### September 8, 2015

US Department ofTransportation, Docket Operations WestBuilding GroundFloor, RoomW12-140 1200NewJersey Avenue, SE Washington, DC 20590
Dear SirorMadam: Pursuantto Section 333 ofthe FAAModernization and ReformAct of2012 and CFR Part 11, I am submitting a requestto be exemptfrom the FederalAviation Regulations (FAR) listed below so I may operate UASs commercially inairspace regulatedbythe FAA as long as such operations are conductedwithin andunderthe conditions outlined hereinoras may be establishedbyFAAas requiredby Section 333. All operations will be performedwiththepublic's safety and rightto privacy at all times. Respectfully

Gale Stoner 744 Stonetrace Drive Murfreesboro, TN 37128 615-473-7674 gale@galestoner.com

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UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC Regulatory Docket No.



### IN THE MATTER OF THE PETITION FOR EXEMPTION OF: GALE L. STONER

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF
TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 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) CONCERNING COMMERCIAL OPERATION DJI Phantom 3 UNMANNED AIRCRAFT SYSTEMS and a BLANKET EXEMPTION FOR UAS OPERATION LESS THAN 55 POUNDS, DAYLIGHT OPERATION, VLOS, VFR AND BELOW 200 FEET AGL
PURSUANTTO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112--95)
Submitted on SEPTEMBER 8, 2015

GALE L. STONER 744 STONETRACE DRIVE MURFREESBORO, TN 37128 615-473-7674 GALE@GALESTONER.COM•.


### TABLE OF CONTENTS GLOSSARY OF ABBREVIATIONS .................................................•......•.....................................................•..... iii SUMMARY..................................••.......•...................•...................•.......••••.............•....................................... ! INTRODUCTION AND INTERESTS OF THE PETITIONER ...............•.•............................................................... 1 BACKGROUND

.............................................................................................................................................. 1 Unmanned Aircraft Systems: DJI Phantom 3 {Hereafterthe DJI UAS Aircraft)

............................................ 1 BASIS FOR PETITION

..................................................................................................................................... 1 Name And Address OfThe Petitioner

.......................................................................................................... 3 THE SPECIFIC SECTIONS OF 14C.F.R. FROM WHICH GALE L. STONER SEEKS EXEMPTION

........................... 3 GALE L. STONER Seeks Exemption From The Requirements OfSection 61.113(a) And (b)

.................... 3 GALE L. STONER Seeks Exemption From The Requirements OfSection 91.7{a)

..................................... 3 GALE L. STONER Seeks Exemption From The Requirements OfSection 91.121

..................................... 3 GALE L. STONER Seeks Exemption From The Requirements OfSection 91.151(b)

................................. 4 GALE L. STONER Seeks Exemption From The Requirement OfSection 91.405{a)

................................... 4 GALE L. STONER Seeks Exemption From The Requirements OfSection 91.407(a){l)

............................. 4 GALE L. STONER Seeks Exemption From The Requirements OfSections 91.409{a)(l) And 91.409(a)(2)

......................................................................................................................................4 GALE L. STONER Seeks Exemption From The Requirements OfSections 91.417{a) And 91.417{b)

........ 5 THE EXTENT OF RELIEF GALE L. STONER SEEKS AND THE REASON GALE L. STONER SEEKS THE RELIEF

.. 6 Extent Of Relief GALE L. STONER Seeks And The Reason GALE L. STONER Seeks Relief From Section 61.113(a) And (b)

.....................................................................................................................................6 Extent Of Relief GALE L. STONER Seeks And The Reason GALE L. STONER Seeks Relief From Section 91.7{a)

............................................................................................................................... 7 Extent Of Relief GALE L. STONER Seeks And The Reason GALE L. STONER Seeks Relief From Section 91.121

...............................................................................................................................7 Extent Of Relief GALE L. STONER Seeks And The Reason GALE L. STONER Seeks Relief From Section 91.151(b)

...........................................................................................................................8 Extent Of Relief GALE L. STONER Seeks And The Reason GALE L. STONER Seeks Relief From Sections 91.405(a), 91.407{a)(l), 91.409(a){l) 

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

### &(b)

................................ 8 The Reasons Why Granting GALE L. STONER Request Would Be In The Public Interest;That Is, How ItWould BenefitThe Public As A Whole

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

The Public Will Benefit From Decreased Congestion OfThe NAS

........................................................... 9 The Public Will Benefit From The SafetyAnd Efficiency OfThe DJI UAS Aircraft

.................................... 9 Performing Aerial Video and Photography Operations With The DJI UAS Aircraft will BenefitThe Economy

.............................................................................................................................. 10 There Are No Privacy Issues

.................................................................................................................... 10 The Reasons Why GrantingThe Exemption Would NotAdversely Affect Safety, Or HowThe Exemption Would Provide A Level OfSafetyAt Least Equal To That Provided By The Rule From Which GALE L. STONER Seeks Exemption

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Reasons WhyThe DJI UAS Aircraft MeetThe Conditions OfThe FAA Modernization and Reform Act of2012 (FMRA) Section 333

.................................................................................................... 11 The Specifications OfThe DJI UAS Aircraft Demonstrate Its Save Characteristics

....................................... 12 Technical Specifications of DJI UAS Aircraft

................................................................................................. 12 DJI UAS Aircraft GCS Operation

................................................................................................................... 12 Flight Operations of DJI UAS Aircraft are limitedTo The line OfSight OfA Certificated Pilot in Command With A Safety Observer

.......................................................................................................... 12 Flights of DJI UAS AircraftWill Be Conducted PursuantTo Specific Operating limitations

.................................. 12 Reasons WhyAn Exemption FromThe Requirements OfSection 61.113(a) And (b) Would Not Adversely Affect Safety

......................................................................................................................................... 16 Reasons WhyAn Exemption From The Requirements OfSection 91.7(a) Would NotAdversely Affect Safety

.......................................................................................................................................................... 18 Reasons WhyAn Exemption From The Requirements OfSection 91.121 Would NotAdversely Affect Safety

.......................................................................................................................................................... 18 Reasons Why An Exemption From The Requirements OfSection 91.151(b) Would NotAdversely Affect Safety

.......................................................................................................................................................... 18 Reasons WhyAn Exemption From The Requirements OfSections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would NotAdversely Affect Safety

........................................................................ 19 The FAA May Prescribe Any OtherConditions For Safe Operation

...................................................................... 20 A SummaryThat Can Be Published In The Federal Register, stating: The Rules From Which GALE L. STONER Seeks Exemption:

.......................................................................................................................21 Brief Description OfThe Nature OfThe Exemption GALE L. STONER Seeks:

........................................................ 21 AnyAdditional Information, Views, OrArguments Available To SupportGALE 

### L. STONER Request

.................... 21 CONCLUSION

.........................................................................................................................................................22 Phantom 3 Specifications and Description:

