March	15 ,	2015

U.S.	Department	of	Transportation Docket	Management	System 1200	New	Jersey	Ave.,	SE Washington,	DC	20590

Re:	Exemption	Request	under	Section	333	of the	FAA	Reform	Act	and	Part	11	of the

Federal Aviation	Regulations

Dear Sir	or	Madam:

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	(the "Reform	Act") and	14	C.F.R.	Part 11,	XplorIt	Multimedia	Technologies	(XplorIt)

, seeks	an	exemption	from	Federal Aviation	Regulations	("F ARs")	detailed	below	for

the DJI	Phantom	2	Vision+	Unmanned Aircraft	System	manufactured	by	DJI	of Shenzhen,	China.

The	requested	exemption	would	support	an	application	for	a	commercial	Certificate

of Authorization to	use	the	system	to	support	aerial	cinematography	for XplorIt’s

int eractive	virtual	multi

- m edia	platform .	The	DJI Phantom	2	Vision+	system	consists of	a	lightweight	(2.	73	pounds)	battery	operated	aircraft, based	on	a	small	hand

- held remote	control	operating	on	5.8	GHz	and	is	CE	and	FCC	compliant. In	addition	to	the

remot e	control,	the	DJI	Phantom	2	Vision	+	offers	the	pilot	with	First	Person Viewing	"FPV"	via	WiFi	connect ion	and	ground	control	receiver independent	of	the

main remote	control	device.	The	aircraft	carries an	onboard	geo

- referenced camera that	allows	it to	co nduct	precision imaging and	videography	at	the	re solutions necessary	for to	enhance our advanced virtual	exploration	technology .	This	high

resolution	imaging	will	be	used	as	an	educational	tool	to	improve	spatial	awareness and	to	advance	the	experience	wit hin	our	immersive	multi

- media	environments (examples	attached ,	Appendix	J )

The	aircraft	will	be	operated	in	the	field	with	both	a	Pilot	in	Command	(PIC)	and	a ground

- based Visual	Observer	(VO)	in	accordance	with	FAA	Policy N	8900.227 Section	14	"Operatio nal Requirements	for	UAS"	with	the	following	additional

restrictions:

- All	operations	will	occur	in	Class	G	airspace	at	no	more	than	400'	AGL- Operations	will	be	operated	over	private	property	with	the	perm ission	of	the	land

owner	or representative	of	lan d	owner

- All	required	permits	will	be	obtained	from	state	and	local	government	prior	to operation

- The	aircraft	will	not	be	operated	over	urban	areas

- When	necessary,	the	aircraft	will	only	be	operated	over	populated	business	parcels

before	normal busine ss	operating	hours	to	maintain	safe	and	efficient	flights	at	all times,	noting	the	general public's	safety	is	our	main	priority

- The	aircraft	will	not	be	operated	at	air	shows	or	over	an	open

- air	assembly	of people

- The	aircraft	will	not	be	operated	withi n	5	NM	of	an	airport	or	heliport

- Operations	will	be	limited	to	day,	visual	meteorological	conditions

- Aircraft	will	remain	within	Visual	Line	of	Sight	at	no	greater	than	1/2	NM	of	the	PIC

at	all	time

- While the	aircraft	is	airborne,	the	V O	will	be	posit ioned	within	voice	distance	to	the

PIC

The	PIC	and	V O	will	meet	the	requirements	outlined	in	FAA	Policy	N	8900.227

Section	16 Personnel	Qualifications.	Additionally,	the	PIC	and	VO	will	perform maintenance	on	the	system and	will	complete	a	course	of	maint enance	instruction as	part	of	their	initial	training.	Due	to	the simplicity	of	the	system,	we	do	not anticipate	the	need	for	a	supplemental	pilot.

We	submit	that	the	combination	of	the	aircraft's	light	weight,	historically demonstrated	flight performance, fully	qualified	flight	crew	and	strict	operation under	the	guidelines	established	in 8900.227,	the	FAA	can	have	confidence	that	the operation	will	have	an	equivalent	or	greater level	of	safety	of	manned	aircraft performing	the	same	mission.

