 2) will not carry passengers or property for compensation or hire.**2. Extent Of Relief Christoph**  **er L Mey er**  **Seeks A nd The Reason**  **Christopher L**

**Mey er**  **Seeks Relief From Section 91.7(a).** Relief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to the extent required to allow Christopher L Meyer to determine that the DJI Phantom 3 Professional UAS is in an airworthy con dition prior to every flight by ensuring that the UAS is in compliance with the operat ing documents (i.e., the Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Professional Instruction Manual). Chr istopher L Meyer seeks the requested relief because the DJI Phantom 3 Professional UAS do es not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Christopher L Meyer wil l ensure that the DJI Phantom 3 Professi onal UAS are in air worthy condition based upon its compliance with the operating documents (i.e., M onthly Maintenance Log, and DJI Phantom 3 Professional Instruction Manual ) prior to every flight, and further, determine that the aircraft are in condition fo r safe flight, as stated in the conditions and limitations below.

**3. Extent Of Relief Christopher L Mey** **er Seeks A** **nd The Reason Christopher L**  **Mey er**  **Seeks Relief From Section 91.121.** Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the DJI Phantom 3 Professional 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 th e 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), Christopher L Meyer seeks the requested relief because the DJI Phantom 3 Professional UA S ’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field a ltitude, before each flight. Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply wit h the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level of safety will be maintained since the DJI Phantom 3 Professional UAS is equipped with a barometric pressure sensor and GPS equipment, w hich 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 S on the heads

- up display of the GCS. **4. Extent Of Relief Christoph**  **er L Mey er**  **Seeks A nd The Reason**  **Christopher L Mey** **er Seeks Relief From Section 91.151(b).**  Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to allow flights of the battery powered DJI Phantom 3 Professional UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. Christopher L Meyer see ks the requested relief because without an exemption from Section 91.151(b), the flig ht time duration of the battery powered DJI Phantom 3 Professional UAS will severely constrain the practicality of any aer ial video or still photo flight operations that Christopher L Meyer proposes to conduct pursuant to this Petition. Significantly, as set forth below, the technical spec ifications of the DJI Phantom 3 Professional UAS, the DJI Phantom 3 Professional operati ng documents,and Christopher L Meyer proposed operating limitations, ensure that Christopher L

Meyer will safely operate the battery powered DJI Phantom 3 Professional UAS during daylight hours in visual m eteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a tot al duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

**5. Extent Of Relief Christopher L Mey** **er Seeks**  **An d The Reason**  **Christopher L Mey** **er Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2),**  **An d 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 airworthin ess certificate, Christopher L Meyer requests relief from these Sections because the DJI Phantom 3 Professional UAS do es not require an airworthiness certificate . As set forth more fully below, the DJI Phantom 3 Professional UAS meets the con ditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, Christopher L Meyer will perform maintenance, alterations, o r preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the Monthly Maintenance Log, and DJI Phantom 3 Professional Instruction Manual). Furthermore, Christopher L Meyer will document and maintain all maintenance records for the DJI Phantom 3 Professional UAS

. 

## D. The Reasons Why**Gran ting**  **Christopher L Mey er**  **’s Request Would Be In The Public**  **Interest; That Is, How It**  **Would Benefit The Public A s**  **A Whole.**  Granting the present Petition will further the publ ic interest by allowing Christopher L Meyer to safely, efficiently, and economically perform aerial video and photography and training for commercial ventures over certain areas of the United States. Additionally, use of the DJI Phantom 3 Professional UAS will decrease congestion of the NAS, reduce pollution, and prov ide significant benefits to the economy. Notably, the benefits of Christopher L Meyer’ s proposed operation of the DJI Phantom 3 Professional UAS will be realized without implicating any privacy issues. Lastly, training novice individuals on how to properl y operate an UAS safely and legally can only benefit the future of integrating UAS’s into the NAS.