.................................................................................................. 23

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### GLOSSARY OF ABBREVIATIONS 

### AGL Above GroundLevel AOI ATC ATO AV CFR COA DllUAS Aircraft FAA FAR GCS GPS LOL NAS NOT AM PIC Section 333 

# so SOP UAV UAS VFR VLOS VMC VTOL AreaofInterest AirTraffic Control AirTraffic Organization Aerial Vehicle Code ofFederalRegulations Certificate ofAuthorization DllPhantom 3 subject ofthis Petition. Federal Aviation Administration FederalAviation Regulation Ground Control Station Global Positioning System Loss ofLink NationalAirspace System Notice to Airman PilotIn Command FAAMod and Reform Actof2012 (FMRA) Section 333 Safety Observer Standard OperatingProcedures UnmannedAircraft Vehicle UnmannedAircraft System Visual FlightRules Visual Line ofSite Visual Meteorological Conditions Vertical Takeoffand Landing

iii

### SUMMARY GALE 

### L. STONER seeks exemption from the requirements of 14 C.F.R §§61.113(a} 

### & (b), 91.7(a}, 91.121, 91.151(b}, 91.40S(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 ofthe FAA Modernization and Reform Act of 2012 (FMRA}. This exemption will permit GALE 

### L. STONER to operate an Unmanned Aircraft System (UAS} forthe commercial purpose ofconducting aerial video and photography in support ofsmall business, community and charitable activities in and around the State ofTennessee. 

### INTRODUCTION AND INTERESTS OF THE PETITIONER
GALE 

### L. STONER's primary occupation is a sole proprietorofa photography business. From time to time he is asked to support local community, small business, and charitable activities by providing commercial aerial photography orvideography. In the absence ofthe exemption, GALE L. STONER must decline to supportthese interests.The objective ofGALE 

### L. STONER and his aerial operations is to provide high quality imaging for avariety ofcommercial, public, and residential uses that are incidentalto his primary occupation, specificallytargeting

• GolfCourses • Church Properties • Real Estate Marketing 

### BACKGROUND
Unmanned Aircraft Systems: OJI Phantom 3 (Hereafterthe OJI UAS Aircraft)
GALE 

### L. STONER seeks an exemption to operate OJI Phantom 3 UAS systems for compensation or hire within the NAS. The DJI Phantom 3 is a vertical takeoffand landing (VTOL} Unmanned Aircraft (UA} with a Ground Control Station (GCS} utilizing electronictablet or smart phone systems. OJI Phantom 3 has a maximum gross weight of6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed ofapproximately 30 knots. The OJI Phantom 3 is equipped with four main rotors; driven by Lithium Polymer battery powered electric motors.
BASIS FOR PETITION Petitioner, GALE 

### L. STONER, pursuantto the provisions ofthe Federal Aviation Regulations (14 C.F.R. § 11.61} and the FAA Modernization and Reform Act of2012 (FMRA}, Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitionsthe Administrator to commercially operate the OJI UAS Aircraft 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}, 91.40S(a}, 91.407(a}(1}, 91.409(a)(1} 

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

### &(b).

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In consideration ofthe speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, GALE 

### L. STONER operation DJI UAS Aircraft meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingly, GALE 

### L. STONER requests relieffrom Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) 

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

### & (b), as these sections setforth requirements for maintenance thatonly apply to aircraft with an airworthiness certificate.
GALE 

### L. STONER submitsthatthe requested relief is proper since an equivalent level ofsafety will be ensured. GALE 

### L. STONER will use experienced personnel ortechnicians to perform maintenance, alterations, or preventive maintenance on the UASs usingthe methods, techniques, and practices prescribed in the operating documents.
Relieffrom certain requirements ofSection 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested by GALE 

### L. STONER tothe extent necessary to allow a Pilot in Command (PIC) with significant experience in the field of UAV's, and who has demonstrated, by meeting minimum flight--hour and currency requirements, thatthe PIC is able to safely operate the OJI UAS Aircraft in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.
GALE 

### L. STONER seeks relieffrom Section 91.7(a), entitled Civil aircraft airworthiness, because the OJI UAS Aircraft do not require an airworthiness certificate in accordance with 14C.F.R. Part 21, Subpart H. As such, GALE 

### L. STONER submits that he will ensure the DJI UAS Aircraftare in an airworthy condition, priorto everyflight, by determiningthatthe UASs are in compliance with the operating documents and thatthe aircraft are in a condition for safe flight.
GALE 

### L. STONER also seeks an exemption from the requirements ofSection 91.121, entitled Altimeter Settings; OJI UAS aircraft will not have a typical barometric altimeter onboard. However, altitude information ofthe OJI UAS Aircraft will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinksfrom the UAto the GCS for active monitoring ofthe flight path. This altitude information, combined with GALE 

### L. STONER operation ofthe DJI UAS Aircraftwithin visual line ofsight, at or below 400feetAGL, will ensure a level ofsafety equivalent to Section 91.121. Additionally, GALE 

### L. STONER seeks an exemption from the requirements ofSection 91.151(b), entitled Fuel requirements forflight in VFR conditions. GALE 

### L. STONER submits that safety will not be affected by operation ofthe DJI UAS Aircraft during daylight hours in visual meteorological conditions (VMC) undervisual flight rules (VFR), with enough battery powerto fly for atotal duration ofapproximately 15 minutestothe first point of intended landing and, assuming normal cruising speed, tofly afterthatfor at least 5 minutes.

2In accordance with 

### 14 C.F.R. § 

### 11.81, GALE L. STONER providesthe following information in support of its petition for exemption:
NameAnd Address OfThe Petitioner
The name and address ofthe Petitioner and point ofcontact is:
GALE 

### L. STONER 744 Stonetrace Drive Murfreesboro, TN 

### 37128 615-473-7674 (Mobile) gale@galestoner.com



### The Specific Sections Of 14 C.F.R. From Which GALE 

### L. STONER Seeks Exemption.
GALE L. STONER Seeks Exemption FromThe Requirements OfSection 61.113(a) And (b).
Section 

### 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections (a) and (b) prescribe thefollowing, in relevant part: No person who holds a private pilot certificate may act as a pilot in command (PIC) ofan aircraftthat is carrying passengers or propertyfor compensation or hire; nor maythat person, for compensation or hire, act as PIC ofan aircraft. A private pilot may, for compensation or hire, act, as PIC ofan aircraft in connection with any business or employment if- The flight is only incidental tothat business or employment; and the aircraft does notcarry passengers or propertyfor compensation or hire.

