UNITED STATES OF AMERICA DEPARTMENT OF

TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC Regulatory Docket No. **IN THE MATTER OF THE PETITION FOR EXEMPTION OF: Sky Media NV LLC**  **FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF**  **FEDERAL REGULATIONS SECTIONS 61.101(e)(4) & (5), 61.113(a) & (b), 61.23(a), 61.315(a), 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 OF DJI INSPIRE 1 UNMANNED AIRCRAFT SYSTEMS**  **PURSUANT TO SECTION 333 OF**  **THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112** 

**- 95)** 

Subm itted on July 20, 2015 Paul C Tronier Sky Media NV LLC 336 Om ni dr Sparks, NV 89441 Tel: (775) 772

- 1413 Em ail: Skym edianv@yahoo.com

**TABLE OF CONTENTS**

Page GLOSSARY OF ABBREVIATIONS ..................................................................................3

SUMMARY

..................................................................................................................... ..... 4 INTRODUCTION AND INTERESTS OF PETITI ONER....................................................4BACKGROUND........................................................................................ ............................4 BASIS FOR PETITION..................................................

................................................. ..... 5 NAME AND ADDRESS OF PETITIONER. ........................................................... 7 THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH SKY MEDIA NV LLC SEEKS EXEMPTION ........................

.......................... 8 THE EXTENT OF RELIEF SKY MEDIA NV LLC SEEKS AND THE REASON SKY MEDIA NV LLC SEEKS THE RELIEF............... . 11 THE REASONS WHY GRANTING SKY MEDIA NV LLC’S REQUEST WOULD BE IN THE PUBLIC INTEREST

............................ ......... 15 THE REASONS WHY GRANTING THE EXEMPTION WOULD

NOT ADVERSELY AFFECT SAFETY ......................................................................... 19 SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL

REGISTER. .... 34 ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT SKY MEDIA NV LLC’S REQUEST....

..................................................................................................................... ......... 34 CONCLUSION

......................................... ............................................................................ ....... 35 APPENDICES........................................................................................372

AGL AOI ATC ATO AV CFR COA FAA FAR GCS

GPS LOL NAS NOTAM PIC Se ction 333 SO SOP UA UAS VFR VLOS VMC VTOL **GLOSSARY OF ABBREVIATIONS** Above Ground Level Area of Interest Air Traffic Control Air Traffic

Organization Aerial Vehicle Code of Federal Regulations Certificate of Authorization Federal Aviation Administration Federal Aviation Regulation Ground Control Station Global Positioning System Loss of Link National Airspace System Notice to Airman Pilot In Command FAA Modernization and Reform Act of 2012 (FMRA) Section 333 Safety Observer Standard Operating Procedures Unm anned Aircraft Unm anned Aircraft System Visual Flight Rules Visual Line of Site Visual Meteorological Conditions

Vertical Takeoff and Landing

3 **SUMMARY** PAUL C. TRONIER seeks exem ption from the requirements of 14 C.F.R §§ 61.101(e)(4) and (5), 61.315(a), 61.23(a), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMR A). This exem ption will permit Sky Media NV LLC to operate an Unmanned Aircraft System (UAS) for the co mmercial purpose of conducting aerial video and photography of construction sites, building inspections,agricultural lands, wineries, outdoor recreation al facilities, real estate,

special events, and landscapes within the United States. **INTRODUCTION AND INTERESTS OF THE PETITIONER** Sky media NV LLC will provide its clients with the highest quality digital content for use in their commercial, personal, an d non

- profit multimedia projects. Sky Media NV LLC will bring together years of professional m arketing expertise, award

- winning production talent and state

- of

- the

- art technology to make studio quality productions within reach for organizations of any size. Sky Media NV LLC will also leverage years of professional Private Pilot experience a nd aerial knowledge to become a leading provider of geom apping and image analysis services to the civil engineering and environmental monitoring industries. Sky media NV LLC has over 10 years of recreational/hobby aircraft, rotorcraft and m

ulti rotorcraft experience and over 1 year in all aspects of aerial video and photography. The objective of Sky Media NV LLC i s to provide aerial video and photography operations in hig h quality imaging for a variety of commercial, public, and residential uses, specifically targeting:

•

• Aerial event filming and photography

• Promotional videos for businesses, non

- profits & government entities

• Local Search and Rescue missions

• Agricultural surveys and environmental monitoring

• Civil engineering inspection and documentation
4**BACKGROUND**

Unm anned Aircraft Systems: DJI Inspire 1 UAS Sky Media NV LLC

seeks an exemption to operate DJI sys tems for

com pensation or hire within the NAS. The DJI Inspire 1 (Inspire 1) is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The Inspire 1 is an electri c powered rotary wing UAS that is capable of transmitting live airborne video images and location inform ation to a Ground Control Station (GCS). The Inspire stores the photographs and data on board and makes them available for download after completion of the flight. The Inspire is 22 in x 22 in x 8 in and weighs 6.4 pounds, well under the 55 lbs mandated in the FMRA. The Inspire can conduct hovering flight and has a maxim um cruising speed of 42 knots. It is battery powered, has a flight endurance of 1 5

- 22 minutes and can operate in temperatures ranging from 0° to 40° C. The Inspire’s omni

- directional antenna has a range of 2.1 km and operates in

the 2.420

– 2.483 GHz frequency range. The Inspire 1 that will be operated by Sky Media NV LLC will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft , as well as 14 C.F.R Part 47, Aircraft Registration , and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking

. **BASIS FOR PETITION** Petitioner, Sky Media NV LLC, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unm anned Aircraft Systems , hereby petitions the Administrator to commercially operate the DJI Inspire 1 in the National Airspace Syste m (NAS), and for an exem ption from the requirements of 14 C.F.R §§ 561.101(e)(4) and (5), 61.315(a), 61.23(a), 91.7(a), 91 .121, 91.151(b),

