### December 28,2015
U. S. Department

of Transportation Docket Management

Operations West Building Ground Floor, Room W12-140 1200 NewJersey

Ave, SEWashington,

DC 20590 RE: Propelled

Media Group, Inc.'s Request

An Exemption

From TheRequirements

of Title 14

of The code of Federal

Regulations

l4 c.F.R.a5.23(b);14

cFR part2l; l4 cFR 6l.l l3 (a) & (b); 91 .7(a); 91.9 (b) (2);et.l03(b);

91.109;e1.il9;

st.t2t; 9l.l5r(a);

9t.203(a)&(b);el

.405 (a);el.407(a)(1); 9t.409 (a)(2);9t.417

(a)& (b). Dear Sir orMadam:

Pursuant

to Section

333 of the FAA Modernization and Reform Act of 2012 (the ReformAct) and 14 C.F.R.Part 11, Propelled Meclia, LLC, ("Propelled

Media', herein after), a professional

photography

lirm, herebyapplies

for an exemptionliom the listed Federal Aviation Regulations ("FARs") to allow commercial opiration of its Small Unmanned

Aircrall Systems

("sUASs") fur aerial photography unJ viileography,

so long as such operations

are conducted

within ancluncler

the conilitions outlined herein or as may be established

by the FAA asrequirecl by Section

333. As detailedin this documentand the attacheil Manual, the requested exemption would permit the operationof stIAS under controlled cor-rditionsin airspaoe that is 1) Iimited 2) predetermined 3) controlled as to accessand 4) would provide saf.ety enhancements

to the already best practices safety protocols followed by propelled Media at each oue of its aerial photography sites.Approval of this exemptiol would thereby enhance safbty and fullill the Secretary of Transportation's (the FAA Administrator's)

responsibilities

to "...establish

requirements

for the safb

operation

of such aircraftsystems

in the national airspace system."

Seotion 333(c)of tlre Reiorm Act. l['he namesand addresses of the applicantsare as follows:
Mr. Austin M. Price,President Mr. RonaldW. Kots, Treasurer Propelled

Media Group, Inc. 10502Iron Point Circle Reno, Nevada 89521 Mr, RonaldW. Kots (775)223-3429 Mr. Austin M. Price (775) 636-1296 Email: I ifteel

im*S"ex({,Ijgrua

i I"c$r:t

PropelledMedia Group Inc.'s Petitionfor 333 Exemption

### TABLE OF'CONTENTS Page

GLOSSARY

OF ABBREVIATIONS... ........3 REGULATIONS

FROM WHICH EXEMPTIONS

AREREQUESTED... ..........3 suMMARy............... ..................4 INTRODUCTION

AND INTERESTS

OFPETITIONER... .,..,........4
BACKGRO[rND......... .................4

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

NAMEANDADDRESS OFPETITIONERS..... .............6

THE SPECIFIC

SECTIONS

OF 14 C.F.R. FROM WHICH PROPELLED

MEDIA GROUP. INC. SEEKS EXEMPTION........... .,.,,,,,,,,,,,..7 THE EXTENT

OF RELIEF

PROPELLED

MEDIA GROUP,

INC. SEEKS

AND THE REASON PROPELLED

MEDIA GROUP,

INC. SEEKS

THE RELIEF. ........,10 THE REASONS

WHY GRANTING

PROPELLED

MEDIA GROUP,

INC. REQUEST 

## *"::::: ^ l:'PUBLrc TNTEREST 

# rHE REAS'NS w;; ;ilr^;;r, ;;;r;;;t;;;;r;;" ;; ;;, INC. WOULD NOT ADVERSELY

AFFECT

SAFETY ..................14 SUMMARY

THATCANBE PUBLISHED IN THEFEDERAL

REGISTER.....,.,,.,,.,,.,.,.25 ANY ADDITIONAL INFORMATION, VIEWS, ORARGUMENTS

AVAILABLE TO SUPPORT

PROPELLED

MEDIA GROUP.