GALE L. STONER Seeks Exemption FromThe Requirements OfSection 91.7(a).
Section 

### 91.7, entitled civil aircraft airworthiness, subsection (a), statesthe following:



### (a) Nopersonmay operate a civil aircraft unless it is in an airworthy condition.
GALE L. STONER Seeks Exemption From The Requirements OfSection 91.121.
Section 

### 91.121, entitled Altimeter settings, subsection (a), states the following, in part:

3Each person operating an aircraftshall maintain the cruising altitude orflight level ofthat aircraft, as the case may be, by reference to an altimeterthat is set, when operating- Below 18,000feet MSL, to--The current reported altimeter setting ofa station along the route and within 100nautical miles ofthe aircraft; Ifthere is no station within the area prescribed in paragraph (a)(1)(i) ofthis section, the current reported altimetersetting ofan appropriate available station; or In the case ofan aircraft not equipped with a radio, the elevation ofthe departure airport or an appropriate altimetersetting available before departure.
GALE L. STONER Seeks Exemption FromThe Requirements

### OfSection 91.151(b).
Section 91.151, entitled Fuel requirements forflight in VFR conditions, subsection (b), states the following: (b) No person may begin a flight in a rotorcraft underVFR conditions unless (considering wind and forecast weather conditions) there is enough fuel toflytothe first point of intended landing and, assuming normal cruising speed, tofly afterthatfor at least 20 minutes.
GALE L. STONER Seeks Exemption FromThe Requirement

### OfSection 91.405(a).
Section 91.405, entitled Maintenance required, subsection (a), states thefollowing: Each owner or operator ofan aircraft- Shall have thataircraft inspected as prescribed in subpart Eofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part43 ofthis chapter [.]
GALE L. STONER Seeks Exemption From The Requirements 

### OfSection 91.407(a)(1)
Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration, subsection (a)(1), states the following: No person may operate any aircraftthat has undergone maintenance, preventive maintenance, rebuilding, or alteration unless--It has been approved for return to service by a person authorized under §43.7 ofthis chapter [.]
GALE L. STONER Seeks Exemption FromThe Requirements

### OfSections 91.409(a)(1) And 91.409(a)(2).
Section 91.409, entitled Inspections, subsection (a), states thefollowing: Except as provided in paragraph (c) ofthis section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had
-- An annual inspection in accordance with part43 ofthis chapter and has been approved for return to service by a person authorized by § 43.7 ofthis chapter; or An inspection for the issuance ofan airworthiness certificate in accordance with Part 21 ofthis chapter.



### 4GALE L. STONER Seeks Exemption FromThe Requirements

### OfSections 91.417(a) And 91.417(b).
Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following: Except forwork performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records forthe periods specified in paragraph (b) ofthis section:
Records ofthe maintenance, preventive maintenance, and alteration and records ofthe 100-- 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--A description (or reference to data acceptable tothe Administrator) ofthe work performed; and the date ofcompletion ofthe work performed; and
The signature and certificate number ofthe person approving the aircraftfor return to service.
Records containingthe following information:
The total time in service ofthe airframe, each engine, each propeller, and each rotor.
The current status of life--limited parts ofeach airframe, engine, propeller, rotor, and appliance.
The time since last overhaul ofall items installed on the aircraftwhich are required to be overhauled on a specified time basis.
The current inspection status ofthe aircraft, includingthe time since the last inspection required bythe inspection program underwhich the aircraft and its appliances are maintained.
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. Ifthe AD or safety directive involves recurring action, the time and date when the next action is required. Copies ofthe forms prescribed by§ 43.9(d) ofthis chapterfor each major alteration tothe airframe and currently installed engines, rotors, propellers, and appliances.

5The owner or operator shall retain the following records for the periods prescribed: The records specified in paragraph {a)(l) ofthis section shall be retained until the work is repeated or superseded by otherwork orfor 1year afterthe work is performed.
The records specified in paragraph (a)(2) ofthis section shall be retained and transferred with the aircraft atthe time the aircraft is sold. 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.


### The Extent of Relief GALE L. STONER Seeks and The Reason GALE L. STONER Seeks the Relief.
Extent of Relief GALE L. STONER Seeks and The Reason GALE 

### L. STONER 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 or higher level certificate, as well as a current and valid airman medical certificate, and who has met certain flight--hour and currency requirements, to conduct the proposed UAS flight operations for compensation or hire.
This relief is requested since the limitations set forth in Section 61.113{a) and (b) state that 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 propertyfor compensation or hire.
As set forth more fully below, GALE L. STONER submits that an equivalent level ofsafety will be maintained because no PIC will be allowed to operate the OJI Phantom 3 UAS unless that PIC has metcertain flight hour and currency requirements, demonstratingthatthe PIC is able to safely operate the OJI Phantom 3 UAS in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures. Further, GALE 

### L. STONER submits that all flights of OJI UAS aircraft, conducted by the PIC pursuant to the grant ofthis Petition: {1) will be incidental to GALE 

### L. STONER business; and {2) 

### will not carry passengers or propertyfor compensation or hire.

6

### Extent of Relief GALE L. STONER Seeks and The Reason GALE L. STONER Seeks Relief from Section 91.7(a).
Relieffrom Section 91.7(a) entitled Civil aircraft airworthiness, is requested tothe extent required to allow GALE L. STONER to determinethatthe DJI UAS Aircraft are in airworthy condition priorto everyflight by ensuringthatthe UAS is in compliance with the operating documents (i.e., the GALE 

### L. STONER Aerial Operations Manual, Monthly Maintenance Log, and OJI UAS Aircraft Instruction Manual).
GALE 

### L. STONER seeks the requested relief because the OJI UAS Aircraft do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, GALE 

### L. STONER will ensure thatthe OJI UAS Aircraft are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and OJI UAS Aircraft Instruction Manual) priorto everyflight, and further, determinethatthe aircraft are in condition for safe flight, as stated in the conditions and limitations below.


### Extent of Relief GALE L. STONER Seeks and The Reason GALE L. STONER Seeks Relieffrom Section 91.121.
Relieffrom Section 91.121, entitled Altimeter settings, may be required to allowflight operations ofthe OJI UAS Aircraft, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlinkaltitude information from the UA tothe PIC atthe ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to airtraffic control (ATC) in feet above ground level (AGL), GALE 

### L. STONER seeks the requested relief because the OJI UAS Aircraft altimeter may be set on the ground to zero feet AGL, ratherthan the local barometric pressure orfield altitude, before each flight. Considering the limited altitude ofthe proposed operations, relieffrom 14 CFR 91.121 is sought tothe extent necessary to comply with the applicable conditions and limitationsstated below. As more fully setforth herein, an equivalent level ofsafetywill be maintained since the OJI UAS Aircraft are equipped with a barometric pressure sensor and GPS equipment, which automatically ensures thataground level pressure setting will be established priorto each flight, and providesthe PIC with altitude information ofthe UA on the heads--up display ofthe GCS.