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, Sky Media’s operation of the DJI Inspire 1 UAS 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, Sky Media NV LLC requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to

aircraft with an airworthiness certificate. Sky Media NV LLC subm its that the requested relief is proper since an equivalent level of safety will b e ensured. Sky Media NV LLC will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenan ce Log, and DJI Inspire 1 Instruction Manual). Furthermore, Sky Media NV LLC will document and maintain all
ma intenance records for the DJI Inspire 1 UAS. Relief from certain requirements of Section 61.101(e)(4) and (5) entitled Recreational pilot privile ges and limitations: Pilot in command , and from Section 61.315(a) entitled What are the privileges and limits of my sport pilot certificate , and from Section 61.23(a) entitled Medical certificates: Requirements and duration , is requested by Sky Media NV LL C to the extent necessary to allow a Pilot in Command (PIC) holding a sport pilot or higher level certificate, as well as a valid driver’s license, and who has dem onstrated, by meeting minimu m flight

- hour and currency requirements, that the PIC is able to safely operate the DJI

Inspire 1 UAS in a manner consistent with this

6

exem ption, including evasive and emergency maneuvers andma intaining appropriate distances from people, vessels, vehicles and structures. Sky Media NV LLC seeks relief from 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.F.R. Part 21, Subpart H. As such, Sky Media NV LLC submits that it will ensure that the DJI Inspire 1 UAS are in an airworthy condition, prior to every flight, by determining that the UASs are in compliance with the operating docum ents (i.e., Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual), and that the aircraft are in a condition for safe flight. Sky Media NV LLC also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , as the DJI Inspire 1 UA will not have a typical barometric altimeter onboard. However, altitude inform ation of the DJI Inspire 1 UA will be prov ided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude inform ation, com bined with Sky Media LLC’s operation of the DJI Inspire 1 UAS within visual line of sight (VLOS), at or below 400 feet AGL, will ensure a level of safety

equivalent to Section 91.121. Additionally, Sky Media NV LLC seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions . Sky Media NV LLC submits that safety will not be affected by operation of the DJI Inspire 1 UA during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough batt ery power to fly for a total duration of approxim ately 13.5 m inutes to the first point of intended landing and, assum ing normal cruising speed, to fly after that for at least 4.5 minutes. 7 In accordance with 14 C.F.R. § 11.81, Sky Media NV LLC provides thefollowing inform ation in support of its petition for exemption: **A. Nam**  **e And Address Of The Petitioner.** The nam e and address of the Petitioner and point of contact is: Paul Tronier Sky Media NV LLC 7336 om ni dr Sparks, NV 89441 Tel: (775) 772

- 1413 Em ail: Skym edianv@yahoo.com **B. The Specific Sections Of 14 C.F.R. From Which Sky Media NV**

**LLC Seeks Exemption. 1. Sky Media NV LLC Seeks Exemption From The Requirements** 

**Of Section 61.101(e)(4) and (5).** Section 61.101, entitled Recreational pilot privilege s and limitations: Pilot in command , subsection (e)(4) and (5) prescribe the following, in relevant part: (e) Except as provided in paragraphs (d) and (i) of this section, a recreational pilot may not act as pilot in command of an aircraft

-- (4) For comp ensation or hire; (5) In furtherance of a business; **2. Sky Media NV LLC Seeks Exemption From The Requirements**

**Of Section 61.23(a).** Section 61.23(a), entitled Operations requiring a medical certificate: Requirements and duration , subsection (a) prescribe the following, in relevant part: (f) Except as provided in paragraphs (d) and (i) of this section, a recreational pilot may not act as pilot in command of an aircraft

-- 8 **3. Sky Media NV LLC Seeks Exemption From The Requirements**

**Of Section 61.315(a).** Section 61.315(a), entitled What are the privileges and limits of my sportpilot certificate , subsection (a) prescribe the following, in relevant part:

(c) You may not act as pilot in command of a light

- sport aircraft:

(2) For compensation or hire. (3) I n furtherance of a business.

-- **4.Sky Media NV LLC Seeks Exemption From The Requirements Of Section 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. **5. Sky Media NV LLC Exemption From The Requirements Of Section 91.121.**  Section 91.121, entitled Altimeter settings, subsection (a), states the

following, in part: (a) Each person operating an aircraft shall maintain the cruis ing altitude or flight level of that aircraft, as the case may be, by reference to an

altimeter that is set, when operating

-- (1) Below 18,000 feet MSL, to

-- (i) The current reported altimeter setting of a station along the route and

within 100 nautical miles of the aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate

available station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure. 9**6. Sky Media NV LLC Exemption From The Requirements Of Section 91.151(b).**  Section 91.151 , entitled Fuel requirements for flight in VFR conditions ,

subsection (b), states the following: (b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather 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. **7. Sky Media NV LLC Exemption From The Requirement Of**

**Section 91.405(a).** Section 91.405, entitled Maintenance required , subsection (a), s tates the following: Each owner or operator of an aircraft

— (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies rep aired as prescribed

in part 43 of this chapter[.] **8. Sky Media NV LLC From The Requirements Of Section 91.407(a)(1)**  Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration , subsection (a)(1), states the fol lowing: (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

-- (1) It has been approved for return to service by a person authorized

under § 43.7 of this chapter[.] **9. Sky Media NV LLC Seeks Exemption From The Requirements** 

**Of Sections 91.409(a)(1) and 91.409(a)(2).**Section 91.409, entitled Inspections , subsection (a), states the following:

(a) Except as provided in paragraph (c) of this 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 43 of this chapter and has been approved for return to service by a person authorized by § 43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance 10 with part 21 of this chapter. **10. Sky Media NV LLC 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) of this section: (1) Records of the maintenan ce, preventive maintenance, and alteration and records of the 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 of an aircr aft.