INC. REQUEST ..................2s CONCLUSION........... .................26 APPENDICES.... ...,,..,27

PropelledMedia Group Inc.'s Petitionfor 333 Exemption

### AGL

AOI ATC ATO AV CFR COA FAA FAR GCS GPS LOL NAS NOTAM PIC Section 333 SO SOP UA UAS VFR VLOS VMC VTOL GLOSSARY OF ABBREVIATIONS Above Ground Level Area of Interest Air Traffic Control Air Traffi c Or ganization Aerial Vehicle Code of Federal

Regulations Certifi cate of Authorization Federal AviationAdministration Federal Aviation Regulation Ground ControlStation Global Positioning

System Loss of Link National Airspace System Notice to Airman Pilot In Command FAA Modenizationand Reform Actof 2012

(FMRA) Safety Observer Standard Operating

Procedures Unmanned

Aircraft Unmanned

Aircraft System Visual FlightRules Visual Lineof Site Visual Meteorological

Conditions Vertical Takeoff and Landins
Regulations

fromwliich

theexemption

isrequested:

I4 C,F.R.

Part2l l4 c.F.R.4s.23(b) 14 C.F.R. 61

.I l3 (a) & (b) l4 C.F.R.

91.7 (a) r4 c.F,R.

e1.9 (b) (2) t4 c.F.R.

9l

.I03 14 C.tr.R.91.109 l4 c.F.R.91.119 l4 c.F.R.91.121 l4 C.F.R.91.lsl

(a) 14 C.F.R. el.203 (a)& (b) 14 C.F.R. 91.405 (a) 14 C.F.R. a07 @) (1) 14 c.F.R. aje @)(2) l4 C.F.R.

al7 (a) & (b)

Propelled Media Group Inc.'s Petitionfor 333 ExemptionSUMMARY

Propelled

Media Group, Inc. hereafter referred to as Propelled

Media Group, seeks

exemptions from the requirements of 14 C.F.R part 2r, $$ 45.23(b), 61.113(a) & (b), 9r.7(a),

gr.72t, 91.151(b),91.405(a),

9r.a07@)Q),9r.409(axr) & (a)(2),

and 91 ,afi@) & (b), to operate an Unmanned

Aircraft System(DJI Phantom3 Professional) pursuant

to Section333 of the FAA Modernization

and Reform Act of 2012 (FMRA). This exemption will permit Propelled

Media Group, Inc' to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography of construction sites, residential and commercial real estate, civil landscapes

andevents

over certain

areas of the United States. INTRODUCTION AND INTERESTS OF THE PETITIONER Propelled

Media Group, Inc. has providedtheir clients (which include private sector businesses and non-profits, along with local state and federal agencies)with expertise and knowledge in video and multimedia marketing, advertising, public relations and training using advanced technologies

and solutions.PropelledMedia Group, Inc. has worked in all types of locations with a perfectclient and employee safetyrecord. In the pastwe have supplied our client's aerial video and photography using commercial

aircraft.The objective of Propelled

Media Group, Inc. and our Unmanned

Aircraft System

(DJI Phantom

3 Professional)

aerialoperations

is to provide a more affordable,high-quality production systemfor a variety of governmental, commercial, public, andresidential

uses, specifically

targeting:

. Construction

sites before andafter

. Appraisals

. Real-estate

marketing

. Economic

development

. Civic landmarks

. Aerial photography

. Aerial videography
Propelled

Media's staff has safely flownsmall,

RC,electric

quadcopters

ecreationally

for over two (2)years without incident.
BACKGROUND Unmanned

Aircraft Systems:

DJI Phantom

3 professional.

UAS Propelled

Media Group, Inc. seeks an exemption

to operate

DJI Phantom

3 Professional

system for compensation,

or hire, within the NAS. The DJI Phantom3 Professional is vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The DJI Phantom3 Professionalhas a maximum gross weight of approximately 2.8lb. while having a diagonal dimension

of 23.2",a maximum speed of approximately 16.4'fps and a maximum flying height of 400'. The DJI Phantom 3 Professional is equipped with four main rotors; driven by Lithium Polymer battery powered electric motors.