The	name	and contact	information	of	the	applicant	are: XplorIt	Multimedia	Technologies 924	Incline	Way Incline	Village	NV	89451 Attn:	Greg	Murtha

Ph:	775

- 298

- 2690

Fax: 775

- 298

- 2677 Email:	greg@xplorIt .com

The	regulations	from	which	the	exemption	is	requested	are	as	fo llows:

- 14	CFR	Part	21

- 14	CFR	91.203

- 14	CFR	45.23,	45.29

- 14	CFR	91.9

- 14	CFR	61.113,61.133

- 14	CFR	91.11	9

- 14	CFR	91.121,91.151- 14	CFR	Subpart	E	(91.401

- 91.417)

- FAA	Policy	8900.227	Paragraph	16(c)(4)	and	Paragraph	16(e)(1)

Thanks	in	advance for	your	time	and	consideration.	We’re prepared	to	modify	or amend	any	part	of	this	request	to	satisfy	the	need	for	an	equivalent level	of	safety. Should	you	need	any	additional	information	or	clarification	please	feel	free	to contact	our	office	at	any	ti me.

Sincerely,

Greg

Greg	Murtha

President XplorIt	Multimedia	TechnologiesAppendices:

A.	Exemption	Request	and	Equivalent	Level	of	Safety

B.	Maintenance	Procedures

C.	User	Manual D.	Training	Program E.	Quick	Start	Guide	and Description	List F.	Model	Updates

G.	Manufacture	Disclaimer H.	Energy	Management	&	Battery	Guidelines I.	Aviation	Experience 31Page	Appendix	AAppendix	A

EXEMPTION	REQUESTS	AND	EQUIVALENT	LEVEL	OF	SAFETY XplorIt	Multimedia	Tec hnologies requests	an	exemption	from	the	following regulations	as	well	as	any	additional	regulations	that	may	technically	apply	to	the operation	of	the	DJI	Phantom	2	Vision+:

14	CFR	Part	21,	Subpart	H:	Airworthiness	Certificates

This	part	establishes	the procedures	for	the	issuance	of	an	airworthiness	certificate. While	the	FAA	continues	to	work	to	develop	airworthiness	standards	for	UAS,	we request	an	experimental	certificate	be	issued	for	the	DJI	Phantom	2	Vision+	under either	or	both	of	the	following	p rovisions:

21.191	Experimental	certificates. Experimental	certificates	are	issued	for	the	following	purposes: (a)	Research	and	development.	Testing	new	aircraft	design	concepts,	new	aircraft equipment,	new	aircraft	installations,	new	aircraft	operating	te chniques,	or	new

uses	for	aircraft. (b)	Showing	compliance	with	regulations.	Conducting	flight	tests	and	other operations	to	show	compliance	with	the	airworthiness	regulations	including	flights to	show	compliance	for	issuance	of	type	and	supplemental	type certificates,	flights to	substantiate	major	design	changes,	and	flights	to	show	compliance	with	the function	and	reliability	requirements	of	the	regulations.

Since	the	experimental	certificate	can	be	used	for	commercial	purposes	such	as market	surveys,	sa les	demonstrations,	and	customer	crew	training,	we	would	expect that	an	experimental	certificate	would	permit	our	commercial	purpose	as	well.

The	aircraft	will	not	carry	persons	or	property,	will	not	carry	fuel,	and	will	only	fly under	strict	operational requirements.	Combined	with	the	fact	that	the	aircraft weighs	only	2.	73	pounds	and	is	constructed	primarily	out	of	injected	plastic,	we propose	that	the	DJI	Phantom	2	Vision+	will	be	at	least	as	safe,	if	not	safer,	than	a conventionally	certificated	air cr aft	performing	the	same	missio n.

If	an	experimental	airworthiness	certificate	is	not	appropriate	for	this	application, then	we	request	an	exemption	of	14	CFR	Part	21,	Subpart	H,	and	the	requirement for	an	airworthiness	certificate	in	general,	citing	the	e quivalent	level	of	safety outlined	in	the	previous	paragraph.

14	CFR	91.203(a)	&	(b)	Civil	aircraft:	Certifications	required.

The	regulation	provides	that	an	airworthiness	certificate,	with	the	registration number	assigned	to	the	aircraft	and	a	registrat ion	certificate	must	be	aboard	the aircraft.	Additionally,	subparagraph(b) Provides that	the	airworthiness	certificate	be	"displayed	at	the	cabin	or	cockpit entrance	so	that	it	is	legibl e	to	passengers	or	crew."	At	2. 73	pounds,	the	DJI	Phantom

2	Vision+	i s	too	small	to	carry	documentation,	does	not	have	an	entrance,	and	is	not capable	of	carrying	passengers	or	crew.	To	obtain	an	equivalent	level	of	safety	and

meet	the	intent	of 91.203,	we	propose	that	documents	deemed	appropriate	for	this aircraft	by	the	F AA	will	be	co