The records must include

-- (i) A description (or reference to data acceptable to the Administrator) of

the work performed; and (ii) The date of completion of the work performed; and(iii) The signature, and certificate number of the person approvin g the aircraft for return to service. (2) Records containing the following inform ation: (i) The total ti me in service of the airframe, each engine, each propeller, and each rotor. (ii) The current status of life

- lim ited parts of each airframe, engine,

propeller, rotor, and appliance. (iii) The ti me since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the time since the la st inspection required by the inspection program under which the

aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive num

ber and revision date. If the AD or safety directive involves recurring action, the time and date when the next

action is required. (vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each 11

ma jor 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) of this section shall be retained until t he 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) of this section shall beretained and transferred with the aircraft at the time the aircraft is sold.

(3) A list of d efects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and

the aircraft is approved for return to service. **C. The Extent Of Relief Sky Media NV LLC Seeks And The Reason**

**Sky Media N V LLC Seeks The Relief.**  **1. Extent Of Relief Sky Media NV LLC Seeks And The Reason Sky Media NV LLC Seeks Relief From Section 61.113(a) and (b).**  Relief from 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 com pensation or hire. This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for co mp ensation or hire, act as PIC of an aircraft in connection with any business or emplo ym ent 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. As set forth more fully below, Feather Light Media LLC subm its that an equivalent level of sa fety will be maintained because no PIC will be allowed to

operate the DJI Inspire 1 UAS UA unless that PIC has met certain flight

- hour and currency requirements, 12 dem onstrating that the PIC is able to safely operate either the DJI Inspire1 UAS in a m anner consistent with the operations specifications as

described in this exem

ption, including evasive and emergency
ma neuvers, as well as maintaining appropriate distances from people,

vessels, vehicles and structures. Further, Sky Media NV LLC submits th at all flights of the DJI Inspire 1 UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to Sky Media NV LLC business; and (2) will not carry passengers or property for compensation or hire. **2. Extent Of Relief Sky Med ia NV LLC Seeks And The Reason Sky**  **Media NV LLC Seeks Relief From Section 61.23(a).** Relief from Section 61.23(a), entitled Operations requiring a medical certificate: Requirements and duration, is requested to the extent required to necessary to allow a P IC holding a sport pilot certificate or higher level certificate, as well as a current and valid driver’s license, to conduct the proposed UAS flight operations for com pensation or hire. This relief is requested since the limitations set forth in Section 61.23(a) otherwise require the PIC of any flight for com pensation or hire to hold a comprehensive FAA issued medical certificate. In Exemption No. 11213 to Aeryon Labs, Inc., the FAA “finds that, because of the risk mi tigations established in the condition s and lim itations of this exem ption, a person that holds a U.S. issued driver’s license who is operating a UAS will not adversely affect safety. The FAA is granting relief from § 61.23(a) to allow any pilot that holds one of the pilot’s certificates discus sed above to operate a UAS under this exemption with a U.S. issued driver’s license, in lieu of an FAA

- issued medical certificate. The FAA is also granting relief from § 61.23(c) to allow sport pilot certificate holders to operate aircraft other than LSA w ith a U.S. issued driver’s license under this exemption.”

13 **3. Extent Of Relief Sky Media NV LLC Seeks And The Reason Sky Media NV LLC Seeks Relief From Section 61.315(a).** 

Relief from Section 61.315(a) entitled What are the privileges and limits of my sport pilot certificate , is requested to the extent necessary to allow a PIC holding a sport pilot or higher level certificate to conduct the proposed UAS flight operations for com pensation or hire. This relief is requested since the limitations set forth in Section 61.315(a) restrict a sport pilot from acting as the PIC of any flight for com pensation or hire, or for the furtherance of any business. In Exemption No. 11213 to Aeryon Labs, Inc., the FAA re

- assessed the level of pilot certificate that would be appropriate for the petitioner’s operations. In evaluating this petition, similar to the evaluation of the private and commercial pilot certificates in Exemption No. 11062, the agency compared the aeronautical knowledge requirements of the recreational and sport pilot certificates to those of the private pilot certificate. They found that the aeronautical knowledge requirements that would be applicable to a UAS operation for a recreational pilot and sport pilot certificate are substantially similar as th ose for a private pilot certificate. Additionally, similar to the private and commercial pilot certificates, holders of recreational and sport pilot certificates are subject to security screening by the Department of Ho meland Security (DHS). Therefore, b ecause they must demonstrate aeronautical knowledge relevant to UAS operations and are subject to DHS screening, factors that were considered by the FAA in allowing private pilot operations under previous exemptions, the FAA now determines that holders of recreational and sport pilot certificates may serve as the PIC for UAS operations. 14 **4. Extent Of Relief Sky Media NV L**  **LC Seeks And The Sky Media**

**NV LLC Seeks Relief From Section 91.7(a).**Relief from Section 91.7(a) entitled Civil aircraft a irworthiness , is

requested to the extent required to allow Feather Light Media LLC to determine that the DJI Inspire 1 UAS are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating docum ents (i.e., the DJ I Inspire 1 Maintenance Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). Sky Media NV LLC seeks the requested relief because the DJI Inspire 1 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Sub part H. Therefore, Sky Media NV LLC will ensure that the DJI Inspire 1 UAS are in airworthy condition based upon its com pliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual) prior to every flight, and fu rther, determine that the aircraft are in condition for safe flight, as

stated in the conditions and lim itations below. **5. Extent Of Relief Sky Media NV LLC Seeks And The Reason Sky Media NV LLC Seeks Relief From Section 91.121.**  Relief from Section 91.12 1, entitled Altimeter settings, may be required to allow flight operations of the DJI Inspire 1 UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to t he 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), Sky Media NV LLC seeks the requested relief because the DJ I Inspire 1 UA’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight. 15 Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to co mply with the applicable conditions and limitations stated below. As more fully setforth herein, an equivalent level of safety wi ll be maintained since the

