**.I.-~uedeke** Aviation Consulting, LLC

- DBA "Aeroview Solutions"

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Attn: 4008 FarbenWay FortMill, SC 29715 980-272-7248 JDLuedeke@mac.com

U. S. Department ofTransportation Docket Operations West Building GroundFloor, Room w12-140 1200 New JerseyAve, SE Washington, DC 20590 RE: LUEDEKEAVIATION CONSULTING, LLC DBAAEROVIEW SOLUTIONS REQUESTAN EXEMPTIONFROMTHE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERALREGULATIONS 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) CONCERNING COMMERCIAL OPERATION OF DJI Inspire 1 UNMANNEDAIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THEFAAMODERNIZATIONAND REFORMACT OF 2012 (PUBLIC LAW 112-95)

### JustinD~

## owner~ LuedekeAviation Consulting, LLC 4008 FarbenWay Fort Mill, SC 29715 JDLuedeke@mac.com (980)-272-7248TABLE OF CONTENTS

GLOSSARY OF ABBREVIATIONS

..................................................................................3 SUMMARY

.........................................................................................................................4 INTRODUCTIONAND INTERESTS OF PETITIONER.

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

.................................................................................................................5 BASIS FOR PETITION

............................................................................. 5 NAMEANDADDRESS OF PETITIONER.

......................................................................6 THE SPECIFIC SECTIONS OF 14 C.F.R. FROMWHICHAEROVIEW SOLUTIONS SEEKS EXEMPTION

...............................................................................7 THE EXTENT OF RELIEF THEAEROVIEW SOLUTIONS SEEKS AND THE REASON THEAEROVIEW SOLUTIONS SEEKS THE RELIEF

............................................................................................... 10 THE REASONS WHY GRANTING AEROVIEW SOLUTIONS REQUEST WOULD BEIN THE PUBLIC INTEREST

.................................................................................... 12 THE REASONS WHY GRANTING THE EXEMPTION TO AEROVIEW SOLUTIONS WOULD NOTADVERSELYAFFECT SAFETY

........................................................... 14 SUMMARYTHAT CANBEPUBLISHED INTHE FEDERAL REGISTER.

................25 ANYADDITIONAL INFORMATION, VIEWS, ORARGUMENTS AVAILABLE TO SUPPORTAEROVIEW SOLUTION'S REQUEST

..........................................25 CONCLUSION

..................................................................................................................25 APPENDICES

...................................................................................... 26

2AGL AOI ATC ATO AV CFR COA FAA FAR GCS GPS LOL NAS NOTAM PIC Section 333 

## so SOP UA UAS VFR VLOS VMC VTOL GLOSSARY OF ABBREVIATIONS Above Ground Level Area ofInterest AirTraffic Control AirTraffic Organization Aerial Vehicle Code ofFederal Regulations Certificate ofAuthorization FederalAviationAdministration FederalAviation Regulation Ground Control Station Global Positioning System Loss ofLink National Airspace System Notice to Airman Pilot in Command FAAModernization andReformAct of2012 (FMRA) Safety Observer Standard Operating Procedures UnmannedAircraft UnmannedAircraft System Visual Flight Rules Visual Line ofSight Visual Meteorological Conditions Vertical Takeoffand Landing

3SUMMARY LuedekeAviation Consulting, LLC, dba. Aeroview Solutions hereafter referred to as AEROVIEW SOLUTIONS 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)(l) & (a) (2), and 91.417(a) & (b), to operate an UnrnannedAircraft System (Dll Inspire 1) pursuant to Section 333 ofthe FAAModernization and ReformAct of2012 (FMRA). This exemption will permitAEROVIEW SOLUTIONS to operate an UnrnannedAircraft System (UAS) for the commercial purpose ofconducting aerial video andphotography of construction sites, residential and commercial real estate, civil landscapes and events over certain areas ofthe United States. INTRODUCTIONAND INTERESTS OFTHE PETITIONER AEROVIEW SOLUTIONS and its owner, Justin D. Luedeke have worked in the NAS in various capacities for over 16 years as a pilot operating aircraft from single engine propeller aircraft up to and including transport categoryjetliners. Having over 5,000 flight hours and licensed as anAirline Transport Pilot, I hold a perfect safety record with an intimate knowledge ofall aspects oftheNAS. The objective ofAERO VIEW SOLUTIONS and our UnmannedAircraft System (DJI Inspire 1) aerial operations is to provide a more affordable, high-quality video and production system for a variety of governmental, commercial, public, and residential uses, specifically targeting