### 7Extentof Relief GALE L. STONER Seeks and The Reason GALE L. STONER Seeks Relieffrom Section 91.151(b).
Relieffrom Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested tothe extent required to allowflights ofthe battery powered DJI UAS Aircraft during daylight hours in visual meteorological conditions (VMC), undervisual flight rules (VFR), for a total duration of 15 minutes tothe first point of intended landing and, assuming normal cruising speed, to fly afterthatfor at least 5 minutes. GALE l. STONER seeks the requested relief because without an exemption from Section 91.15l(b), the flight time duration ofthe battery powered DJI UAS Aircraft will severely constrain the practicality of any aerial video or still photo flight operations that GALE l. STONER proposes to conduct pursuant tothis Petition. Significantly, as set forth below, thetechnical specifications ofthe DJI UAS Aircraft operating documents, and GALE 

### l. STONER proposed operating limitations, ensure that GALE 

### l. STONER will safely operate the battery powered DJI UAS Aircraft during daylight hours in visual meteorological conditions (VMC), undervisual flight rules (VFR), with enough battery powerto flyfor a total duration of 15 minutestothe first point of intended landing and, assuming normal cruising speed, to fly afterthat for at least 5 minutes.
Extentof Relief GALE L. STONER Seeks and The Reason GALE L. STONER Seeks Relieffrom Sections 91.40S(a), 91.407(a)(1), 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, GALE l. STONER requests relieffrom these
Sections because the DJI UAS Aircraft do not require airworthiness certificates. As setforth more fully below, DJI UAS Aircraft meetthe conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, GALE 

### l. STONER will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the GALE l. STONER Aerial Operations Manual, Monthly Maintenance Log, and DJI UAS Aircraft Instruction Manual). Furthermore, GALE 

### l. STONER will document and maintain all maintenance records for the DJI UAS Aircraft.
The Reasons Why Granting GALE L. STONER Request Would Be inThe Public Interest;That Is, How ItWould Benefitthe Public as a Whole. Granting the present Petition will furtherthe public interest by allowing GALE l. STONER to safely, efficiently, and economically perform aerial video and photography of construction sites, real estate, and landscape over certain areas ofthe United States.

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Additionally, use ofthe 

### OJI UAS Aircraft will decrease congestion ofthe NAS, reduce pollution, and provide significant benefitstothe economy. Notably, the benefits ofGALE L. STONER proposed operation ofthe 

### OJI UAS Aircraft would be realized without implicating any privacy issues.
The PublicWill Benefitfrom Decreased Congestion ofThe NAS.


### DJI UAS Aircraft is battery powered and serves as a safe, efficient, and economical alternative tothe manned aircrafttraditionally utilized to obtain aerial imagery. By reducing the amount ofmanned aircraft needed to perform aerial acquisitions, an exemption allowing the use ofa 

### OJI UAS Aircraft would reduce the amount ofmanned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground. Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The 

### OJI UAS Aircraft does not require an airportto takeoffor land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would result in fewer aircraftthat must be handled by airtraffic control duringthe ground, takeoff, departure, arrival, and landing phases offlight operations.

The Public Will Benefitfrom The Safetyand Efficiency ofThe DJI UAS Aircraft Conducting aerial acquisitions with the 

### OJI UAS Aircraft, instead of manned aircraft, will greatly benefitthe public by drastically reducing the levels ofair and noise pollution generated during traditional aerial video and still photographyflight operations. By using battery power and electric motors, the 

### OJI UAS Aircraft produce no air pollution, and is the mostviable environmentally conscious alternative tothe cabin class, six cylinder internal combustion engine aircraftthat are typically utilized for aerial video and photography, while burning approximately
20--30 gallons per hourof leaded aviation fuel. The 

### OJI UAS aircraft, while reducing the carbon footprint ofaerial acquisitions, also eliminates noise pollution, as the UAs are propelled by battery powered electric motors, ratherthan an internal combustion engine. By using the 

### OJI UAS Aircraftto perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated.



### 9Aside from the lack offlight crew members located onboard the aircraft, the OJI UAS Aircraft (weighing approximately2 pounds 11 ounces and 6 pounds 7.5 ounces respectively, attheir maximum gross weights with lengths of 16 inches and 17.3 inches respectively, widths of 16 inches and 17.7 inches respectively, and with nofuel on board), has less physical potential for collateral damage to life and property on the ground, and in the air, compared tothe manned aircraftthattypically conduct similar operations (weighing approximately 6,000 pounds with a wingspan ofapproximately42 feet, a length of34 feet, and a fuel capacity of 180gallons). PerformingAerial Video and Photography Operations withThe DJI UAS AircraftWill Benefitthe Economy.
In addition to being safe and efficient, the OJI UAS Aircraft are also an economical alternative to using manned aircraftto conduct similar aerial operations. As such, operation ofthe OJI UAS Aircraft will allow United States based companies, like GALE 

### L. STONER, to remain competitive and contribute to growth ofthe U.S. economy. Specifically, with the rising cost ofaviation fuel and the Environmental Protection Agency ("EPA") regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt newand alternative technology in orderto remain competitive. Operatingthe battery powered OJI UAS Aircraft is one such technology that notonlyallows companies greater operational flexibility compared to manned aircraft, but provides such flexibility withoutthe high operational cost ofatraditional manned aircraft. By operating the OJI UAS aircraft, petitionerssuch as GALE 

### L. STONER can remain competitive and profitable, and therefore, provide greaterjob stabilityto employees and contractors, which will ultimately contribute togrowth ofthe U.S. economy. Improved financial performance of U.S. companies, through commercial use ofthe OJI UAS Aircraft, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the United States and abroad.
ThereAre No Privacy Issues.
Similartothe manned aerial acquisition flight operationsthat have been conducted for decades, GALE 

### L. STONER proposed operation ofthe OJI UAS Aircraft will not implicate any privacy issues. Specifically, the DJI UAS Aircraftwill be operated only in compliance with operating documents (i.e., the GALE 

### L. STONER Aerial Operations Manual, Monthly Maintenance Log, and OJI UAS Aircraft Instruction Manual), which requires property owner involvementas well as local lawenforcement notification, and in accordance with the Federal Aviation Regulations, includingthe minimum altitude requirements of 14 C.F.R. § 91.119.