DJI Inspire 1 UA (s) are equipped with a barometric pressure sensor and GPS equipment, which autom atically ensures that a ground level pressure setting will be established prior to each flight, and provides the PIC with altitude inform ation of the UA on the heads

- up display of the GCS. **6. Extent Of Relief Sky Media NV LLC Seeks And The Sky Media**

**NV LLC Relief From Section 91.151(b).** Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is request ed to the extent required to allow flights of the battery powered DJI Inspire 1 UA (s) during daylight hours in visual me teorological conditions (VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to the first point of intended lan ding and, assum ing normal cruising speed, to fly after that for at least 4.5 minutes. Sky Media NV LLC seeks the requested relief because without an exem ption from Section 91.151(b), the flight time duration of the battery powered DJI Inspire 1 UA will sev erely constrain the practicality of any aerial video or still photo flight operations that Sky Media NV proposes

to conduct pursuant to this Petition. Significantly, as set forth below, the technical specifications of the DJI Inspire 1 UAS, the DJI Inspir e 1 operating docum ents, and Sky Media NV LLC’s proposed operating limitations, ensure that Sky Media NV LLC will safely operate the battery powered DJI Inspire 1 UA (s) during daylight hours in visual meteorological conditions (VMC), under visual flight r ules (VFR), with enough battery power to fly for a total duration of 13.5 m inutes to the first point of intended landing and, assuming norm al cruising speed, to fly after that for at least 4.5 minutes. 16 **7. Extent Of Relief Sky Media NV LLC Seeks And T he Reason Sky**  **Media NV LLC Seeks Relief From Sections 91.405(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 cer tificate, Sky Media NV LLC requests relief from these Sections because the DJI Inspire 1 UAS does not

require airworthiness certificates. As set forth m ore fully below, the DJI Inspire 1 UAS meets the conditions of FMRA Section 333 for operation without an airworthiness certificate.

Accordingly, Sky Media NV LLC 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 DJI Inspire 1

Maintenance Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual).

Furthermore, Sky Media NV LLC will document and maintain all maintenance records for the DJI Inspire 1 UAS. **D. The Reasons Why Granting Sky Med ia NV LLC Request Would**  **Be In The Public Interest; That Is, How It Would Benefit The**

**Public As A Whole.** Granting the present Petition will further the public interest and safety by allowing Sky Media NV LLC to safely, efficiently, and econom icallyconduct aerial video and photography of construction sites, building

inspections, agricultural lands, wineries, outdoor recreational facilities, Assistance in Search and Rescue applications, real estate, special events, and landscapes over certain areas of the Un ited States. Additionally, use of the DJI Inspire 1 UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of Sky Media NV LLC’s proposed operation of the DJI Inspire 1 UAS will be realized without im plicating any privacy issues. 17 **1. The Public Will Benefit From Decreased Congestion Of The NAS.** The DJI Inspire 1 UAS are battery powered and serve as a safe, efficient, and econom ical alternative to the manned aircraft traditional ly utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJI Inspire 1 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollutio n, as well as increase the safety of life

and property in the air and on the ground. Furthermore, by reducing the num ber of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The DJI Inspire 1 UAS do not require an airport to takeoff or land. Likewise, a reduction of m anned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, de parture, arrival, and landing phases of flight operations. **2. The Public Will Benefit From The Safety And Efficiency Of The DJI Inspire 1 UAS.**  Conducting aerial acquisitions with the DJI Inspire 1 UAS, instead of ma nned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerialvideo and still photography flight operations. By using battery power

and electric motors, the DJI Inspire 1 UAS produce no air pollution, and is the most viable environm entally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically utilized for aerial video and photography, while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The DJI Inspire 1 UAS, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UASs are propelled by battery powered electric motors, rather than an internal co mb ustion engine.

18 By using the DJI Inspire 1 UAS to 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 com plete ly eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI Inspire 1 UAS (weighing approxim ately 6.5 pounds m axim um gross weights with a length of 17.3 inches, width of 17.7 inches, and with no fuel on board), has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct sim ilar operations (weighing approximately 6,000 pounds with a wingspan of approxim ately 42 feet, a length o f 34 feet, and a fuel

capacity of 180 gallons). **3. Performing Aerial Video and Photography Operations With The**

**DJI Inspire 1 UAS Will Benefit The Economy.** In addition to being safe and efficient, the DJI Inspire 1 is also an econom ical alternative to usi ng m anned aircraft to conduct similar aerial operations. As such, operation of the DJI Inspire 1 UAS will allow United States based com

panies, like Sky Media NV LLC, to remain com petitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated co mp anies must adopt new and alternativetechnology in order to remain competitive. Operating the ba ttery

powered DJI Inspire 1 UAS is one such technology that not only allows com panies greater operational flexibility co mp ared to manned aircraft, but provides such flexibility without the high operational cost of a

traditional manned aircraft. By operati ng the DJI Inspire 1 UAS, com panies such as Sky Media NV LLC, can remain competitive and profitable, and therefore, provide greater job stability to

em ployees and contractors, which will ultimately contribute to growth of the U.S. 19 economy. Im

proved financial performance of U.S. companies, through commercial use of the DJI Inspire 1 UAS, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and developm ent in order to remain com

petitive both in the United States and abroad. **4. There Are No Privacy Issues.** Similar to the manned aerial acquisition flight operations that have been conducted for decades, Sky Media NV LLC proposed operation of the DJI Inspi re 1 UAS will not im plicate any privacy issues. Specifically, the DJI Inspire 1 UAS will be operated only in compliance with the conditions set forth in any exem ption granted under this petition. **E. The Reasons Why Granting The Exemption Would Not Adverse**  **ly Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule**  **From Which Sky Media NV LLC Seeks Exemption. 1. Reasons Why The DJI Inspire 1 UA Meet The Conditions Of The**  **FAA Modernization and Reform Act of 2012 (FMRA) Section 333.** In consideration of the size, weight, speed, and limited operating area

associated with the unmanned aircraft and its operation, Sky Media NV LLC operation of the DJI Inspire 1 UAS meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section

333 states the following, in part: (a) In General.