• Agricultural mapping

• Appraisals

• Business Marketing

• Auto Dealers • Pipeline and PowerLine observation and monitoring

• Real Estate • Construction sites • Civic Landmarks

• Special Events • Training inthe private and governmental sectors

4BACKGROUND



### UnmannedAircraft Systems: Dn Inspire 1, UAS

AEROVIEW SOLUTIONS seeks and exemptionto operate the DJI to operate the Dll Inspire 1 system for compensation or hire within the NAS. The DJI Inspire 1 is a vertical takeoffand landing (VTOL) UnmannedAircraft (UA) with a Ground Control Station (GCS) utilizing an electronic tablet or smart phone system. The Dll Inspire 1 has a maximum gross weight ofapproximately 6 lbs while having dimensions of 438x451x301 mm. The maximum speed is approximately 22m/sand a maximum flying height of400'. The Dll Inspire 1 is equipped with four main rotors, driven by Lithium Polymer battery powered electric motors. The Dll Inspire 1 that will be operated by AEROVIEW SOLUTIONS will be registered in accordance with 49 U.S.C., 44103, Registration of Aircraft, 

### as well as 14 C.P.R. Part 47,AircraftRegistration, 

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

BASIS FORPETITION 

### Petitioner, AEROVIEW SOLUTIONS, pursuantto the provisions ofthe FederalAviation Regulations (14 C.P.R.§ 11.61) and the FAAModernization and ReformAct of2012 (FMRA), Section 333, Special Rules for CertainUnmannedAircraft Systems, hereby petitions the Administrator to commercially operate the DJI Inspire 1, 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 ofthe speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, AEROVIEW SOLUTION'S operation ofDll Inspire 1UAS 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. Accordingly,AEROVIEW SOLUTIONS requests relieffrom Sections 91.405(a), 91.407(a)(l), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate. AEROVIEW SOLUTIONS submits thatthe requested reliefis proper since an equivalent level ofsafety will be ensured. AEROVIEW SOLUTIONS will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance 5onthe UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 InstructionManual). Furthermore, AEROVIEW SOLUTIONS will document and maintain all maintenance records for the DJI Inspire 1UAS. Relieffrom certain requirements ofSection 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested byAEROVIEW SOLUTIONS to the extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an airman medical certificate, and who has demonstrated, by meeting minimum flight- hour and currency requirements, thatthe PIC is able to safely operate the DJI Inspire 1UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. AEROVIEW SOLUTIONS seeks relieffrom Section 91.7(a), entitled Civil aircraft airworthiness, because the DJI Inspire 1 UAS do not require an airworthiness certificate in accordance with 14 

### C.P.R. Part 21, SubpartH. As such, AEROVIEW SOLUTIONS submits thatthey will ensure thatthe DJI Inspire 1UAS is in an airworthy condition, prior to every flight, by determining thatthe UAS are in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1InstructionManual), and that the aircraft are in a condition for safe flight. AEROVIEW SOLUTIONS also seeks an exemption from the requirements ofSection 91.121, entitledAltimeter Settings, as the DJI Inspire 1UAS will not have a typical barometric altimeter onboard. However, altitude information ofthe DJI Inspire 1UAS will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UAto the GCS for active monitoring ofthe flight path. This altitude information, combined withAEROVIEW SOLUTION'S operation ofthe DJI Inspire 1 UAS within visual line ofsight, at orbelow 400 feet AGL, will ensure a level ofsafety equivalent to Section 91.121. Additionally, AEROVIEW SOLUTIONS seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. AEROVIEW SOLUTIONS submits that safety will notbe affected by operation ofthe DJI Inspire 1 UAS during daylight hours invisual meteorological conditions (VMC) under visual flight rules (VFR), with enoughbattery power to fly for a total duration ofapproximately 23 minutes. Battery power indicators are also able to show exactly how much battery power is left, as well as how much time is needed to return safely back to point oftake off

6In accordance with 14 

### C.F.R. § 11.81, AEROVIEW SOLUTIONS provides the following information in support ofits petition for exemption: A. Name and Address OfThe Petitioner Justin D. Luedeke Owner Luedeke Aviation Consulting, LLC dba. Aeroview Solutions 4008 FarbenWay Fort Mill, SC 29715 (980) 272-7248 JDLuedeke@mac.com

B. The Specific Sections Of14 C.F.R. From Which AEROVIEW SOLUTIONS Seeks Exemption. 

### 1. AEROVIEW SOLUTIONS 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) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PIC ofan aircraft. (b) A private pilot may, for compensation or hire, 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 or property for compensation or hire. 2. AEROVIEW SOLUTIONS 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.

7

### 3. AEROVIEW SOLUTIONS Seeks Exemption From The Requirements OfSection 91.121. Section 91.121, entitledAltimeter settings, subsection (a), states the following, in part: (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeterthat is set, when operating-- (1) 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. 

### 4. AERO VIEW SOLUTIONS 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 of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes. 

### 5. AEROVIEW SOLUTIONS 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 inpart 43 ofthis chapter[.] 

### 6. AEROVIEW SOLUTIONS Seeks Exemption From The Requirements OfSection 91.407(a)(l) Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration, subsection (a)(1), states the following:

8(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless-- (1) Ithas been approved for return to service by a person authorized under§ 43.7 ofthis chapter[.] 