10The Reasons WhyGrantingthe Exemption Would NotAdverselyAffect Safety, Or Howthe Exemption Would Provide a Level ofSafety at Least Equal toThat Provided byThe Rule from Which GALE L. STONER Seeks Exemption.
Reasons WhyThe OJI UAS Aircraft Meetthe Conditions ofThe FAA Modernization and Reform Act of2012 (FMRA) Section 333.
In consideration ofthe size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, GALE L. STONER operation ofthe OJI UAS Aircraft 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 authorityfor a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users ofthe NAS orthe public, or otherwise pose athreatto national security. Specifically, FMRA Section 333 statesthe following, in part: In General. ----Notwithstanding any other requirement ofthis subtitle, and not laterthan 180days afterthe date ofenactment ofthis Act, the Secretary of Transportation shall determine ifcertain unmanned aircraft systems may operate safely in the national airspace system before completion ofthe plan and rulemaking required by section 332 ofthisAct orthe guidance required by section 334 ofthisAct.
Assessment of Unmanned Aircraft Systems. ----In makingthe determination undersubsection (ate Secretary shall determine, at a minimumWhich types of unmanned aircraft systems, ifany, as a result oftheir size, weight, speed, operational capability, proximityto airports and populated areas, and operation within visual line ofsight do not create a hazard to users ofthe national airspace system orthe public or pose a threat to national security; and whether a certificate ofwaiver, certificate ofauthorization, or airworthiness certification undersection 44704 oftitle 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1). Requirements for Safe Operation.

- Ifthe Secretary determines underthis section that certain u), unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation ofsuch aircraft systems in the national airspace system.
In seeking this exemption, GALE 

### L. STONER submits thatthe OJI UAS Aircraft can operate safely inthe NAS pursuantto FMRA Section 333, as demonstrated by: (a) the characteristics ofthe OJI UAS aircraft; (b) the pilot certification requirement; and (c) the specific operating limitations.

11The Specifications ofThe DJI UAS Aircraft Demonstrate ItsSafe Characteristics.
The DJI UAS Aircraft do notcreate a hazard to users ofthe NAS orthe public, or otherwise pose a threatto national security considering its size, weight, speed, and operational capability.
Technical Specifications of DJI UAS Aircraft.
The technical specifications ofthe DJI UAS Aircraft are setforth by the DJI UAS aircraft User Manuals, attached hereto as Appendix A and B.
The DJI UAS Aircraft Autonomous Flight and Navigation Modes Enable The UASs to Remain Within a Defined Operational Area.
The DJI UAS Aircraft may be operated in both manual and fully autonomous flight modes. A complete description ofthe flight and navigational modes ofthe DJI UAS Aircraft provided in the User Manuals, attached hereto as Appendix A and B.
The DJI UAS AircraftAre Designed forAutomatic Return to Home Point or Hover in The Event of Loss ofthe Control Link or Navigation.
When the Control Link is lost, the DJI UAS Aircraft will remain stationary, in flight, for 3 seconds or more. If, after3 seconds, the DJI UASAircraft do not reacquire control link data from the GCS, the UAs will assume thatthe Control Link is lost and the UAs will return tothe home position (i.e., failsafe mode)via GPS, and will descend tothe takeoff position and shutdown.
A complete description ofthe Failsafe Functions ofthe DJI UAS aircraft are described in the User Manuals, attached hereto as Appendix A and B.
DJI UAS Aircraft GCS Operation.
Phantom 3 GCS and flight control software is provided in the User Manual forthe DJI UAS aircraft attached hereto as AppendixA and B. FlightOperations of DJI UAS Aircraftare Limited toThe Line ofSightofa Certificated Pilot in Command with A SafetyObserver.
GALE L. STONER will be the only person to act as a pilot in command (PIC) of DJI UAS Aircraft Flights of DJI UAS AircraftWill Be Conducted Pursuantto Specific Operating Limitations.

12In seeking this exemption, GALE L. STONER proposes to commercially operate OJI UAS Aircraft for the special purpose ofconducting aerial video and photography over certain areas of United States, pursuantto the following specific operating limitations:

1. Operations authorized by this grant ofexemption will be limited tothe following aircraft described in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: OJI UAS AIRCRAFT. Proposed operations ofany other aircraft will require a new petition or a petition to amend this grant. 2. UAS operations underthis exemption will be limited to conducting operationsforthe purpose of aerial video and photography. 3. The UAs may not be flown atan indicated airspeed exceeding 45 knots. 4. The UA must be operated atan altitude of no morethan 400feet above ground level (AGL), as indicated bythe procedures specified in the operating documents unless a special request is made and approved by ATC. All altitudes reported toATC must be 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 otherthan corrective lenses, as specified on the PIC's FAA--issued airman medical certificate. 6. The use offirst person view (FPV) by the PIC orsafety observer (SO} is not permitted. 7. All operations must utilize a safety observer (SO). The SO may be used to satisfytheVLOS requirement as long as the PIC always maintainsVLOS capability. The SO and PIC must be able to communicate verbally at all times. Electronic messaging ortexting is not permitted duringflight operations. The PIC must be designated before theflight and cannottransfer his or her designation forthe duration ofthe flight. The PIC must ensure thatthe SO can perform thefunctions prescribed in the operating documents. 8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding otherairtraffic and otherground based obstacles/obstructions and is not permitted to operate the camera or other instruments. 9. The operating documents and the grant ofexemption must be accessible during UAS operations and made available tothe Administrator upon request. Ifa discrepancy exists between the conditions and limitations contained in the grant ofexemption and the procedures outlined in the operatingdocuments, the conditions and limitations contained in the grant ofexemption take precedence and must be followed. Otherwise, the operator mustfollow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator's responsibility totrack such revisions and present updated and revised documentstothe Administrator upon request. The operator must also present updated and revised documents ifit petitions for extension or amendmenttothe grant ofexemption. Ifthe operator determinesthat any update or revision would affectthe basis upon which the FAA granted the exemption, then the operator must petition for amendmentto itsgrant ofexemption. The FAA's UAS Integration Office (AFS80} may be contacted ifquestions arise regarding updates or revisions tothe operating documents.

1310. Priorto each flight the PIC must inspect the UAS to ensure that it is in a condition forsafe flight. Ifthe inspection reveals a condition that affectsthe 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 forsafe flight. The Ground Control Station must be included in the Preflight inspection. All maintenance and alterations must be properly documented in the aircraft records. 11. Any UAS that has undergone maintenance or alterations that affectthe UAS operation orflight characteristics, e.g. replacement ofa flight critical component, must undergo afunctional testflight. The PIC who conducts thefunctional test flight must make an entry in the aircraft records. 12. The pre--flight inspection must accountfor all potential discrepancies, e.g. inoperable components, items, or equipment, notalready covered in the relevant sections ofthe operating documents. 13. The operator mustfollowthe UAS manufacturer's aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. 14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be 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 UASs operated underthis exemption mustcomply with all manufacturer Safety Bulletins. 16. The authorized person must make an entry in the aircraft record ofthe corrective action taken against discrepancies discovered between inspections. The operator may not permit any PIC to operate unless the PIC meetsthe operator's qualification criteria and demonstratesthe abilityto safely operate the UAS in a mannerconsistent with howthe UAS will be operated underthe exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualificationflight hours must be logged in a manner consistent with 14 C.F.R. §61.51(b). Flights forthe purposes oftrainingthe operator's PICs are permitted undertheterms ofthe exemption. However, training operations mayonly be conducted during dedicated training sessions. During training, proficiency, and experience-building flights, all persons notessential for flight operations are considered nonparticipants, and the PIC mustoperate the UA with appropriate distance from nonparticipants in accordance with 14C.F.R. § 91.119. 17. UAS operations may not be conducted during night, as defined in 14 C.F.R. 18. §1.1. All operations must be conducted undervisual meteorological conditions (VMC). Ifflight at night is required, a special request will be made atthe FAA office closest to proposed area of operations. Flights underspecial visual flight rules (SVFR) are not authorized. 19. The UAV may notoperate within 5 nautical miles ofan airport reference point as denoted on a current FAA--published aeronautical chart unless a letterofagreement with that airport's management is obtained, and the operation is conducted in accordance with a NOTAM as required bythe operator's COA. The letterofagreement with the airport management must be made available tothe Administrator upon request.