-- Notwithstanding any other requirement of this subtitle, and not later than 180 days a fter the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of the plan and rule making required by section 332 of t his Act or the guidance required by section 334 of this Act. 20 (b) Assessment of Unmanned Aircraft Systems.

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

-- (1) which types of unmanned aircraft systems, i f any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a

threat to national security; and (2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems

identified under parag raph (1). (c) Requirements for Safe Operation.

-- If the Secretary determines underthis section that certain unmanned aircraft systems may operate safely

in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the

national airspace system. In seeking this exemption, Sky Media NV LLC submits that the DJI Inspire 1 UAS can operate safely in the NAS pursuant to FMRA Section 333, as dem onstrated by: (a) the characteristics of the DJI Inspir e 1 UAS; (b) the pilot certification requirement; and (c) the specific

operating limitations. **a. The Specifications Of The DJI Inspire 1 UAS Demonstrate Its**

**Safe Characteristics.** The DJI Inspire 1 UAS does not create a hazard to users of the NAS or the p ublic, or otherwise pose a threat to national security considering its

size, weight, speed, and operational capability. **i. Technical Specifications Of The DJI Inspire 1 UAS.** The technical specifications of the DJI Inspire 1 UAS is set forth by the DJI In spire 1 Specifications and Data Sheet, attached hereto as Exhibit A. **ii. The DJI Inspire 1 UAS Autonomous Flight And Navigation Modes Enable The UAS To Remain Within A Defined Operational**  **Area.** The DJI Inspire 1 UAS may be operated in both manual and fully

autonom ous flight modes. A complete description of the flight and navigational m odes of the DJI Inspire 1 21 UAS is provided in the DJI Inspire 1 User Manual, attached hereto as Exhibit B.**iii. The DJI Inspire 1 UAS Are Designed For Automatic Return To**

**Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation.**  When the Control Link is lost, the DJI Inspire 1 UA will remain stationary, in flight, for 3 seconds or more. If, a fter 3 seconds, the DJI Inspire 1 UA does not reacquire control link data from the GCS, the UA will assume that the Control Link is lost and the UA will return to the hom e position (i.e., failsafe mode) via GPS, and will descend to the

takeoff position and shutdown. A complete description of the Failsafe Functions of the DJI Inspire 1 UAS are set forth in the DJI Inspire 1 User Manual, attached hereto as B. **iv. The DJI Inspire 1 GCS And Its Operation.** A complete description of the operation and specifications of the DJI Inspire 1 GCS and flight control software is provided in the DJI Inspire 1 User Manual. DJI Inspire 1 User Manual is attached hereto as Exhibit B. **b. Flight Operations Of DJI Inspire 1 UAS Are Limited To The Line**  **Of Sight Of A Certificated Pilot in Command With A Safety Observer.**  Sky Media NV LLC will only utilize certificated pilots who possess a current and valid airman medical certificate to act as a pilot in command (PIC) of the DJI Inspire 1 UAS. Additionally, a safety observer will

assist all pilots during flight tim e. **c. Flights Of DJI Inspire 1 UAS Will Be Conducted Pursuant To**

**Specific Operating Limitations.** In seeking this exemption, proposes to commercially operate DJI Inspi re 1 UAS for the special purpose of conducting aerial video and photography over certain areas of United States, pursuant to the

following specific operating limitations:1. Operations authorized by this grant of exem ption will be limited to the following aircraft described in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: DJI Inspire 1

Unm anned Aircraft System.

22 Proposed operations of any other aircraft will require a new petition or a

petition to amend thi s grant. 2. UAS operations under this exem ption will be limited to conducting operations for the purpose of aerial video and photography. 3. The UAs may not be flown at an indicated airspeed exceeding 20 knots. 4. The UA m

ust be operated at an altitude of no m ore than 500 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved by ATC. All altitudes reported to ATC must be in feet AGL. 5. The UAs m

ust be operated wit hin visual line of sight (VLOS) of the PIC at all ti mes. This requires the PIC to be able to use hum an vision unaided by any device other than corrective lenses, as specified on the

PIC’s FAA

- issued airman medical certificate. 6. The use of first person v iew (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 ma intains VLOS capability. The SO and PIC must be able to co mmunicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the SO can perform the functions

prescribed in the operating docum ents.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 oper ate the camera or

other instruments. 9. The operating docum ents and the grant of exem ption m ust be accessible during UAS operations and made available to the Adm inistrator upon request. If a discrepancy exists between the conditions and limitations contai ned in the grant of exemption and the procedures outlined in the operating docum ents, the conditions and limitations contained in the grant of exem ption take precedence and must be followed. Otherwise, the operator m ust follow the procedures as outlined in its operating docum ents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised docum ents to the Adm inistrator upon request. The operator m ust also present upd ated and revised docum ents if it petitions for extension or amendment to the grant of exem ption. If the operator determines that any update or revision would affect the basis upon which the FAA granted the exem ption, then the operator m

ust petition for ame ndment to its grant of exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

10. Prior to each flight the PIC m ust inspect the UAS to ensure that it is in a

23 condition for safe flight. If the inspection reveals a condition that affects the safe operation of the 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 andalterations must be properly documented in the aircraft records.