### 7. AEROVIEW SOLUTIONS Seeks Exemption From The Requirements Of Sections 91.409(a)(l)And 91.409(a)(2). Section 91.409, entitled Inspections, subsection (a), states the following: (a) Except as provided inparagraph (c) ofthis section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had-- (1) An annual inspection in accordance with part 4 3 ofthis chapter and has been approved for return to service by a person authorized by§ 43.7 ofthis chapter; or (2) An inspection for the issuance ofan airworthiness certificate in accordance with part 21 ofthis chapter. 

### 8. AEROVIEW SOLUTIONS Seeks Exemption From The Requirements Of Sections 91.417(a)And 91.417(b). Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following: (a) Except for work performed in accordance with§§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) ofthis section: (1) Records ofthe maintenance, preventive maintenance, and alteration andrecords ofthe 1

00-hour, annual, progressive, and other required 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 theAdministrator) ofthe work perfonned; and (ii) The date ofcompletion ofthe work performed; and (iii) The signature, and certificate number ofthe person approving the aircraftfor return to service. (2) Records containing the following information: (i) Thetotal time in service ofthe airframe, each engine, each propeller, and eachrotor.

9(ii) The current status oflife-limited parts ofeach airframe, engine, propeller, rotor, and appliance. (iii) The time 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 the time since the last inspection required by the inspection program under whichthe 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 and revision date. IftheAD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies ofthe forms prescribed by§ 43.9(d) ofthis chapter for each major alteration to the airframe and currently installed engines. rotors. propellers. and appliances. (b) The owner or operator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) ofthis section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed. (2) The records specified in paragraph (a)(2) 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 operator under § 43.11 ofthis chapter shall be retained until the defects are repaired and the aircraft is approved for return to service. C. The Extent OfReliefAEROVIEW SOLUTIONS SeeksAnd The Reason AEROVIEW SOLUTIONS Seeks The Relief. 1. Extent OfReliefAEROVIEW SOLUTIONS SeeksAnd The ReasonAEROVIEW SOLUTIONS Seeks ReliefFrom Section 61.113(a)And (b). Relieffrom Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command, is requested to the extent necessary to allow a PIC holding a private pilot 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 or hire. This reliefis 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 ofan aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or

10employment; and (2) The aircraft does not carry passengers or property for compensation orhire. As set forth more fully below, AEROVIEW SOLUTIONS submits that an equivalent level ofsafety will be maintained because no PIC will be allowed to operate the 

### Dll Inspire 1UAS unless that PIC has met certain flight-hour and currency requirements, demonstrating that the PIC is able to safely operate eitherthe DJI Inspire 1UAS in a manner consistent withthe operations specifications as described inthis exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures. Further, AEROVIEW SOLUTIONS submits that all flights ofthe DJI Inspire 1 UAS, conducted by the PIC pursuantto the grant ofthis Petition: (1) will be incidental to The AEROVIEW SOLUTION'S business; and (2) will not carry passengers orproperty for compensation or hire. 

### 2. Extent OfReliefAERO VIEW SOLUTIONS SeeksAnd The Reason AERO VIEW SOLUTIONS Seeks ReliefFrom Section 91.7(a). Relieffrom Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent requiredto allowAEROVIEW SOLUTIONS to determine thatthe DJI Inspire 1UAS are in airworthy condition priorto every flight by ensuring that the UAS is in compliance with the operating documents (i.e., AEROVIEW SOLUTIONS Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 InstructionManual). AEROVIEW SOLUTIONS seeks the requested reliefbecause the DJI Inspire 1UAS do not require an airworthiness certificate in accordance with 14 

### C.P.R. Part 21, SubpartH. Therefore, TheAEROVIEW SOLUTIONS will ensure that the DJI Inspire 1 UAS are in airworthy condition basedupon its compliance withthe operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1) prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated inthe conditions and limitations below. 3. Extent OfReliefTheAEROVIEW SOLUTIONS SeeksAndThe Reason The AEROVIEW SOLUTIONS Seeks ReliefFrom Section 91.121. Relieffrom Section 91.121, entitledAltimeter settings, may be required to allow flight operations ofthe 

### Dll Inspire 1UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UAto the PIC at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), AEROVIEW SOLUTIONS seeks the requested reliefbecause the DJI Inspire 1UA's altimeter may be set onthe ground to zero feetAGL, rather thanthe local barometric pressure or field altitude, before each flight.