**1. The Public Will Benefit From Decreased Congestion Of The NA S.**  The DJI Phantom 3 Professional UAS is battery powered and serve as a safe, efficient, and economical alternative to th e manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amou nt of manned aircraft needed to perform aerial acquisitions, an exemption allo wing the use of a DJI Phantom 3 Professional UAS would reduce t he a mount 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 departin g aircraft will be reduced. The DJI Phantom 3 Professional UAS do es not require an airport to takeoff or land.Likewise, a reduction of manned aircraft conducting aerial video and photogra phy

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 S afety A**  **nd Efficiency Of The DJI**  **Phantom 3**  **Professional UA S** 

**.** Conducting aerial acquisitions with the DJI Phantom 3 Profes sional UAS , instead of manned aircraft, will greatly be nefit the public by drastically reducing the levels of air and noise pollution generated duri ng traditional aerial video and still photography flight op erations. By using battery power and electric motors, the DJI Phantom 3 Professional UAS produce no air pollution, and is the most viable environmentally conscious alternative to the cab in class, six cylinder internal combustion engine aircraft that are ty pically utilized fo r aerial video and photography, while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The DJI Phantom 3 Professional UAS , while

reducing the carbon footprint of aerial acquisitions, also eliminates noise poll ution, as the UAS is propelled by battery powered electric motors, rather than an internal combustion engine. By using the DJI Phantom 3 Professional UAS to perform aerial acquisitions, the substantial risk to life and property in the a ir and on the ground, whic h is usually associated with traditional manned airc raft flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI Phantom 3 Profess ional UAS (weighing appro x imately 2 pounds 11 ounces, at its ma ximum gross weights with length of 16 inc hes, width of 16 inc hes , and with n o fuel on board), has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically condu ct similar operations (weighing approximately 6,000 pounds with a wingspan of approx imately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

**3. Performing A erial Video and Photography**  **Operations With The DJI Phantom**  **3 Professional UA S Will Benefit The**  **Economy**

**.** In addition to being safe and efficient, the DJI Phantom 3 Professional UAS are also an economical alternative to u sing manned aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom 3 Professional UAS will allow United States based companies, like Christopher L Meyer , to remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Prote ction Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. ow ned and operated companies must adopt new and alternative technology in order to re main competitive. Operating the battery powered DJI Phantom 3 Professional UAS is one such technology th at not only allows companies greater operati onal flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft. By operating the DJI Phantom 3 Professional UAS, companies such as Christopher L Meyer , can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, whic h w ill ultimately contribute to growth of the U.S. economy. Improved financial perform ance of U.S. companies, through commercial use of the DJI Phantom 3 Professional UAS, provides a stable workforce that increases consumer spending;improve s 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 A re No Privacy**  **Issues.** Similar to the manned aerial acquisition flight operatio ns that have been conducted for decades, Christopher L Meyer’s proposed operation of the DJI Phantom 3 Professional UAS will not implicate any privacy issues. Specifically, the DJI Phantom 3 Professional UAS will be operated on ly in compliance with operating documents (i.e., the Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Professional Instruction Manual) wh ich requires property ow ner 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 Wo u**  **ld Not Ad**  **ve rsely** **A**

**ffect Safety**
**, Or How** **The Exemption Would Prov**  **ide A**

**Lev el O**  **f Safety A** 

**t Least Equal To That Prov**  **ided By** **The Rule From Which Christopher L Mey** **er Seeks**  **Exemption.**

**1. Reasons Why**

**The DJI Phantom 3 Professional UA** **S Meet The Conditions Of**  **The FA**  **A Moder**  **nization and Reform A ct of 2012**  **(FMRA ) Section 333.**  In consideration of the size, weight, speed, and li mited operating area associated with the unmanned aircraft and its operation, Christopher L Meyer’s operation of the DJI Phantom 3 Professional UAS meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Section 333 provides authority for a UAS to operate wi thout airworthiness certification and sets forth requirements for consider ing whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part: (a) In General.

--Notwithstanding any other req uir e ment of this subtitle, and not later than 180 days after the date of enactmen t of this Act, the Secretary of Transportation shall determine if certai n unmanned aircraft systems may operate safely in the national airspace syste m before completion of the plan and rulemaking required by section 332 of th is Act or the guidance required by section 334 of this Act. (b) Assessment of Unmanned Aircraft Systems.