1420. The UAV may not be operated less than 500 feet below or less than 2,000 feet horizontallyfrom a cloud orwhen visibility is less than 3 statute milesfrom the PIC. 21. Ifthe UAV loses communications or loses its GPS signal, it must return to a pre-determined location within the planned operating area and land or be recovered in accordance with the operating documents. 22. The PIC must abortthe flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents. 23. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough powertofly at normal cruising speed tothe intended landing point and land the UAV with 25% battery power remaining. 24. The operator must obtain an AirTraffic Organization (ATO) issued Certificate ofWaiver or Authorization (COA) priorto conducting any operations underthe grant ofexemption. This COA will also require the operatorto request a Notice toAirman (NOTAM) not morethan 72 hours in advance, but not less than 48 hours priortothe operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class ofairspace, altitude level and potential transponder requirements. 25. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (N--Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable. 26. Before conducting operations, the radio frequency spectrum used for operation and control of the UAV must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 27. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available tothe PIC at the Ground Control Station ofthe UAS any time the UAS is operating. These documents must be made available tothe Administrator or any law enforcementofficial upon request. 28. The UAV must remain clear and yield the right ofwayto all manned aviation operations and activities at all times. 29. The UAV may not be operated bythe PIC from any moving device orvehicle. 30. Flight operations must be conducted at least 500feetfrom all nonparticipating persons (persons otherthan the PIC, SO, operatortrainees or essential persons), vessels, vehicles, and structures unless: 31. Barriers orstructures are presentthat sufficiently protect nonparticipating persons from the UAV and/or debris in the event ofan accident. The operator must ensure that nonparticipating persons remain under such protection. Ifa situation arises where nonparticipating persons leave such protection and are within 500feet ofthe UA, flight operations must cease immediately and/or; 32. The aircraft is operated nearvessels, vehicles orstructures where the owner/controller ofsuch vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of the risk ofoperating closer tothose objects and determined that itdoes not present an undue hazard, and;

1533. Operations nearertothe PIC, SO, operatortrainees or essential persons do not present an undue hazard tothose persons per§ 91.119(a). 34. All operations shall be conducted over private or controlled--access propertywith permission from the land owner/controller or authorized representative. Permission from land owner/controllerorauthorized representative will be obtained for each flightto be conducted. 35. Any incident, accident, orflight operation thattransgresses the lateral orvertical boundaries of the operational area as defined bythe applicable COA must be reported to the FAA's UAS Integration Office (AFS--80) within 24 hours. 36. Accidents must be reported tothe NationalTransportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. 

### Reasons Why an Exemption from The Requirements ofSection 61.113(a) And (b) Would Not Adversely Affect Safety. GALE L. STONER submitsthatthe equivalent level ofsafety established bySection 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI UAS Aircraft unless that PIC has demonstrated, by meeting minimum flight--hour and currency requirements, thatthe PIC is able to safely operate the OJI UAS Aircraft in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering GALE 

### L. STONER proposed area ofoperations, and the operating limitations set forth--above;the parallel nature of private pilot aeronautical knowledge requirements tothose ofcommercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI UAS aircraft, GALE L. STONER submits thatthe training, preparation, practice, and experience ofthe Petitioner is sufficientto meetthe requirements of the proposed use.
The FAA has previously granted relieffrom Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, tothose 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).
GALE 

### L. STONER will notallow any PIC to operate the DJI UAS Aircraft unless the PIC has demonstrated, by meeting minimum flight--hour requirements orthe OJI UAS Aircrafttraining and currency requirements, thatthe PIC is able to safely operate the DJI UAS Aircraft in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

16Specifically, 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 operatingthe same make and model of UAS to be used for operations underthe exemption). In addition tothe hour requirements, the PIC must accomplish 3 takeoffs and landings inthe 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 ofsafety during GALE L. STONER proposed operations. The Administrator has held that prior documented flight experience thatwas obtained in compliance with applicable regulations would ensure safe operations, stating as follows:
In Exemption No. 11062, the FAA required that priorto conducting operationsforthe purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14CFR 61.51(b), 25 hours oftotal time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilotwith a multi--rotor UAS. Priorto operations under Exemption No. 11062, the PIC mustalso have accumulated and logged a minimum of5 hours as a UAS pilot operatingthe same make and model of UAS to be used for operations underthe exemption. For clarification, the FAA considers these minimum hour requirementsto be inclusive ratherthan additive; i.e. 5 hours make and model time may be included in the 10 hours of multi--rotortime and the 10 hours may be included in thetotal 25 hours of UAS rotorcrafttime.
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 that at minimum, the flight--hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the petitioner's proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience--buildingflights can also be conducted underthe grantofexemption to accomplish the required flighttime. Duringtraining, proficiency, and experience building flights the PIC is required to operate the UAS with appropriate distances in accordance with 14C.F.R 91.119. Exemption No. 11138 at page 16. Accordingly, GALE L. STONER will ensure safe operations by notallowing any PIC to operate OJI UAS Aircraft unless that PIC has demonstrated, by meeting minimum flight--hour and currency requirements, thatthe PIC is able to safely operate the DJI UAS Aircraft in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

17Reasons Whyan Exemptionfrom The Requirements ofSection 91.7(a) Would NotAdversely Affect Safety.
The equivalent level ofsafety established by Section 91.7(a) will be maintained because prior to every flight, GALE 

### L. STONER will ensure that OJI UAS Aircraft 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, tothose presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110,11112,11136, 11138,11150,11153,11156,11157,11158,11159,11160,11161).
Reasons Whyan Exemptionfrom The Requirements ofSection 91.121 Would NotAdversely Affect Safety.
The equivalent level ofsafety established by Section 91.121 will be maintained because the altitude information ofthe OJI UAS Aircraftwill be provided tothe PIC via GPS equipment and a radio communicationstelemetry data link, which downlinksfrom the UA to the GCS for active monitoring ofthe flight path and altitude. This altitude information, combined with GALE 