11Considering the limited altitude ofthe proposed operations, relieffrom 14 CFR 91.121 is soughtto the extent necessary to comply with the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level ofsafety will be maintained since the DJI Inspire 1UAS are equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the PIC with altitude information ofthe UA on the heads-up display ofthe GCS. 4. Extent OfReliefAERO VIEW SOLUTIONS SeeksAnd The ReasonAERO VIEW SOLUTIONS Seeks ReliefFrom Section 

### 91.15l(b). Relieffrom Section 91.151(b) entitled Fuel requirements for flight inVFR conditions, is requested to the extent required to allow flights ofthe battery powered DJI Inspire 1UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of23 minutes. AEROVIEW SOLUTIONS seeks the requested reliefbecause without an exemption from Section 91.151(b), the flight time duration ofthe battery powered DJI Inspire 1UAS will severely constrain the practicality ofany aerial video or still photo flight operations thatAEROVIEW SOLUTIONS proposes to conduct pursuant to this Petition. Significantly, as set forth below, the technical specifications ofthe DJI Inspire 1 UAS, the DJI Inspire 1 operating documents, andAEROVIEW SOLUTIONS proposed operating limitations, ensure thatAEROVIEW SOLUTIONS will safely operate the battery poweredDJI Inspire 1UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enoughbattery power to fly for a total duration of23 minutes. 5. Extent OfReliefAEROVIEW SOLUTIONS Seeks And The ReasonAEROVIEW SOLUTIONS Seeks ReliefFrom Sections 91.405(a), 91.407(a)(l), 91.409(a)(1) & (a)(2), And 91.417(a) 

### & (b). Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, AEROVIEW SOLUTIONS requests relieffrom these Sections because the DJI Inspire 1UAS do not require airworthiness certificates. As set forth more fully below, the DJI Inspire 1UAS meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, AEROVIEW SOLUTIONS will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., AEROVIEW SOLUTIONS Aerial Operations Manual, Monthly Maintenance Log, DJI Inspire 1 Maintenance Manual and DJI Inspire 1Instruction Manual). Furthermore,AEROVIEW SOLUTIONS will document and maintain all maintenance records for the DJI Inspire 1 UAS.

12

### D. The Reasons Why GrantingAERO VIEW SOLUTION'S RequestWould Be In The Public Interest; ThatIs, 

### How ItWould Benefit The PublicAs AWhole. Granting the presentPetition will further the public interest by allowingAERO VIEW SOLUTIONS to safely, efficiently, and economically perform aerial video and photography ofagricultural and construction sites, real estate, events and civic landscape over certain areas ofthe United States. Additionally, use ofthe DJI Inspire 1UAS will benefitthe local economy, open new opportunities for business expansion among customers ofAEROVIEW SOLUTIONS, decrease the use offossil fuels currently used inmanned aircraft. allow cutting edge technology to decrease the costs associated withtraditional advertising and marketing, decrease pesticide and fertilizer use in agricultural operations and provide an localized operation that eliminates privacy concerns. Furthermore,AEROVIEW SOLUTIONS and the DJI Inspire 1 will be a much safer means ofaerial acquisitions comparedto traditional aircraft. 

### 1. 

### ThePublicWill See Both an Economical and Safety Benefit From The Use ofthe DJIInspire 1. The DJI Inspire 1 will allow a safer, more economical means ofmarketing local businesses and their products compared to conventional aircraft. While a conventional manned aircraft may weigh thousands ofpounds, produce noise levels significantly higher than the DJI Inspire 1 and emit pollutant inducing exhaust, all while creating a safety threat muchhigher than any UAS, the DJI Inspire 1 andAEROVIEW SOLUTIONS will operate a UAS weighing less than 10 lbs, produce very little noise and allow access to areas that traditional aircraft would find impossible to access. This ability, coupled with the new found advertising and marketing exposure oflocal businesses will drive interest and traffic to these businesses to newlevels. 

### 2. AEROVIEW SOLUTIONSAnd TheDJIInspire 1WillAllowA Reduction of Fertilizers and Pesticides. Currently, agricultural operations use a blanketpesticide and fertilizer approachto maintaining optimum health oftheir plants. With the Dll Inspire 1, we can identify specific areas ofa field that may need fertilizer ofpesticides vs. areas that do not. This will allowthe owner to precisely apply fertilizers and pesticides which will save thousands ofgallons ofchemicals from the environment eachyear. 

### 3. Businesses Will Have a New, Efficient Option to Better Showcase TheirProducts In order to remain competitive in the United States marketplace, businesses are constantly looking to innovate their advertising and marketing By using theDJI Inspire 1, AEROVIEW SOLUTIONS canprovide an economically efficientmeans ofaerial 13video and picture acquisition from angles never previously available. The Dll Inspire 1 can do this for a fraction ofthe cost oftraditional aircraft, and do so quietly (battery operated), safely and efficiently (less than 23 minutes offlight time). 

### 4. Privacy issues will benon-existent. The use ofthe DJI Inspire 1 will be operated with strict compliance to the DJI Inspire 1's operating manual, maintenance manual and all applicable FAARegulations. Furthermore, as traditional aircraft have always hadto operate in a much larger space, covering multiple private properties in orderto arrive at their destination, the DJI Inspire 1 does not require an airport, and can be launched and landed at the property ofintention, thereby eliminating privacy concerns. Also, AEROVIEW SOLUTIONS will maintain communication with law enforcement, and gain approval from the local land owner for all operations requiring such. 