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

-- (1) which types of unmanned aircraft system s, if any, as a result of their size, weight, speed, operational capabi lity, proximity to airports and populated areas, and operation within vis ual line of sight do not create a hazard to users of the national airspa ce system or the public or pose a threat to national security; and (2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under se ction 44704 of title 49, United States Code, is required for the operation of unmann ed aircraft systems identified under paragraph (1).(c) Requirements for Safe Operation.

-- If the Secretary determines under this section

that certain unmanned aircraft sy stems 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, Christopher L Meyer submits that the DJI Phantom 3 Professional UAS can operate safely in the NAS pursuant to FMRA Section 333, as d emonstrated by: (a) the chara cteristics of the DJI Phantom 3 Professional UAS ; (b) the pilot certifi cation requirement; and (c) the specific operating limitations.

**a. The Specifications Of The DJI Phantom 3 Professional**  **UA S Demonstrate Its**  **Safe Characteristics.**  The DJI Phantom 3 Professional UAS do not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability. **i. Technical Specifications Of Th e**  **DJI Phantom 3 Professional UA S** 

**.** The technical specifications of the DJI Phantom 3 Professional UAS are set forth by the DJI Phantom 3 Professional Specifications and Data S heet, attached hereto as Appendix A

. **ii. The DJI Phantom 3 Professional UA** **S Autono**  **mous Flight A nd**  **Navigation Modes Enable The UA** **S To Remain Within A**  **Defined Operational A rea.**  The DJI Phantom 3 Professional UAS may be operated in both manual and fully autonomous flight modes. A complete description of the flight and navigational modes of the DJI Phantom 3 Professional UAS is provided at pages 25

- 35 of the DJI Phantom 3 Profession al User Manual, attached hereto in Appendix B

. **iii. The DJI Phantom 3 Pro fessional UA** **S Is Designed For A**  **utomatic Return To**  **Home Point Or Hover In The Event Of Los**  **s Of The Control Link Or Navigation.** Wh en the Control Link is lost, the DJI Phantom 3 Professional UAS will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 3 Professional UAS do not reacq uire control link data from the GCS, the UAS will assume that the Control Link is lost and the UAS will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown. A complete description of the Failsafe Functions of the DJI Phantom 3 Professional UAS are set forth at pages 27 through 29 of the DJI Phantom 3 Professional User Manual, attached hereto in Appendix B

. **iv. The DJI Phantom 3 Professional GCS A**  **nd Its Operation.**  A complete description of the operation and spec ificatio ns of the DJI Phantom 3 Professional GCS and flight control software is p rovided at pages 32 through 43 of the DJI Phantom 3 Professional User Manua l . DJI Phantom 3 Professional User Manual is att ached hereto in Appendix B

. **b. Flight Operations Of DJI Phan tom**  **3 Professional UA S**  **Ar e Limited To The Line**  **Of S ight Of A** 

**Certificated Pilot in Command With A**  **Safety Observer.** Christopher L Meyer will only utilize certificated pilots who possess a current and valid airman medical certificate to act as a pilot in command (PIC) of the DJI Phantom 3 Professional UAS . Additionally, a safety observer will assist all pilots during flight time.**c. Flights Of DJI Phantom 3 Professional UA** **S Will Be Conducted Pursuant To** 

**Specific Operating Limitations.** In seeking this exemp tion, Christopher L Meyer proposes to commercially operate DJI Phantom 3 Professional UAS for th e special purpose of conducting aerial video and photography and UAS training over certain areas of United States, pursuant to the following specific operating limitations: 1. Operations authorized by this grant of e xemption will be limited to the following aircraft described in the opera ting documents, rotorcraft UASs weighing less than 55 pounds maximum gros s weight: DJI Phantom 3 Professional Unmanned Aircraft System. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant. 2. UAS operations under this exemption will be l imited to conducting operations for the purpose of aerial video and photography and training. 3. The UAs may not be flown at an indicated airspeed exceeding 20 knots. 4. The UA must be operated at an altitude of no more than 4 00 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special reque st 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 sp ecified on the PIC’s FAA