- located	with	the	crew	at	the	ground	control	station and	available	for	inspection	upon	request.	In	order	to	identify	the	aircraft,	we propose	that	the	information	found	on	airworthiness	and	registration	certificates	be permanently	affixed	to	t he	aircraft	via	placard:

Manufacturer:	DJI

Model:	Phantom	2

Vision+

Model	Number:	PV331

Serial	Number:

PH645302668 Registered t o: XplorIt	Multimedia	Technologies 924	Incline	Way Incline	Village,	NV	89451

If	foun d	please	contact:	(775)	298

- 2690

14	CFR	45 .23	Display	of	marks;	general	and	45.29	Size	of	marks.

These	regulations	provide	that	each	aircraft	must	display	"N"	and	the	aircraft's registration	number	in	letters	at	least	3	inches	high.	Additionally,	the	aircraft	must display	the	word	"EXPERIMENTAL" in	letters	at	least	2	inches	high	near	the entrance	to	the	cabin,	cockpit,	or	pilot	station.	The	2.73	pound	DJI	Phantom	2

Vision+	does	not	have	an	entrance	in	which	the	word	"EXPERIMENTAL"	can	be placed,	and	may	not	have	a	registration	number	assigned	to	i t	by	the	FAA. We	propose	to	achieve	an	equivalent	level	of	safety	by	including	the	word "EXPERIMENTAL"	on	the	top	of	the	aircraft,	where	the	PIC,	VO	and	others	in	the vicinity	of	the	aircraft	while	it	is	preparing	for	launch	will	be	able	to	see	the designa tion.	Additionally,	we	feel	that	the	permanent	placard	discussed	in	the previous	paragraph	will	provide	the	aircraft's	registration	information	should	it	be found	on	the	ground.	Finally,	we	will	display	at	the	ground	station	a	high	contrast flag	or	banner that	contains	the	words	"Unmanned	Aircraft	Ground	Station"	in letters	3	inches	high	or	greater.	Since	the	airc raft	will	operate	within	site of	the ground	station,	the	banner	should	be	visible	to	anyone	that	observes	the	aircraft	and

chooses to	investigate it's	point	of	origin

.

14	CFR	91.9	Civil	aircraft	flight	manual,	marking,	and	placard	requirements.

This	regulation	provides	that	no	person	may	operate	an	aircraft	unless	a	current, approved	flight	manual	is	in	the	aircraft.	We	assume	that	the	intent	of	t hisrequirement	is	to	ensure	that	flight	manual	information	is	available	to	the	aircrew while	operating	the	aircraft.	We	request	an	exemption	to	this	requirement	since	the aircraft	is	not	only	too	small	to	carry	documentation,	the	documentation	would	not

b e	available	to	the	crew.

To	obtain	an	equivalent	level	of	safety	and	meet	the	intent	of 91.9,	we	propose	that	a current,	approved	Airplane	Flight	Manual	(appendix	E)	must	be	available	to	the crew	at	the	ground	station	anytime	the	aircraft	is	in,	or	prepar ing	for,	flight. 5I	Page	Appendix	A

14	CFR	61.113	Private	pilot	privileges	and	limitations:	Pilot	in	Command	and

61.133 Commercial	pilot	privileges	and	limitations.

The	regulation	provides	that	no	person	that	holds	a	private	pilot	certificate	may	act

as pilot	in	command	of	an	aircraft	for	compensation	or	hire.	Subparagraph	(b) allows	a	private	pilot	to	act	as	pilot	in	command	of	an	aircraft	in	connection	with any	business	or	employment	if:	(1)	The	flight	is	only	incidental	to	that	business	or employment; and	(2)	The	aircraft	does	not	carry	passengers	or	property	for compensation	or	hire.

Our	proposed	operations	meet	the	requirements	of8900.227	para	16(c)(2)(c) "Operations	without	a	pilot	certificate"	in	which	the	PIC	is	required	to	complete

"FAA	commercia l	pilot	ground	instruction"	and	pass	"the	FAA	commercial	pilot written	examination."	Since	there	are	currently	no	means	available	for	the	pilot	of	a UAS	to	gain	the	experience	in	an	equivalent	category	and	class	in	order	to	apply	for a	commercial	pilot's	l icense,	we	propose	to	generate	an	equivalent	level	of	safety	by requiring	our	pilots	to	complete,	at	a	minimum,	FAA	Private	Pilot	ground	instruction and	pass	the	FAA	Private	Pilot	written	examination	in	addition	to	completing	the Private	Pilot	requirements .	Since	the	aircraft	cannot	carry	passengers	or	property, we	feel	we	meet	the	intent	of	61.113	Subparagraph	(b)	even	though	the	intent	of this	application	is	to	conduct	a	business.