### E. TheReasons Why Granting TheExemption Would NotAdverselyAffect Safety, OrHowTheExemption Would ProvideA Level OfSafetyAt Least EqualTo That Provided By The Rule From Which AEROVIEWSOLUTIONS Seeks Exemption. 1. Reasons Why The DJI Inspire 1UAS Meet The Conditions OfThe FAA Modernization andReformAct of2012 (FMRA) Section 333. In consideration ofthe size, weight, speed, and limited operating area associated withthe unmanned aircraft and its operation, AEROVIEW SOLUTION'S operation ofthe DJI Inspire 1 UAS meet the conditions ofFMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, SubpartH. 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 or the public, or otherwise pose a threatto national security. Specifically, FMRA Section 333 states the following, inpart: (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 rule making required by section 332 of this Act orthe guidance required by section 334 ofthis Act. (b) Assessment ofUnmannedAircraft Systems.--In 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, proximity to airports and populated areas, and operation within visual line ofsight do not create a hazardto users ofthe national airspace system orthe public orpose a threat to national security; and

14(2) whether a certificate ofwaiver, certificate ofauthorization, or airworthiness certification under section 44704 oftitle 49, United States Code, is required for the operation ofunmanned aircraft systems identified under paragraph (1). (c) Requirements for Safe Operation.--Ifthe Secretary determines under this sectionthat certain unmanned aircraft systems may operate safely inthe national airspace system, the Secretary shall establish requirements for the safe operation ofsuch aircraft systems in the national airspace system. In seeking this exemption,AEROVIEW SOLUTIONS submits thatthe Dll Inspire 1 UAS can operate safely inthe NAS pursuantto FMRA Section 333, as demonstratedby: (a) the characteristics ofthe Dll Inspire 1 UAS; (b) the pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications OfThe Dll Inspire 1 UAS Demonstrate Its Safe Characteristics. The Dll Inspire 1 UAS does not create a hazard to users oftheNAS or the public, or otherwise pose a threatto national security considering its size, weight, speed, and operational capability. 

### i. Technical Specifications OfThe Dn Inspire 1 UAS. The technical specifications oftheDll Inspire 1 UAS are set forth by the Dll Inspire 1 User Manual, attached hereto as AppendixA ii. The DJI Inspire 1 UAS Global Positioning Modes Enable The UAS To Remain Within A Defined OperationalArea The Dll Inspire 1 UAS may be operated 

### inboth manual and global positioning flight modes. A complete description ofthe flight and navigational modes ofthe DJI Inspire 1 UAS is provided at page 12 ofthe DJI Inspire 1 User Manual attached hereto as AppendixA. iii. The DJI Inspire 1 UAS Are DesignedForAutomatic ReturnTo Horne Point OrHover InTheEvent OfLoss OfThe Control Link OrNavigation. When the ControlLink is lost, the DJI Inspire 1UAS will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Inspire 1 UAS does not reacquire control link data from the GCS, the UAS will assume that the Control Link is lost and will return to the horne position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown. 15

15A complete description ofthe Failsafe Functions ofthe DJI Inspire 1UAS are set forth at pages 12 through 14 and page 50 ofthe DJI Inspire 1 User Manual, attached hereto as AppendixA. iv. The DJI Inspire 1 GCS And Its Operation. A complete description ofthe operation and specifications ofthe DJI Inspire 1 GCS and flight control software is provided at pages 12 through 18 and pages 45 through 51 ofthe DJI Inspire 1UserManual. The DJI Inspire 1User Manual is attached hereto as AppendixA. b. Flight Operations OfDJI Inspire 1UAS Is Limited To The Line OfSight OfA Certificated Pilot in CommandWithA Safety Observer. AEROVIEW SOLUTIONS staffwill bethe only persons to act as a pilot in command (PIC) ofthe DJI Inspire 1UAS. Additionally, a safety observer will assist him at all times during flight time.

c. Flights OfDJI Inspire 1 UAS Will Be Conducted PursuantTo Specific Operating Limitations. In seeking this exemption,AEROVIEW SOLUTIONS proposes to commercially operate 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 UAS weighing less than 55 pounds maximum gross weight: DJI Inspire 1 UnmannedAircraft Systems. Proposed operations ofany other aircraft will require a new petition or a petition to amendthis grant. 2. UAS operations under this exemption will be limited to conducting operations for the purpose ofaerial video and photography. 3. The UAS may not be flown at an indicated airspeed exceeding 20 knots. 4. The UAmust be operated at an altitude ofno more than 400 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved byATC. All altitudes reported to ATC mustbe in feetAGL. 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 on the PIC's FAA-issued airman medical certificate.