- issued airman medical certificate. 6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted. 7. All operations must utilize a safety observer (SO). The SO may be used to sat isfy the VLOS requirement as long a s the PIC always maintains VLOS capability. The SO and PIC must be able to com municate verbally at all times. Electronic messaging or texting is not permitted du ring flight operations. The PIC must be designated before th e flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the SO can perform the functions prescribed in the operating documents. 8. The SO must not perform any other duties beyon d assisting the PIC with s eeing and avoiding other air traffic and other ground b ased obstacles/obstructions and is not permitted to operate the camera or other instruments. 9. The operating documents and the grant of exemption must be accessible during UAS operations and made avai lable to the Administrator upon request. If a discrepancy exists between the conditions a nd limitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the gra nt of exe mption take precedence and must be followed. Otherwise, the operato r must follow the procedures as outlined in its operating documents. The op erator may update or revise its operating documents. It is the operator’s respons ibility to track such revisions a nd present updated and revised documents to the Administrator upon request. The operator must also present updated and re vised documents if it petitions for extension or amendment to the grant of exemption. If the operator determines that any update or rev ision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if questions arise regarding update s or revisions to the operating documents.10. Prior to each flight the PIC must inspect th e UAS to ensure that it is in a condition

for safe flight. If the inspection revea ls a condition that affects the safe operation of the UAS, the aircraft is proh ibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance a nd alterations must be properly documented in the aircra ft records. 11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraft records. 12. The pre

-flight inspection must account for al l 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 man ufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. 14. The operator must carry out its maintenance, inspe ctions, and record keeping requirements, in accordance with the op erating documents. Maintenance, inspection, alterations, and status of repla cement/overhaul component parts must be noted in the aircraft records, i ncluding total time in service, description of work accomplished, and the sig nature of the authorized person returning the UAS to service. 15. Each UASs operated under this exemption must comply with all manufacturer Safety Bulletins. 16. The authorized person must make an entry in the aircraft re cord of the corrective action taken against discrepancies di scovered between inspections. 17. The PIC must possess a FAA Pilot C ertificate 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 demons trate s the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessel s, vehicles and structures. PIC q ualification flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of t raining the operator’s PICs are permitted under the terms of the exemption. H owe ver, training operations may only be conducted during de dicated training sessions. During training, proficiency, and experience

- building flights, all p ersons not essential for flight operations are considered nonparticipants, and the PIC m ust operate the UA with appropriate distance from nonparticipants in acco rdance with 14 C.F.R. § 91.119. 19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will be ma de at the FAA office closest to proposed area of operation s. 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 aerona u tical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA.The letter of agreement with the airport ma nagement must be made available to the

Administrator upon request. 21. The UA may not be operated less than 500 fee t below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute mil es from the PIC. 22. If the UA loses communications or loses its GPS sign al, it must return to a pre

determined location within the planne d operating area and land or be recovered in accordance with the operating documents. 23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance wit h the operating documents. 24. The PIC is prohibited from beginning a flig ht unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and lan d the UA with 25% battery powe r remaining. 25. The operator must obtain an Air Traffic Organi zation (ATO) issued Certificate of Wa iver or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will also re quire 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 o perations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requirements. 26. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance w ith 14 C.F.R. part 47, and have identification (N

Number) markings in acc ordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable. 27. Before conducting operations, the ra dio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversi ght agency requirements. 28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made available to the Administrator or any law enforcement official upon request. 29. The UA must remain clear and yield the righ t of way to all manned aviation operations and activities at all times. 30. The UAS may not be operated by the PIC from any moving device or vehicle. 31. Flight operatio ns must be conducted at least 500 feet from all nonparticipating persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect non participating persons from the UA a nd/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protecti on. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, veh icles or structures has granted permission and the PIC has made a safety as sess ment of the risk of operating closer to those objects and dete rmined that it does not present an undue hazard, and;c. Operations nearer to the PIC, SO, operato r trainees or essential persons do not

present an undue hazard to those persons per § 91.119(a). 32. All operations shall be conducted over privat e or controlled