11. Any UAS that has undergone m aintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, m ust undergo a functional test flight. The PIC who conducts the functional test flight m ust m ake an entry in the aircraft records.
12. The pre

- flight inspection must account fo r all potential discrepancies, e.g. inoperable com ponents, items, or equipm ent, not already covered in the relevant sections of the operating

docum ents.
13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, repla cem ent, inspection, and life limit requirements.
14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating docum ents. Maintenance, inspection, alterations, and status of replacement/o verhaul com ponent parts must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature of the authorized person returning

the UAS to service.
15. Each UASs operated under this exemption m ust c om ply with all
ma nufacturer Safety Bulletins.
16. The authorized person m ust m ake an entry in the aircraft record of the corrective action taken against discrepancies discovered

between inspections.
17. The PIC must possess at least a private pilot c ertificate and at least

a current third

- class medical certificate.18. The operator may not permit any PIC to operate unless the PIC

me ets the operator’s qualification criteria and dem onstrates the ability to safely operate the UAS in a manner consiste nt with how the UAS will be operated under the exem ption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours m

ust be logged in a manner consistent w ith 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator’s PICs are permitted under the terms of the exem ption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and expe rience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC m ust operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119.
19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 19.1. All operations must be conducted under visual meteorological 24 conditions (VMC). If flight at night is required, a special request will be ma de at the FAA office closest to proposed area of opera tions. Flights under special visual flight rules (SVFR) are not authorized. 20. The UA may not operate within 5 nautical miles of an airport reference point as denoted on a current FAA

- published aeronautical chart unless a letter of agreement with that a irport’s
ma nagement is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request.
21. The UA may no t be operated less than 500 feet below or less than2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.
22. If the UA loses communications or loses its GPS signal, it m us t return to a pre

- determined location within the planned operating area and land or be recovered in accordance with the operating

docum ents.
23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the o perating documents.
24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the

UA with 25% battery power re ma ining.
25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exem ption. This COA will also require the operator to request a Notice to A irman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential t ransponder

requirements.
26. All aircraft operated in accordance with the exemption must be identified by serial num

ber, registered in accordance with 14 C.F.R. part 47, and have identification (N

- Num ber) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be

as large as practicable.
27. Before conducting operations, the radi o frequency spectrum used for operation and control of the UA must com ply with the Federal Communications Commission (FCC) or other appropriategovernm ent oversight agency requirements.

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 mus t be available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents must be
ma de available to the Administrator or any law enforcement

official upon request.
25 29. The UA must remain clear and yield the ri ght of way to all manned

aviation operations and activities at all times.
30. The UAS may not be operated by the PIC from any moving device or vehicle.
31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (perso ns other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. T he operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or; b. The aircr aft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, and; c. Operations nearer to the PIC, SO, operator trainees 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

- accessproperty with permission from the land owner/controller or

authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted.
33. Any incident, accident, or flight operation th at transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents must be reported to the National Transportation Safety Boar d (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

. **2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety.**  Sky Media NV LLC subm its that the equivalent level of safety establ ished by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI Inspire 1 UAS unless that PIC has dem onstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI Inspire 1 UAS in a manner consistent with the exem ption, including evasive and em ergency maneuvers and

ma intaining appropriate distances from people, vessels, vehicles and structures. 26 Considering Sky Media NV LLC proposed area of operations, and the operating limitations set forth

- above; the parallel nature of sport pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI Inspire 1 UAS, Sky Media NV LLC subm its that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for Sky Media NV LLC specific proposed flightoperations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circu ms tances 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, 111 56, 11158, 11159, 11160, 11161). Sky Media NV LLC will not allow any PIC to operate the DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimu m flight

- hour requirements or the DJI Inspire 1 UAS training and currency requirements, that the P IC is able to safely operate the DJI Inspire 1 UAS in a manner consistent with this exem ption, including evasive and em ergency maneuvers and maintaining appropriate distances from

people, vessels, vehicles and structures. Specifically, the PIC must have a ccumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minim um of 5 hours of those hours as a UAS pilot operating the same make and model of UAS to be used for operations under the 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 Exem

ption Nos. 11062, 11138, and 11153, prior docum ented

flight 27 experience that was obtained in com pliance with applicable regulations will ensure an equivalent level of safety during Sky Media NV LLC proposed operations. The Ad ministrator has held that prior documented flight experience that was obtained in com pliance with applicable regulations wo uld ensure safe operations, stating as follows: In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of m otion picture filming (or similaroperations), the PIC must have accumulated and logged, in a manner

consisten t with 14 CFR 61.51(b), 25 hours of total tim e as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi

- rotor UAS. Prior to operations under Exemption No. 11062, the PIC m ust also have accumulated and logged a minimum of 5 h ours as a UAS pilot operating the same make and m odel of UAS to be used for operations under the exemption. For clarification, the FAA considers these minim

um hour requirements to be inclusive rather than additive; i.e. 5 hours make and m odel time may be i ncluded in the 10 hours of multi

- rotor time and the 10 hours m ay be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must acco mp lish 3 takeoffs and landings in the preceding 90 days (for currency purposes ). The FAA finds that at a 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 document ed flight experience that was obtained in com pliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience

- building flights can also be conducted under the grant of exem ption to accomplish the required flight tim e. During training, proficiency, and experience

- building flights the PIC is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15. Accordingly, Sky Media NV will

ensure safe opera tions by not allowing any PIC to operate the DJI Inspire 1 UAS unless that PIC has dem onstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI Inspire 1 UAS in a manner consistent with the exempti on, including evasive and emergency ma neuvers and maintaining appropriate distances from people, vessels,

vehicles and structures. **3. Reasons Why An Exemption From The Requirements Of Section**

**91.7(a) Would Not Adversely Affect Safety.**The equivalent leve l of safety established by Section 91.7(a) will be ma intained 28 because prior to every flight, Sky Media NV LLC will ensure that the DJI Inspire 1 UAS is in an airworthy condition based upon the UAS’ s com pliance with its operating documents and as stated in the conditions

and limitations herein. Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circu ms tances similar, in all material respects, to those presen ted 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). **4. Reasons Why An Exemption From The Requirements Of Section**