### L. STONER operation ofthe OJI UAS Aircraftwithin visual line ofsight, at or below 400 feetAGL, will ensure a level ofsafety equivalentto Section 91.121. The altitude information will be generated byGPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automaticallyestablished bythe UASs atground level.
The FAA has previously granted relieffrom Section 91.121 specific to UAS, in circumstances similar, in all material respects, tothose 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).
Reasons Why an ExemptionfromThe Requirements ofSection 91.151(b) Would NotAdversely Affect Safety.
A grant ofthis exemption would ensure an equivalent level ofsafety established by 14 C.F.R. Section 91.151(b) as a result of(1} the technical specifications ofthe OJI UAS Aircraft; (2) the limitations on the proposed flight operations; and (3) the location ofthe proposed flight operations. Accordingly, GALE 

### L. STONER will ensure that itwill safely operate the battery powered OJI UAS Aircraft during daylight hours in VFR conditions, with enough battery power toflyfor a total duration of 15 minutestothe first point ofintended landing and, assuming normal cruising speed, to fly afterthatfor at least 5 minutes.

18Here, as in Exemption No. 11109, thetechnical specifications ofthe OJI UAS Aircraft UASs; 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, safetywill be ensured as the DJI UAS Aircraft provide audible and visual warnings tothe PIC atthe 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. Atthe critically low battery level, the OJI Phantom Vision+ and OJI Phantom 3UASs will descend and land automatically. Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is notadversely affected when thetechnical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned aircraftto operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relieffrom Section 91.151 specific to UAS, in circumstances similar, in all material respects, tothose presented herein (e.g. Exemption Nos. 8811, 10808, 10673,11042,11062,11063,11064,11065,11066,11067,11080,11109,11110,11136,11138,11150, 11153,11156,11157,11158,11159,11160,11161).
Reasons Whyan Exemptionfrom The Requirements ofSections 91.405(a),**91.407(a)(1)~** 91.409(a)(1) 

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

### & (b) Would NotAdversely Affect Safety.
In seeking this exemption, GALE L. STONER submitsthatthe equivalent level ofsafety with regard tothe regulatory maintenance and alteration requirements established bySections 91.405(a), 91.407(a)(1), 91.409(a)(1) 

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

### &(b) will be met because GALE L. STONER will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., the GALE L. STONER Aerial Operations Manual, Monthly Maintenance Log, and DJI UAS Aircraft Instruction Manual). Furthermore, GALE L. STONER will document and maintain all maintenance records for the DJI UAS Aircraft UASs.
Since the OJI UAS Aircraft will be inspected as prescribed bythe operating documents, GALE L. STONER will maintain the equivalent level ofsafety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy ofthe OJI UAS Aircraft User Manuals are attached hereto as Appendix A and B; a copy ofthe OJI UAS Aircraft Maintenance LOG is attached heretoas Appendix C.

19Likewise, the exemption sought will not adversely affect safety because GALE L. STONER will use trained technicians to perform maintenance, 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 ofsafety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance ofthe DJI UAS Aircraft 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)(1), 91.409(a)(1) 

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

### &(b) establish that safety is not adversely affected when the technical characteristics and operating limitations ofthe UAS are considered.
In consideration ofGALE L. STONER proposed operating limitations, the operating documents, and the technical aspects ofthe OJI UAS Aircraft, GALE L. STONER 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 presented herein (e.g. Exemption Nos. 11062, 11063,11064,11065,11066,11067,11080,11109,11110,11112,11136, 11138,11150,11153,11156,11157,11158,11159,11160,11161).
The FAA May Prescribe Any OtherConditions for Safe Operation.
In accordance with Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, GALE L. STONER requests thatthe FAA prescribe special conditions for the intended operation ofthe DJI UAS Aircraft UASs, which contain such safety standards thatthe Administrator finds necessary to establish a level of safety equivalentto 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 ofthe UAs for the limited purpose ofconducting aerial video and photography over certain areas ofthe United States for compensation or hire. 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 authorityfor such UAS to operate without airworthiness certification in accordance with any requirements that must be established forthe safe operation ofthe UAS in the NAS. Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. §21.16, for operation ofthe OJI UAS Aircraft UASs, 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:



### 20Ifthe FAA finds thatthe 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, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 ofthis chapter and contain such safety standards forthe aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level ofsafety 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 ofthe OJI UAS Aircraft, which contain such safety standards thatthe Administratorfinds necessary to establish a level ofsafety 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 SummaryThat Can Be Published in The Federal Register, stating: The Rules from Which GALE L. STONER Seeks Exemption:
GALE l. STONER 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).


### A Brief Description ofthe Nature ofthe Exemption GALE L. STONER Seeks: This exemption will permit GALE l. STONER to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas ofthe United States. 

### Any Additional Information, Views, Or Arguments Available to Support GALE L. STONER Request.
This Petition is made pursuant tothe FAA Modernization and Reform Act of2012 {FMRA) Section 333, which directthe Secretary ofTransportation to determine ifcertain UAS may operate safely in the NAS. As such, GALE l. STONER 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 ofthe NAS orthe public, or otherwise pose a threatto national security; and further, provides the authorityfor such UAS to operate without airworthiness certification.

21As discussed in detail above, GALE 

### L. STONER will operate DJI UAS aircraft safely in the NAS, without creating a hazard to users ofthe NAS, orthe public, or otherwise pose a threatto national security. 

### CONCLUSION
As set forth herein, GALE 

### L. STONER seeks an exemption pursuant to 14C.F.R. § 11.61 and Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA), which will permit safe operation ofthe OJI UAS Aircraft commercially, without an airworthiness certificate, forthe limited purpose ofconducting aerial video and photography over certain areas ofthe United States. By grantingthis Petition, the FAA Administrator will be fulfilling the Congressional mandate ofthe FAA Modernization and Reform Act of2012, while also advancingthe interests ofthe public, by allowing GALE 

### L. STONER to safely, efficiently, and economically operate the DJI UAS Aircraft commercially within the NAS. WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of2012, Section 333, GALE 

### L. STONER respectfully requests thatthe Administrator grantthis Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) 

### & (b), 91.7(a), 91.121, 91.151(b), 91.40S(a), 91.407(a)(1), 91.409(a)(1) 

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

### & (b), and permit Leading Edge to operate the DJI UAS Aircraft commercially for the purpose ofconducting aerial video and photography over certain areas ofthe United States.