Propelled Media Group Inc.'s Petitionfor 333 ExemptionThe DJI Phantom3 Professional that will be operated

by PropelledMedia Group, Inc. will be registered

in accordance

with 49 U.S.C. 44103, Registration

of Aircraft aswell as 14 C.F.R parl 47, Aircraft Registration,andmarked in accordance with 14 C.F.R. part 45,Identificationand Registration Marking,

BASIS FOR PETITION Petitioner, Propelled Media Group, Inc., pursuantto the provisions of the FederalAviation Regulations

(14 C'F.R.$ 1

i.61) andthe FAA Modernization and Reform

Act of 2012 (FMRA), Section 333, Special Rules for Certain (lnmanned Aircraft Systems, hereby petitions the Administrator to commercially operatethe DJI Phantom 3 Professional, UAS in the National Airspace

System (NAS), andfor an exemption from the requirements of 14 C.F.R$$ 61.113(a) & (b),91.7(a),9r.r21,91.isi(b), 9t .405(a),9t.a07@)(t),91.409(aX1) & (a)(2),

and.91.al7@) 

### & (b).
In consideration

of the speed,weight, size, and limited operating area associated with the unmanned afu$aft and its operation, Propelled Media Group, Inc. operation of DJI phantom 3 Professional

UAS meets

the conditions

of FMRA Section 333 and therefore,

will not requirean airworthiness

certificate

in accordance

with 14 c.F.R. part2r, Subpart H. Accordingly,

Propelled

Media Group,Inc. requests relieffrom Sections

91.405(a),91.407(a)(l), 9l'a09@)Q) & @)(2), and 9l.al7@) & (b), as these sections set forth requirement, fo, maintenance

that only apply to aircraft with an airworthiness certificate. Propelled

Media Group, Inc. submits that the requested

relief is proper sincean equivalent level of safety will be ensured.Propelled Media Group, Inc. will use experienced personnelor technicians

to perform maintenance, alterations,

or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance

Log, and DJI Phantom 3 Professional

Instruction

Manual). Furthermore, propelled Media Group, Inc' will document and maintain all maintenance records for the DJI Phantom 3 Professional

UAS. Relief from certain requirements of Section61.113(a)

and (b), entitled Private pilot privileges and limitations" Pilot in command, is requested

by PropelledMedia Group, Inc. to the extent necessary

to allow a Pilot in Command (PIC) holding a privatepilot or higher level certificate, as well as an airman medical certificate, and who has demonstrated, by meeting minimum flighthour and currency requirements, that the PIC is able to safely operate the DJI PhantomUAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining

appropriate

distances

from people,

vessels, vehicles and structures. Propelled Media Group, Inc. seeks relief from Section 91.7(a), entitled Civit aircraft airworthiness,

becaqse the DJI Phantom 3 Professional UAS do not require an airworthiness certificatein accordance with 14 C.F.R. Part2l, SubpartH. As such, Propelled Media Group, Inc. submits that they will ensurethat the DJI Phantom 3 ProfessionalUAS is in an airworthy condition, prior to every flight, by determining that the UAS is in compliancewith the operating
PropelledMedia Group Inc.'s Petitionfor 333 Exemption

### documents (i'e., Monthly Maintenance Log, and DJI Phantom 3 Professional

Instruction Manual), and thatthe aircraft

arein a condition

for safe flight. Propelled

MediaGroup,

Inc. also seeks an exemption

from the requirements

of Sectio n 91.127, entitled Altimeter Settings,

as the DJI Phantom

3 Professional

UAS will not have a typical barometric

altimeter onboard. However,

altitude information

of the DJI phantom

3 professional UAS will be provided

to the PIC via GlobalPositioning System (GPS) equipment

and radio communications

telemelry datalink, which downlinks from the UA to the GCS for active monitoring

of theflight path.

Thisaltitude

information,

combined

with Propelled

Media Group, Inc. operation

of the DJI Phantom

3 Professional

UAS within visualline of sight, at or below 400 feet AGL, will ensure

a level of safety equivalent

to section

gr.121. Additionally,

Propelled

Media Group, Inc. seeks

an exemption

fromtherequirements

of Section 91 ' 15 1(b), entitle d Fuel requirements

for flight in VFR

conditions.