14	CFR	91.119	Minimum	safe	altitudes:	General.

The	regulation	provides	th at	over	sparsely	populated	areas	the	aircraft	cannot	be operated	closer	than	500	feet	to	any	person,	vessel,	vehicle,	or	structure.	Since	the aircraft	will	be	operating	at	a	maximum	of	400	feet	AGL,	we	cannot	comply	with	this requirement.	To	provide	an	equ ivalent	level	of	safety	we	will	only	fly	over	private property	with	the	permission	of	the landowner .	The landowner will	be	briefed	of the	expected	route	of	flight	and	the	associated	risks	to	persons	and	property	on	the ground.	We	maintain	that	due	to	the	s mall	size	of	the	DJI	Phantom	2	Vision+,	the hazard	to	persons,	vessels,	vehicles,	and	structures	is	not	comparable	to	manned aircraft	and	should	be	considered	in	granting	the	exemption.

The	aircraft	will	not	be	operated	over	congested	areas	nor	over	any	o pen	air assembly	of	persons. The	aircraft	will	be	operated	at	an	altitude	allowing,	if	a	powerunit	fails,	an	emergency	landing	without	undue	hazard	to	persons	or	property	on

the	surface.

14	CFR	91.121	Altimeter	settings.

The	regulation	provides	that	air craft	shall	maintain	cruising	altitudes	by	reference to	an	altimeter	setting	available	within	100	nautical	miles	of	the	aircraft.	The	aircraft will	fly	below	400	feet	AGL	and	will	not	need	to	maintain	hemispherical	cruising

altitudes	in	order	to	de

- conflic t	with	other	aircraft.	As	such,	an	appropriate	altimeter measurement	presented	to	the	pilot	should	be	Above	Ground	Level	and	should	be based	on	the	barometric	pressure	at	the	point	of	launch.	To	provide	an	equivalent level	of	safety,	the	UAS's	AGL	altimete r	will	be	set	to	zero	on	the	ground	prior	to every	flight.	Since	the	aircraft	will	fly	no	more	than	15	minutes	per	flight,	even	rapid changes	in	barometric	pressure	will	have	limited	affect	on	the	safety	of	the	flight.

14	CFR	91.151	Fuel	requirements	for flight	in	VFR	conditions.

The	regulation	provides	that	no	person	may	begin	a	flight	in	an	airplane	under	day

VFR	conditions	unless	there	is	enough	fuel	to	fly	to	the	first	point	of	intended landing	and	to	fly	after that	for	at	least	30	minutes.	We	feel	th e	intention	of	this paragraph	is	to	provide	a	reserve	of	energy	as	a	safety	buffer	for	go

- arounds	and other	delays	to	landing.

The	DJI	Phantom	2	Vision+	is	battery	operated	and	the	maximum	duration	of	flight from	a	single	battery	charge	is	15	minutes.	Sin ce	the	aircraft	will	never	fly	more than	1/2	nm	from	the	point	of	intended	landing,	a	full	battery	charge	at	launch	will ensure	that	we	meet	the	reserve	energy	requirement	of	this	paragraph.	We	request an	exemption	to	the	word	"fuel"	and	ask	for	an	equival ent	interpretation	with	the word	"energy".

14	CFR	Subpart	E	(91.401

- 91.417)

- Maintenance,	Preventive	Maintenance,

and Alterations.

The	regulation	provides	that	the	operator	is	primarily	responsible	for	maintaining the	aircraft	in	an	airworthy	condition ,	including	compliance	with	part	39	and	43. Paragraphs	91.407	and	91.409	require	that	the	aircraft	be	"approved	for	return	to service	by	a	person	authorized	under	43.7"	after	maintenance	and	inspection.	It	is our	intention	that	the	PIC	perform	maintenance and	inspection	of	the	aircraft	and "be	authorized	to	approve	the	aircraft	for	return	to	service."