**91.121 Would Not Adve rsely Affect Safety.**  The equivalent level of safety established by Section 91.121 will be
ma intained because the altitude information of the DJI Inspire 1 UAS will be provided to the PIC via GPS equipm ent and a radio communications telemetry data link, wh ich downlinks from the UAS to the GCS for active monitoring of the flight path and altitude. This altitude inform ation, combined with Sky Media NV LLC’s operation of the DJI Inspire 1 UAS within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude inform ation will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is autom atically established by the UASs at ground level. The FAA has previously granted relief from Section 91.121 specific to UAS, in circu mstances similar, in all material respects, to those

presented herein (e.g. Exem ption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160,11161).

**5. Reasons Why An Exemption From The Requirements Of Section**

**91.151(b) Would Not Adversely Affect Safety.** A grant of this exemption would ensure an equivalent level of safety established by 29 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJI Inspire 1 UAs; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, Sky Media NV will ensure that it will s afely operate the battery powered DJI Inspire 1 UA during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming norm al cruising speed, to fly after that for at least 4.5 minutes. Here, as in Exemption No. 11109, the technical specifications of the DJI Inspire 1 UAS; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safety est ablished 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 low battery voltage, the first warning occurring at approximately 33% r em aining battery power, and again at approximately 10% remaining battery power. At the critically low battery level, the DJI Inspire 1 UAS will

descend and land autom atically. Significantly, previous exem ptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimu ms prescribed in Section 91.151, includin g Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA haspreviously granted relief from Section 91.151 specific to UAS, in

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 1106 2, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

30 **6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(**  **a) & (b)**

**Would Not Adversely Affect Safety.** In seeking this exemption, Sky Media NV LLC submits that the equivalent level of safety with regard to the regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91.4 09(a)(1) & (a)(2), and 91.417(a) & (b) will be met because Sky Media NV LLC will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating docu ments (i.e., the DJI Inspire 1 Maintenance Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, Sky Media Nv LLC will docum ent and maintain all maintenance records for the DJI Inspire 1 UAS. Since the DJI Inspire 1 UAS will be inspected as prescribed by the operating docum ents, Sky Media NV LLC will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI Inspire 1 User Manuals are attached hereto as Exhibit B; a copy of the DJI Inspire 1 Maintenance Manual is attached hereto as Exhibit C; a copy of the DJI Inspire 1 UAS Maintenance LOG is attached hereto as Exhibit D. Likewise, the exemption sought will not adversely affect safety because Sky Media NV LLC w ill use trained technicians to perform ma intenance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed by the operatingdocum ents.

Furthermore, the exem

ption sought would m aintain an equivalent level o f safety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI Inspire 1 UAS will be performed by

trained technicians. Maintenance will be docum ented and maintained utilizing the monthly maintenance log. 31 Signific antly, previous exem ptions 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 of the UAS ar e considered. In consideration of Sky Media NV LLC proposed operating limitations, the operating documents, and the technical aspects of the DJI Inspire 1 UAS, Sky Media NV LLC submits that safety will not be adversely affected by granting exem ption 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 F AA has previously granted relief specific to UAS in circu mstances similar, in all material respects, to those presented herein (e.g. Exem ption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 111 57, 11158, 11159, 11160, 11161). **7. The FAA May Prescribe Any Other Conditions For Safe Operation.**  In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Sky Media NV LLC r equests that the FAA prescribe special conditions for the intended operation of the DJI Inspire 1 UAS, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R.Pa rt 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121,

91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAs for the limited purpose of conducting aerial video and photography over certain areas of the United States for com pensation or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to nationa l security; and further, provides the 32 authority for such UAS to operate without airworthiness certification in accordance with any requirements that must be established for the safe

operation of the UAS in the NAS. Likewise, the Administrator may pre scribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of the 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 o f the aircraft. Section 21.16, entitled Special Conditions, states the following: If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and amendm ents thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain s uch safety standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent to

that established in the regulations. See 14 C.F.R. § 21.16. Therefore, in accordance with FMRA Section

333 and 14 C .F.R. § 21.16, the FAA

ma y prescribe special conditions for Leading Edge’s intended operation of the DJI Inspire 1 UAS, which contain such safety standards that theAdm inistrator finds necessary to establish a level of safety equivalent to that establishe d 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). **F. A Summary That Can Be Published In The Federal Register, stating: The Rules Fro**  **m Which Sky Media NV LLC Seeks**

**Exem ption:**  Sky Media NV LLC seeks exemption from the requirements of 14 C.F.R Sections 61.101(e)(4) and (5), 61.315(a), 61.23(a), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a )(2), and 91.417(a) & (b

). **A Brief Description Of The Nature Of The Exemption Sky Media NV LLC Seeks:**  This exemption will permit Sky Media NV LLC to commercially operate
an 33 Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States. **G. Any Additional Information, Views, Or Arguments Available To**

**Support Sky Media NV LLC Request.** This Petition is made pur suant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. As such, Sky Media NV LLC request for exemption may be granted pursuant to th e 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 aUAS will create a hazard to users of the NAS or the public, or otherwise

pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification. As discussed in detail above, Sky Media NV LLC will operate the DJI Inspire 1 UASs safely in the NAS, without creating a hazard to users of the NAS, or the pu blic, or otherwise pose a threat to national security. **CONCLUSION** As set forth herein, Sky Media NV LLC seeks an exemption pursuant to 14 C.F.R § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operati on of the DJI Inspire 1 UAS commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography over certain areas of the United States. By granting this Petition, the FAA Adm inistrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing Sky Media NV LLC to safely, efficiently, and econom ically operate the DJI Inspire 1 UAS 34 commercially within the NA S. **WHEREFORE** , in accordance with

the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, Sky Media NV LLC respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.101(e)(4) and (5), 61.315(a), 61.23(a), 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), and permit Sky Media NV LLC to operate the DJI Inspire 1 UAS commercially for the purpose of conduct ing aerial video and photography over areas of the United States. Dated: July 20, 2015Respectfully submitted, Paul T ronier