Gale Stoner



### 22 Very respectfully,


### GALE 

### L. STONER 744 STONETRACE DRIVE MURFREESBORO, TN 37128 615-473-7674

## 7-8-/~ Date

### DJI Phantom 3 Manual http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professionai_User_Manu al_vl.O_e n.pdf 

## Gilnbal
Model ZENMUSEX3 

## OutputPower (With Camera) Static: 9 W In Motion: 11 W 

## OperatingCurrent Station: 750 rnA 

### Motion: 900 rnA 

## AngularVibration Range ±0.03° 

## Mounting Detachable 

## ControllableRange Pitch: -90° to +30° Pan: ±320° 

## Mechanical Range Pitch: -125° to +45° Pan: ±330° 

## MaxControllable Speed Pitch: 120°/sPan: 180°/s 

## Camera Name X3 

## Model FC350 

## TotalPixels 12.76M 

## Effective Pixels l2.4M 

## Image Max Size 4000x3000 

## lso Range 100-3200 (video) 100-1600 (photo) 

## Electronic Shutter Speed 8s

- l/8000s 

## Fov (Field OfView) 94° 

## Cmos 23

### Sony EXMOR 1/2.3" 

### Lens 20mm (35mm format equivalent)f/2.8 focus at oo 

### 9 Elements in 9 groups Anti-distortion 

### Still Photography Modes Single shoot-burst shooting: 3/5/7 frames Auto Exposure Bracketing (AEB): 3/5 bracketed frames Time-lapse 

### Video Recording Modes UHD ( 4K): 4096x2160p24/25, 3840x2160p24/25/30FHD: 1920xI080p24/25/30/48/50/60HD: l280x720p24/25/30/48/50/60 

### Max Bitrate OfVideo Storage 60 Mbps 

### Supported File Formats FAT32/exFAT Photo: JPEG, DNG Video: MP4/MOV (MPEG-4AVC/H.264) 

### Supported Sd Card Types Micro SD Max capacity: 64GB. Class 10 or UHS-1 rating required. 

### Operating Temperature Range 0° to 40° C 

## Remote Controller Cl Operating Frequency 922.7-927.7 MHz (Japan Only)5.725-5.825 GHz 2.400,..,2.483 GHz 

### Transmitting Distance (Outdoor And Unobstruct) 2km 

### Eirp 10dBm@900m, 13dBm®5.8G, 20dBm@2.4G 

### Video Output Port USB, mini-HDMI 

### Power Supply Built-in battery 

### Charging DJI charger 

### Dual User Capability Host-and-Slave connection 

### Mobile Device Holder Tablet or Phone 

### Max Mobile Device Width 170mm 

### Output Power 9W 

### Operating Temperature Range -10° to 40° C 

### Storage Temperature Range 24

### Less than 3 months: -20° to 45° C More than 3 months: 22° to 28° C 

## Charging Temperature Range 0-40°

# c Battery 6000 mAh LiPo 2S 

## Charger Model Al4-IOOPIA 

## Voltage 26.3 

# v Rated Power IOOW 

## Battery (Standard) Intelligent Flight Battery Model TB47 

## Capacity 4500mAh 

## Voltage 22.2

# v BatteryType LiPo 6S High voltage battery 

## Energy 99.9Wh 

## NetWeight 570 g 

## OperatingTemperatureRange -10° to 40° C 

## StorageTemperatureRange Less than 

## 3 months: -20° to 45° 

## C More than 

## 3 months: 22° 

## C to 28° 

## C ChargingTemperatureRange 0° to 40° 

## C MaxChargingPower 180W 

## Battery (Optional) Intelligent Flight Battery Model TB48 

## Capacity 5700 mAh 

## Voltage 25

### 22.8 

# v Battery Type LiPo 6S 

### Energy 129.96 Wh 

### Net Weight 670 g 

### Operating Temperature Range -10° to 40° C 

### Storage Temperature Range Less than 3 months: -20 to 45° C More than 3 months: 22° to 28° C 

### Charging Temperature Range 

# oo to 40° C 

### Max Charging Power 180 

# w Vision Positioning Below 8 m/s (2 m above ground) Altitude Range 5-500 em 

### Operating Environment Brightly lit (lux> 15) patterned surfaces 

### Operating Range 0-250 em 

## DJI Pilot App Mobile Device System Requirements lOS 8.0 or later Android 4.1.2 or later 

### Supported Mobile Devices • Compatible with iPhone 5s, iPhone 6, iPhone 6 Plus, mini 3, and iPad mini 3 WiFi +Cellular.This app is opt • Samsung S5, Note 3, Sony Xperia Z3, Google Nexus *Support for additional Android devices available as test

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# Phantom 3 Professional

The Phantom 3 Professional's flight controllerfeatures severalimportantupgrades, including a newflight mode. Safetymodes include Failsafe andReturn-to-Home. These features ensure the safe return of youraircraftifthe controlsignalis lost. The flight controllercan also save critical flight data from each flight to the on-boardstorage device. The new flight controlleralsoprovides increasedstabilityanda newair-braking feature. GENERAL FEATURES

• EpicAerial Video • Live HD View • Complete Control • Powerful MobileApp • Vision Positioning • Easy to Fly • Worry-free Autopilot • Intelligent Battery • SupportsAdobe DNG RAW • Unmatched Propulsion • SDK Development VISION POSITIONING
• MaxVelocity: Less than 8 m/s (when 2 m above ground) • Altitude Range: 30 cm-300 em • Operating Range: 30 cm-300 cm<ltd><ltr> • Transmitter Power: CE: 25mw; FCC: 1OOmw • Operating Environment: Surface with clear pattern and adequate lighting (lux > 15) CAMERA • Sensor: Sony EXMOR 1/2.3" Effective pixels: 12.4 M (total pixels: 12.76 M) • Lens: FOV 94° 20 mm (35 mm format equivalent) f/2.8, focus at oo 

### • ISO Range: 100-3200 (video) 100-1600 (photo) • Max Bitrate OfVideo Storage: 60 Mbps • Operating Temperature:

# ooc to 40°C REMOTE CONTROLLER
• Operating Frequency: 2.400 GHz-2.483 GHz
• Max Distance: 2000m (outdoors and unobstructed)
• Receiver Sensitivity (1 %PER): -101 dBm ±2 dBm
• Transmitter Power (EIRP): FCC: 20 dBm CE: 16 dBm • Working Voltage: 1.2 A @7.4 V

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# .. 

# • •

DJI VISION APP

• EIRP: 1OOmW • Live View Working Frequency: 2.4GHz ISM • Live View Quality: 720P@ 30fps (depending on conditions and mobile device) • Required Operating Systems: lOS 8.0 or later, Android 4.1.2 or later • Recommended Devices: lOS: iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad AirWi-Fi 

### + Cellular, iPad mini 2, iPad mini 2 Wi-Fi 

### + Cellular, iPad Air2, iPad Air2 Wi-Fi 

### + Cellular, iPad mini 3, and iPad mini 3 Wi-Fi 

### + Cellular. This app is optimized for iPhone 5s, iPhone 6, and iPhone 6 Plus Android: Samsung S5, Note 3, Sony Xperia Z3, Google Nexus 7 II, Google Nexus 9, Mi 3, Nubia Z7 mini



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