- access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or au thorized representative will be obtained for each flig ht to be conducted. 33. Any incident, accident, or flight operation t hat transgresses the lateral or vertical boundaries of the operational area a s 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 Natio nal Transportation Safety Board (NTSB) per instructions contained on the NTSB W eb site: www.ntsb.gov

. **2. Reasons Why**

**A n Exemption From The Re**  **quirements Of Section 61.113(a) An**  **d (b) Would Not A** **dversely A**  **ffect Safety**

**.** Christopher L Meyer submits that the equivalent level of safety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI Phantom 3 Professional UAS unless that PIC has demonstrated , by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 Professional UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appro priate distances from people,

ve ssels, vehicles and structures. Considering Christopher L Meyer’s proposed area of operations, and the operating limitations set forth

- above; the parallel nature of priva te pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the DJ I Phantom 3 Professional UAS, Christopher L Meyer submits that the addition al manned airmanship experience of a commercially certificate d pilot would not correlate to the airmanship skills necessary for Christopher L Meyer’s specific proposed flight operations. The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material re spects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 110 67, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

Christopher L Meyer will not allow any PIC to operate the DJI Phantom 3 Professional UAS unless that PIC has demonstrated, by meeting minimum flight

- hour requirements or the DJI Phantom 3 Professional UAS training and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 Professional UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining app ropriate 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 exem ption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and la ndings in the preceding 90 days (for currency purposes).As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience

that was obtained in compliance with applic able regulations will ensure an equivalen t level of safety during Christopher L Meyer’s proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows: In Exemptio n No. 11062, the FAA required that pri or 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 roto rcraft pilot including at least 10 hours logged as a UAS pilot with a multi

- rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to b e used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than additi ve; i.e. 5 hours make and model time may be included in the 10 hours of multi

- rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraf t 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 requirem ents in Exemption No. 11062 are ap propriate to practice and build proficiency in the skills necessary to safely co nduct the petitioner’s proposed operations. The FAA also finds that prior docume nted flight experience that

was obtained in compliance with ap plicable regulations would satisfy this requirement. Training, proficiency, and experien ce

- building flights can also be conducted under the grant of exemption to accomplish the required flig ht time. During training, proficiency, and experience

- building fli ghts the PIC is required to operate the UA with appropriate distances in a ccordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15. Accordingly, Christopher L Meyer will ensure safe ope rations by not allowing any PIC to operate the DJI Phantom 3 Professional UAS unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 Professiona l UAS in a manner consistent with the exemption, including evas ive and emerge ncy maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. **3. Reasons Why**

**A n Exemption From The Requirements Of Section 91.7(a)**  **Would Not A dv** **ersely A ffect Safety** 

**.** The equivalent level of safety established by Section 91.7(a) will be maintained because prior to every flight, Christopher L Meyer will ensure that the DJI Phantom 3 Professional 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, 110 67, 1108 0, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). **4. Reasons Why**

**A n Exemption From The Requirements Of Section 91.121**  **Would Not A dv** **ersely A ffect Safety** 

**.** The equivalent level of safety established by Se ction 91.12 1 will be maintained because the altitude information of the DJI Phantom 3 Professional UAS will be provided to thePIC via GPS equip ment and a radio communications telemetry data link, which

downlinks from the UA to t he GCS for active monitoring of the fl ight path and altitude. This altitude information, combined with Christopher L Meyer’s operation of the DJI Phantom 3 Professi onal UAS within visual line of sight, at or below 4 00 feet AGL, will ensure a level of safety equivalent to Section 91.121. The al titude information will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude in itiation point is automatically established by the UASs at ground level. The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exempt ion Nos. 11062, 11063, 11064, 11065, 11066, 11067, 110 80, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). **5. Reasons Why**