Paul C. Tronier Sky Media NV LLC 336 om ni dr Sparks, NV, 89441 Tel: (775) 772

- 1413 Em ail: skym edianv@yahoo.com 35 Exhibits:
A

– DJI Inspire 1 Specifications Data Sheet B

– DJI Inspire 1 Manufacturer’s User Manual C

– DJI Inspire 1 Maintenance Manual D

– Monthly Maintenance Log
EXHIBIT

– A DJI Inspire 1 Specifications Data Sheet 36 **DJI INSPIRE 1 TECHNICAL SPECIFICATIONS** 37 Aircraft
**Model** T600 **Weight (Battery Included)**

2935 g **Hovering Accuracy (GPS Mode)** Vertical: 0.5 m Horizontal: 2.5 m **Max Angular Velocity** Pitch: 300°/s Yaw: 150°/s **Max Tilt Angle** 35°

**Max Ascent Speed** 5 m/s**Max Descent Speed** 4 m/s **Max Speed** 22 m/s (ATTI mode, no wind) **Max Flight Altitude** 4500 m **Max Wind Speed Resistance**

10 m/s **Max Flight Time** Approximately 18 minutes
**Motor Model** DJI 3510 **Propeller Model** DJI 1345 **Indoor Hovering** Enabled by default **Operating Temperature Range**

- 10° to 40° C **Diagonal Distance** 559 to 581 mm
**Dimensions** 438x451x301 mm Gimbal
**Model**ZENMUSE X3 **Output Power (With Camera)** Static: 9 W In Motion: 11 W **Operating Current** Station: 750 mA Motion: 900 mA **Angular Vibration Range** ±0.03° **Mounting** Detachable **Controllable Range** Pitch:

- 90° to +30° 38
Pan: ±320° **Mechanical Range** Pitch:

- 125° to +45° Pan: ±330° **Max Controllable Speed** Pitch: 120°/s Pan: 180°/s Cam era
**Name** X3
**Model** FC350
**Total Pixels** 12.76M
**Effective Pixels** 12.4M **Image Max Size**4000x3000 **ISO Range** 100

- 3200 (video) 100

- 1600 (photo) **Electronic Shutter Speed** 8s

- 1/8000s **FOV (Field Of View)** 94°
**CMOS** Sony EXMOR 1/2.3”
**Lens** 20mm (35mm format equivalent)f/2.8 focus at ∞ 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 at 0.7EV Bias Time

- lapse **Video Recording Modes** UHD

(4K): 4096x2160p24/25, 3840x2160p24/25/30 FHD: 1920x1080p24/25/30/48/50/60 HD: 1280x7 20p24/25/30/48/50/60

**Max Bitrate Of Video Storage**

60 Mbps **Supported File Formats** FAT32/exFAT Photo: JPEG, DNG Video: MP4/MOV (MPEG

- 4 AVC/H.264) **Supported SD Card Types** Micro SD Max capacity: 64 GB. Class 10 or UHS

- 1 rating required. **Operating Temperature Range**  0° to 40° C

39 Rem ote Controller
**Name**C1 **Operating Frequency** 922.7~927.7 MHz (Japan Only) 5.725~5.825 GHz 2.400~2.483 GHz

**Transmitting Distance (Outdoor And Unobstructed)** 2 km
**EIRP** 10dBm@900m, 13dBm@5.8G, 20dBm@2.4G

**V ideo 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**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** A14

- 100P1A **Voltage** 26.3 V
**Rated Power** 100 W Battery (Standard)
**Name** Intelligent Flight Battery
**Model** TB47 **Capacity** 4500 mAh **Voltage** 22.2 V **Battery Type** LiPo 6S High voltage battery

**Energy** 4099.9 W h **Net Weight** 570 g **Operating Temperature Range**

- 10° to 40° C **Storage Temperature Range** Less than 3 months:

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

**Charging Temperature Range**

0° to 40° C **Max Charging Power** 180 W Vision Positioning **Velocity Range** Below 8 m/s (2 m above ground) **Altitude Range** 5

- 500 cm **Operating Environment** Brightly lit (lux > 15) patterned surfaces

**Operating Range** 0

- 250 cm Exhibits:
A

– DJI Inspire 1 Specifications Data Sheet B

– DJI Inspire 1 Manufacturer’s User Manual C

– DJI Inspire 1 Maintenance Manual D

– Monthly Maintenance LogEXHIBIT

– B DJI Ins pire 1 Manufacturer’s User Manual 41 Exhibits:
A

– DJI Inspire 1 Specifications Data Sheet B

– DJI Inspire 1 Manufacturer’s User Manual C

– DJI Inspire 1 Maintenance Manual D

– Monthly Maintenance Log Exhibit

– C DJI Inspire 1 Maintenance Manual

42 Exhibits:
A

– DJI Inspire 1 Specifications Data Sheet B

– DJI Inspire 1 Manufacturer’s User Manual C

– DJI Inspire 1 Maintenance Manual D

– Monthly Maintenance Log EXHIBIT

– D Monthly Maintenance Log

43

month: year: EXHIBIT

– D

**MONTHLY MAINTENANCE LO G** 

**UAS #:** Date I ssue Discovered Date I ssue

Addressed Issue Description & Maintenance Conducted

Software Updates

Airframe
Engines
Propellers

Camera Gimbal

La nding GearVibration Dampening

Other:

44