166. The use offirst person view (FPV) by the PIC or safety observer (SO) is not permitted. 7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The SO and PIC mustbe 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 canperfonnthe functions prescribed inthe operating documents. 8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is not permitted to operate the camera or other instruments. 9. The operating documents and the grant ofexemption mustbe accessible during UAS operations and made available to theAdministrator upon request. Ifa discrepancy exists between the conditions and limitations contained in the grant ofexemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant ofexemptiontake precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator's responsibility to track such revisions and present updated and revised documents to theAdministrator upon request. The operator must also presentupdated and revised documents ifit petitions for extension or amendmentto 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 amendmentto its grant ofexemption. The FAA's UAS Integration Office (AFS-80) may be contacted ifquestions arise regarding updates or revisions to the operating documents. 10. Prior to each flight the PIC must inspectthe UAS to ensure that it is in a condition for safe flight. Ifthe inspection reveals a conditionthat affects the safe operation ofthe UAS, the aircraft is prohibited 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 and alterations must be properly documented in the aircraft records. 11. Any UAS thathas 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.

1713. 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 ofreplacement/overhaul component parts 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. 16. The authorized person must make an entry inthe aircraft record ofthe corrective action taken against discrepancies discovered between inspections. 17. The PIC must possess at least a private pilot certificate and at least a currentthirdclass medical certificate. 18. The operator may not permit any PIC to operate unless the PIC meets the operator's qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with howthe UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes oftraining the operator's PICs are permitted under the terms ofthe exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience-building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UAwith appropriate distance from nonparticipants in accordance with 14 C.F.R. 

### § 91.119. 19. UAS operations may notbe conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Ifflight at night 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 UA may not operate within 5 nautical miles ofan airportreference point as denoted on a current FAA-published aeronautical chart unless a letter ofagreement with that airport's management is obtained, andthe operation is conducted in accordance with a NOTAM as required by the operator's CO A. The letter ofagreement with the airport management mustbe made available to theAdministrator upon request. 21. The UAmay not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

1822. Ifthe UA loses communications or loses its GPS signal, it must return to a predetermined 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 enough power to fly atnormal cruising speed to the intended landing point and landthe UAwith 25% battery powerremaining. 25. The operator must obtain anAir Traffic Organization (ATO) issued Certificate of Waiver orAuthorization (COA) prior to conducting any operations under the grant of exemption. This COAwill also require the operator to request a Notice to Airman (NOTAM) notmore than 72 hours in advance, butnot less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in theATO issued COAincluding class ofairspace, altitude level and potential transponder requirements. 26. All aircraft operated in accordance with the exemption must be identifiedby serial number, registered in accordance with 14 C.F.R. part 47, and have identification (NNumber) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable. 27. Before conducting operations, the radio frequency spectrum used for operation and control ofthe UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 mustbe available to the PIC at the Ground Control Station ofthe UAS any time the UAS is operating. These documents must be made available to theAdministrator or any law enforcement official upon request. 29. The UAmust remain clear and yieldthe right ofway 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 operations mustbe conducted at least 500 feet from all nonparticipating persons (persons other thanthe PIC, SO, operatortrainees or essential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UAand/or debris in the event ofan accident. The operator must ensure that nonparticipating persons remain under such protection. Ifa situation arises where

19nonparticipating persons leave such protection and are within 500 feet ofthe UA, 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 ofoperating closerto those objects and determined that it does not present an undue hazard, and;

c. Operations nearer to the PIC, SO, operatortrainees or essential persons do not present an undue hazard to those persons per § 91.119(a). 32. All operations shall be conducted over private or controlled-access property with permission from the land owner/controller or authorized representative. Pennission from land owner/controller or authorized representative will be obtained for each flight to be conducted. 33. Any incident, accident, or flight operation that transgresses the lateral orvertical boundaries ofthe operational area as defined by the applicable COAmust be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained onthe NTSB Web site: www.ntsb.gov. 2. Reasons WhyAnExemption FromThe Requirements OfSection 61.113(a) And (b) Would NotAdversely Affect Safety. AEROVIEW SOLUTIONS submits thatthe equivalent level ofsafety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the 

### Dll Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flighthour and currency requirements, that the PIC is able to safely operate the 

### Dll Inspire 1 UAS in a manner consistent withthe exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. ConsideringAEROVIEW SOLUTIONS proposed area ofoperations, and the operating limitations set forth-above; the parallel nature ofprivate pilot aeronautical knowledge requirements to those ofcommercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI Inspire 1 UAS, AEROVIEW SOLUTIONS submits that the additional manned airmanship experience ofa commercially certificated pilot would not correlate to the airmanship skills necessary for AEROVIEW SOLUTIONS specific proposed flight operations. The FAA has previously granted relieffrom Section 61.113(a) and (b) specific to UAS, in circumstances similar, 

### in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

20AEROVIEW SOLUTIONS will not allow any PIC to operate the DJI Inspire 1 UAS unless thatPIC has demonstrated, by meeting minimum flight-hour requirements orthe DJI Inspire 1UAS training and currency requirements, thatthe PIC is able to safely operate the DJI Inspire 1UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. 