**A n Exemption From The Requirements Of Section 91.151(b)**  **Would Not A dv** **ersely A ffect Safety** 

**.** A grant of this exemption would ensure an equival ent level of safety established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical speci fications of the DJI Phantom 3 Professional UAS ; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, Christopher L Meyer will ensure that it will safely operate the battery powered DJI Phantom 3 Professional UAS during dayligh t 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 minute s. Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 3 Professional UAS ; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Phantom 3 Professional UAS prov ide audible and visual warnings to the PIC at the GCS when the UAs experiences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery power. At the critically low batte ry level, the DJI Phantom 3 Professional UAS will descend and land automatically. Significantly, previous exemptions granted by th e FAA concerning Section 91.151 establish that safety is not adversely affected when th e technical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescrib ed in Section 91 .151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in circumstances simila r, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 108 08, 10673 , 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 111 36, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). **6. Reasons Why**

**A n Exemption From The Requirements Of Sections**  **91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), A nd**  **91.417(a) & (b) Would Not**  **Ad versely** 

**A ffect Safety** 

**.** In seeking this exemption, Christopher L Meyer submi ts that the equivalent level of safety with regard to the regulatory maintenance and alte ration 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 Christopher L Meyer will perform maintenance, alterations, orpreventive maintenance on the UAS usi ng the methods, techniques, and practices

prescribed in the operating documents (i.e.

, Mo nthly Maintenance Log, and DJI Phantom 3 Professional Instruction Manual). Furthermore, Christopher L Meyer will document and maintain all maintenance records for the DJI Phantom 3 Professional UAS. Since the DJI Phantom 3 Professional UAS will be inspecte d as prescribed by the operating documents, Christopher L Meyer will maintain the equivalent level of safety established by Sections 91.405(a), 91.409( a)(1), and 91.409(a)(2). A copy of the DJI Phantom 3 Professional User Manual is attached hereto as Appen dix B. Likewise, the exemption sought will not adversel y affect safety because Christopher L Meyer will perform mainten ance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed by the operating documents

. Furthermore, the exemption sought would maintain an equivalent level of safety established by Sections 91.407, 91.417(a) and 91.417(b). Maintenance will be documented and m aintained utilizing the monthly maintenance log. Significantly, previous exemptio ns 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 th at safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered. In consideration of Christopher L Meyer’s proposed operating limitations, the operating documents, and the technical aspects of the DJI Phantom 3 Professional UAS

, Christopher L Meyer submits that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407( a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted relief specific to UAS in circumstances similar, in all material respects, to those p resented herein (e.g. Exemption Nos. 11062 , 11063, 11064, 11065, 11066, 11067, 110 80, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). **7. The FAA**

**Ma y**  **Prescribe A ny** 

**Other Conditions For Safe Operation.** In accordance with Section 333 of the FAA Modernizatio n and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Christopher L Meyer requests that the FAA prescribe special conditions for the intended operation of the DJI Phantom 3 Professional 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 photography over certain areas of the United States for compensation or hire. FMRA Section 333 sets forth t he requirements for con sidering whether a UAS will create a hazard to users of the NAS or the public, or otherwise po se
a threat to national security; and further, provides the au thority for such UAS to operate without airworthiness certification in accordance wit h any requireme nts that must be established for the safe o peration of the UAS in the NAS. Likewise, the Administrator may prescribe sp ecial conditions pursuant to 14 C.F.R. § 21.16, for operation of the DJI Phantom 3 Professional 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 regula tions of this subchapter do not contain