As	provided	in	the	attached	Maintenance Procedures ,	the	PIC	will	ensure	that	the aircraft	is	in	an	airworthy	condition	prior	to	flight	and	conduct	detailed	i nspections after	every	10	hours.	Maintenance	performed	by	the	PIC	is	limited	to	repairing	small cracks,	replacing	a	propeller,	and	updating	s oftware	and	firmware.	All	other maintenance	will	be	performed	by	the	manufacturer.	The	PIC	will	document	workperfo rmed	in	accordance	with	91.417.	We	feel	that	due	to	the	size,	construction,	and simplicity	of	the	aircraft,	the	PIC	can	ensure	an	equivalent	level	of	safety.

8900.227 Paragraph	16(c)(4)	PIC	Medical and	Paragraph	16(e)(l)	Observer

Medical.

This	policy	pro vides	that	both	the	PIC	and	VO	must	have	a	valid	FAA	second

- class medical	certificate	issued	under	part	67	in	order	to	perform	as	a	pilot	or	observer. The	aircraft	weighs	2.73	pounds	and	is	constructed	out	of	injected	plastic.	Requiring

the	crew	to	meet	th e	same	medical	requirements	as	a	commercial	pilot	carrying passengers	in	a	large	aircraft	is	an	unnecessary	burden.

We	propose	that	the	minimum	medical	requirements	be	the	PIC	must	possess	a

current	third

- class	medical	certificate.	Given	the	unlikely	even t	that	both	the	PIC	and VO	become	medically	incapacitated	while	the	aircraft	is	in	flight,	the	DJI	Phantom	2 Vision+	will	recover	autonomously	to	the	landing	location	designated	prior	to

launch	without	crew	intervention.

Additional	Information	to	Support Request.

Per	Regulatory	Docket	No.	FAA

- 2014

- 0508	and	Exemption	N umber	11136,	we	feel XplorIt	Multi

- media	technologies models	the	similar	aforementioned	request	and that	all	information	provided	should	meet the	requirements	for	Section	333	Grant	of Exempt ion.

Appendix	B

MAINTENANCE	PROCEDURES http://wiki.dji.com/en/index.php/Phantom_2_Vision%2B_Flight_Testing

See	PDF	attachment	Phantom	2	Vision	Plus	User	manual	v	1.8	en.pdf		Appendix	C page	49	Troubleshooting

Appendix	C

USER	MANUAL See	PDF	attachment	Phantom	2	Vision	Plus	User	manual	v	1.8	en.pdf

Appendix	D

TRAINING	PROGRAM

- See	PDF Attachment http://download.dji

innovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Plus_Pi lot_Training_Guide_v1.1_en.pdf

Appendix	Ehttp://download.dji

innovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Plus_Q uick_Start_Guide_en.pdf

Appendix	F

MODEL	UPDATES http://download.dji

innovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Plus_R elease_Notes_en.pdf

Appendix	G

MANU FACTURE	DISCLAIMER http://download.dji

innovations.com/downloads/phantom_2_vision_plus/Phantom_2_Vision_Plus_Discl aimer.pdf

Appendix H

ENERGY	MANAGEMENT	AND	BATTERY	GUIDELINES http://download.dji

innovations.com/downloads/phantom_2_vision_plus/Smart_Flight_Batt ery_Safety_ Guidelines.pdf

Appendix	I

AVIATION	EXPERIENCE XplorIt	Multi

- media designates	(1)	pilot	for	all	duties	associated	with	the	UAS	for the	purpose	mentioned	in	A ppendix	A.	The	pilo t,	Greg	Murtha,	has	over	3 0 0	hours	of actual	flight	ti me	with	the	DJ I	Phantom	Platform.

Appendix	J

DMO's

LA	Tourism

- LA	Live

Santa	Clara	California

Huntington	Beach	California

Meet	Chicago	Northwest

Fairfield	California

California	Gold	Country

- El	Dorado	CountyFolsom	California

Truckee	California	with	Olympic	Gold	Medalist	Julia	Mancuso

Sacramento	Convention	Center

Salt	Lake	City

- Salt	Palace	Convention	Center

Hotels

Renaissance	Schaumburg

Hilton Anaheim

Attractions

Kennedy	Space	Center

Yosemite National	Park

Tree	Top	Adventure	Park

Chateau	Montelena	Vineyards	Napa

Napa	Valley	Wine	Train

Mammoth	Mountain	Ski	Area

National	Trade	shows	and	Events

HI	TECH	2014	LA	Convention	Center

Nike	US	Open	of	Surfing	with	12	Time	World	Champion	Kelly	Slater

Sprint	US	Grand	Prix

- US	Ski	and	Snowboard	Team

Education

BYU