### § 61.51(b), 25 hours oftotal time as a UAS rotorcraft pilot (with a minimum of5 hours ofthose hours as a UAS pilot operating the same make and model ofUAS to be used for operations under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety duringAEROVIEW SOLUTIONS proposed operations. TheAdministrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows: In ExemptionNo. 11062, the FAArequired thatprior to conducting operations for the purpose ofmotion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours oftotal time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor UAS. Priorto operations underExemptionNo. 11062, the PIC must also have accumulated and logged a minimum of5 hours as a UAS pilot operating the same make and model ofUAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours ofmulti-rotor time and the 10 hours may be included inthe total25 hours ofUAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAAfinds that at a minimum, the flight-hour requirements inExemptionNo. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conductthe petitioner's proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfY this requirement. Training, proficiency, and experience-building flights can also be conducted under the grant ofexemptionto accomplish the required flight time. During training, proficiency, and experience-building flights the PIC is required to operate the UAwith appropriate distances in accordance with 14 C.F.R 91.119. ExemptionNo. 11138 at page 15. Accordingly, AEROVIEW SOLUTIONS will ensure safe operations by not allowing any PIC to operate the DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting 21minimum flight-hour and currency requirements, thatthe PIC is able to safely operate the DJI Inspire 1UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 3. Reasons WhyAn Exemption From TheRequirements OfSection 91.7(a) Would NotAdverselyAffect Safety. The equivalent level ofsafety established by Section 91.7(a) will be maintained because prior to every flight, AEROVIEW SOLUTIONS will ensure that the DJI Inspire 1UAS 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 relieffrom Section 91.7(a) specific to UAS, 

### in circumstances similar, in all material respects, to those presented herein (e.g. ExemptionNos. 11062, 11063, 11064, 11065, 11066,11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 4. Reasons Why AnExemptionFromThe Requirements OfSection 91.121 WouldNot Adversely Affect Safety. The equivalent level ofsafety established by Section 91.121 will be maintained because the altitude information ofthe DJI Inspire 1UAS will be provided to the PIC via GPS equipment and a radio communications telemetry data link, which downlinks from the UAto the GCS for active monitoring ofthe flight path and altitude. This altitude information, combined withAEROVIEW SOLUTION'S operation ofthe DJI Inspire 

### 1 UAS within visual line ofsight, at orbelow 400 feetAGL, will ensure a level ofsafety equivalentto 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 by the UAS at ground level. The FAAhas 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). 5. Reasons \YhyAn Exemption From The Requirements OfSection 91.15l(b) Would NotAdverselyAffect Safety. A grant ofthis exemption would ensure an equivalent level ofsafety established by 14 C.

### FR. Section 91.151(b) as a result of(1) the technical specifications ofthe DJI Inspire 1 UAS; (2) the limitations onthe proposed flight operations; and (3) the location ofthe proposed flight operations. Accordingly, AEROVIEW SOLUTIONS will ensure that it will safely operate the battery powered DJI Inspire 1 UAS during daylight hours inVFR conditions, with enough battery power to fly for a total duration of23 minutes.

22Here, as in ExemptionNo. 11109, the technical specifications ofthe DJI Inspire 1 UAS; the limitations on the proposed flight operations; and the location ofthe proposed operations, will ensure an equivalent level ofsafety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Inspire 1 UAS provide audible and visual warnings to the PIC at the GCS when the UAS experiences lowbattery 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 1 UAS will descend and land automatically. Significantly, previous exemptions granted by the FAAconcerning 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 prescribed in Section 91.151, including ExemptionNos. 2689, 5745, and 10650. Moreover, the FAAhas previously granted relief from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those presented herein (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). 6. Reasons WhyAn Exemption From The Requirements OfSections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2),And 91.417(a) & (b) Would NotAdverselyAffect Safety. In seeking this exemption, TheAEROVIEW SOLUTIONS submits thatthe 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)(1) & (a)(2), and 91.417(a) & (b) will bemetbecauseAEROVIEW SOLUTIONS will use trained technicians to perform maintenance, alterations, orpreventive maintenance ontheUAS using the methods, techniques, and practices prescribed inthe operating documents (i.e., the AEROVIEW SOLUTIONSAerial Operations Manual, MonthlyMaintenanceLog, and DJI Inspire 1UserManual). Furthermore, AEROVIEW SOLUTIONS will document and maintain all maintenance records for theDJI Inspire 1UAS. Since the DJI Inspire 1UAS will be inspected as prescribedby the operating documents, AEROVIEW SOLUTIONS will maintain the equivalent level ofsafety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy ofthe DJI Inspire 1User Manual is attached hereto as AppendixA; a copy ofthe DJI Inspire 1UAS Maintenance Manual is attached hereto as AppendixB. Likewise, the exemption sought will not adversely affect safety becauseAERO VIEW SOLUTIONS will use trainedtechnicians to perform maintenance, alterations or preventive maintenance onthe UAS using the methods, techniques, and practices prescribed by the operating documents.