adequate or appropriate safety standards for a n aircraft, aircraft engine, or propeller because of a novel or unusual design fe ature of the aircraft, aircraft engine or propeller, he prescribes special condit ions and amendments thereto for the product. The special conditions are issued in accord ance with Part 11 of this chapter and contain such safety standards for t he aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent to that established in the regulations. See 14 C.F.R. § 21.16. Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for Leading Edge’ s intended operation of the DJI Phantom 3 Profess ional UAS , which con tain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a ), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). **A Summary That Can Be Published In The Federal Register, stating: The**  **Rules From Which Christopher L Mey** **er Seeks Exemption:**  Christopher L Meyer seeks exemption from the requirements of 14 C.F.R S ections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). **A Brief Description Of The Nature Of The Exemption**  **Christopher L Mey er**  **Seeks:** This exemption will permit Christopher L Meyer to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and Photography and Training over certain areas of the United States. **An y**  **Ad ditional Information, Views, Or A** **rguments A vailable To Support**  **Christopher L M ey** **er ’s Request.**  This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. As such, Christopher L Meyer’s request for exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R . Part 11, as set forth above. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the publ ic, 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, Christopher L Meyer will operate the DJI Phantom 3 Professional UAS safely i n the NA S, 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, Christopher L Meyer seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI Phantom 3 Professional UAS commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography and Training over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfi lling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests ofthe public, by allowing Christopher L Meye r to safely, efficientl y, and economically

operate the DJI Phantom 3 Profession al UAS commercially within the NAS. **WHEREFORE** , in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, Christopher L Meyer respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.1 51(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Leading Edge to operate the DJI Phantom 3 Professional UAS commercially for the purpose of conducting aerial video and photography and training over certain areas of the United States.

Dated: July 29 , 2015 Respectfully submitted, Christopher L Meyer

_____ ____________________ Christopher L Meyer 38619 Wa kefield Ct. Northville, Michigan 48167

Appendices: A

– DJI Phantom 3 Professional Specifications Data Sheet B

– DJI Phantom 3 Professional User Manual Hyperlink

APPENDIX

– A **DJI Phantom 3 Professional TEC HNICA**  **L SPECIFICA TIONS**  Christopher L Meyer only utilizes safe and reliable UAS . DJI is an industry leader in small UAS production. DJI UASs are loaded with ground breaking software enabling the

us er to set parameters which will not allow flight into control le d airspace. Parameters can also be set to limit flight to no higher than a predetermined an d 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 lin ked monitor (smart phone/tablet devices)

1.1 DJI Phantom 3 Professional 1.1.1 Aircraft 1.1.1.1 Supported Battery

– DJI 5200mAH LiPo Battery 1.1.1.2 We ight (Battery & Propellers Included)

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

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

- 200 0/s 1.1.1.5 Max Tilt Angel

- 35 0 1.1.1.6 Max Ascent Speed

– 6m/s 1.1.1.7 Max Descent Speed

– 2m/s 1.1.1.8 Max Flight Speed

– 15m/s (NOT RECOMMENDED) 1.1.2 Gimbal 1.1.2.1 Wo rki ng Current

– Static: 750mA; Dynamic: 900mA1.1.2.2 Control Accuracy

- ±0.03 0

1.1.2.3 Controllable Range

– Pitch:

- 90 0

- 0 0 1.1.2.4 Maximum Angular Speed

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

- 32 0 F

- 104 0 F (0 0 C

- 40 0 C) 1.1.3.2 Sen sor Size

– 1/2.3” 1.1.3.3 Effective Pixels

– 14M 1.1.3.4 Resolution

– 4384x3288 4.1.3.5 HD Video Recording

– 1080p30 & 720p 4.1.3.6 Recording Field of View

- 110 0 /85 0 1.1.4 Transmitter 1.1.4.1 Operating Frequency

– 5.728GHz

– 5.85GHz 1.1.4.2 Communication Distance (unobstructed)

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

- - 93dBm 1.1.4.4 Transmitter Power

– FCC Compliance: 100mW 1.1.4.5 Wo rking Voltage

– 120mA@3.7V 1.1.5 Range Extender 1.1.5.1 Operating Frequency

– 2412

- 2462MHz 1.1.5.2 Communication Distance (unobstructed)

– 500

- 700m 1.1.5.3 Transmitter Power

– 20dBm 1.1.5.4 Power Consumption

– 2W

APPENDIX

– B **DJI Phantom 3 Professional User Manual Hy**  **perlink** http://download.dji

innovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1. 2_en.pdf