23Furthermore, the exemption sought would maintain an equivalent level ofsafety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance ofthe DJI Inspire 1UAS will be performed by trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log. Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(l), 91.409(a)(1) 

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

### & (b) establish that safety is not adversely affected whenthe technical characteristics and operating limitations ofthe UAS are considered. In consideration ofAEROVIEW SOLUTION'S proposed operating limitations, the operating documents, and the technical aspects ofthe DJI Inspire 1 UAS,AEROVIEW SOLUTIONS submits that safety will notbe 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 FAAhas previously granted reliefspecific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. ExemptionNos. 11062, 11063, 11064,11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156,11157, 11158, 11159, 11160, 11161). 7. TheFAA May PrescribeAny Other Conditions For Safe Operation. In accordance with Section 333 ofthe FAAModernization andReformAct of2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions,AEROVIEW SOLUTIONS requests that the FAAprescribe special conditions for the intended operation ofthe DJI Inspire 1 UAS, which contain such safety standards thattheAdministrator finds necessary to establish a level ofsafety equivalentto that established by 14 C.F.R. Part 21, SubpartH, 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 ofthe UAS for the limited purpose ofconducting aerial video and photography over certain areas ofthe United States for compensation orhire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users ofthe NAS orthe public, or otherwise pose a threatto national security; and further, provides the authority for such UAS to operate without airworthiness certification in accordance with any requirements that must be established for the safe operation ofthe UAS inthe 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 or unusual 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, or propeller because ofa novel or unusual design feature ofthe aircraft, aircraft engine or propeller, 24he 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 equivalent to that established in the regulations. See 14 C.P.R.§ 21.16. Therefore, in accordance withFMRA Section 333 and 14 C.P.R. § 21.16, the FAA may prescribe special conditions for AEROVIEW SOLUTION'S intended operation ofthe DJI Inspire 1UAS, which contain such safety standards that theAdministrator finds necessary to establish a level ofsafety equivalent to that establishedby 14 C.P.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 SummaryThat Can Be Published In The Federal Register, stating: The Rules From Which AEROVIEW SOLUTIONS Seeks Exemption: AEROVIEW SOLUTIONS seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a) (2), and 91.417(a) & (b). ABriefDescription OfTheNature OfTheExemptionAEROVIEW SOLUTIONS Seeks: This exemption will permitAEROVIEW SOLUTIONS to commercially operate an UnmannedAircraft System (UAS) for the purpose ofconducting aerial video and photography over certain areas ofthe United States.

• AnyAdditional Information, Views, OrArgumentsAvailable To Support AEROVIEW SOLUTION'S Request This Petition is made pursuantto the FAAModernization and ReformAct of2012 (FMRA) Section 333, which directs the Secretary ofTransportationto determine if certainUAS may operate safely inthe NAS. As such, AEROVIEW SOLUTION'S request for exemption may be granted pursuantto the authority ofFMRA Section 333 and 14 C.P.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 ofthe NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for suchUAS to operate without airworthiness certification. As discussed in detail above, AEROVIEW SOLUTIONS will operate the DJI Inspire 1 UAS safely in the NAS, without creating a hazard to users ofthe NAS, orthe public, or otherwise pose a threatto national security.

25CONCLUSION As set forth herein, AEROVIEW SOLUTIONS seeks an exemption pursuant to 14 C.P.R. 

### § 11.61 and Section 333 ofthe FAA Modernization and ReformAct of2012 (FMRA), which will permit safe operation ofthe DJI Inspire 1UAS commercially, without an airworthiness certificate, for the limited purpose ofconducting aerial video and photography over certain areas ofthe United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate ofthe FAA Modernization and ReformAct of2012, while also advancing the interests ofthe public, by allowing AEROVIEW SOLUTIONS to safely, efficiently, and economically operate the DJI Inspire 1UAS commercially within theNAS. WHEREFORE, in accordance with the FederalAviation Regulations and the FAA Modernization andReformAct of2012, Section 333, AEROVIEW SOLUTIONS respectfully requests thattheAdministrator 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)(l), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and pennitAEROVIEW SOLUTIONS to operate the DJI Inspire 1UAS commercially for the purpose of conducting aerial video and photography over certain areas ofthe United States. Dated: July 14,2015

Respectfully submitted, Justin D.**L~~** Owner

### ~A} LuedekeAviation Consulting, LLC dba. Aeroview Solutions 4008 FarbenWay FortMill, SC 29715 (980) 272-7248 JDLuedeke@mac.corn Appendices: A- Link to DJI UserManual: Click on link below http://download.dji-innovations.com/dm:vnloads/inspire 1/en/ Inspire 1 User Manual v1.2 en.pdf B- Linkto DJI Maintenance Manual: Click on link below http://dovm1oad.dji-innovations.com/dovmloads/inspire_l/enl Inspire _1_ Maintenance_ ManualV1.0 _en.pdf 26