Propelled

Media Group, Inc. submits that safety

will not be affected

by operation

of the DJI Phantom

3 professional

UAS during daylight hours in visual meteorological conditions

(VMC) undervisual flight rules (VFR), with enough

battery powerto fly for a total duration of approximately

23 minutes. Battery power indicators

are also able to show exactly how much

battery power is left,as well as howmuch

time is needed

to return safely back to pointof take-off. In accordance

with 14 C.F.R.

$ 11.81, Propelled

MediaGroup,

Inc. provides

the following information

in support

of its petition

for exemption:

A. Nameo

Address, Telephone

Numberso

& Emailof rhe petitioners. The names and addresses

of thePetitioners

and pointof contact

are: Mr. Ronald

W. Kots Mr. Austin

M. Price Co-Presidents Propelled

Media Group, Inc. 10502 IronPoint

Circle Reno, Nevada 89521 775-223-3429

-Mr. Ronald

W. Kots 775-636-1296

- Mr. Austin

M. Price liftedimage

z@gmail.

com

Propelled Media Group Inc.'s Petitionfor 333 ExemptionB. The Specific Sections Of 14 C.F.R. From Which Propelled Media Group, Inc. Seeks Exemption.
1. Propelled Media Group, Inc. Seeks Exemption From The Requirements Of Section 61.113(a)

And (b). Section 61.113, entitled Private pilot privileges and limitations: Pilot in command. subsections

(a) and (b) prescribe

the following, in relevant part: (a) Except as provicled in palagraphs

(b) thuough

(li) ol this section,

no person

who holds aprivatepilot certificate may act as a pilot in command (PIC) of an aircra that is canying passengers or propertyfor compensation or hire; nor may that person, for compensation

or hire, act as pIC of an aircraft. (b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection

with any business

or employment

if- (1) The flight is only incidental to that business

or employment;

and (2) The aircraftdoes

not carrypassengers

or property

for compensation

or hire. 2. Propelled Media Group, Inc. Seeks Exemption From The Requirements Of Section 

### 9r.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. 3. Propelled Media Group, Inc. Seeks Exemption From The Requirements Of Section 

### 9l.lzt.
Section

91.12I, entitled

Altimeter settings,

subsection

(a), states

the following, in paft: (a) Each personoperatingan airuaft shall maintain the cruising altitude or flight level of that airc.;":aft,

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 stationwithin the areaprescribed in paragraph

(a)(l)(i) of this section, the current reported altimeter setting of an appropriateavailable station; or (iii) In the caseof an aircraft not equippedwith a radio, the elevation of the departure

airport or an appropriate altimeter setting available before departure. PropelledMedia Group Inc.'s Petitionfor 333 Exemption4' Propelled Media Group, Inc. Seeks Exemption From The Requirements Of Section

e1.1s1(b).
Section 91.151, entitledFuel requirements for flight in VFRconditions, subsection (b), states

the following: (b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind andforecqst weather conditions) there is enough fuel to /ty to the first point of intended landing and, assumingnormal cruising spied, to fly after that for at least 20 minutes. 5' Propelled Media Group, Inc. Seeks Exemption From The Requirement Of Section 

### 91.a0s(a).
Section91.405,

entitledMaintenance

required,subsection

(a), states

the following: Each owner or operatorof an aircraft_ (a) Shall have that aircraft inspectedas prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) of this section, havediscrepancies

repaired asprescribed

in part 43 of this chapterf.] 6. Propelled Media Groupo Inc. Seeks Exemption From The Requirements Of Section 

## er,a07@)(r)
Section 9L407, entitled Operation after maintenance, preventive maintenance, rebuilding,or alteratiorz, subsection

(a)(1),states

the following: (a) No person may operate any aircraft that has undergonemaintenance, preventive maintenance,

rebuilding, or alter

ati on unle s s- - (1) It hasbeenapproved for returnto service

by a person

authorized

under of this chapter[.] 

### 7. Propelled

Media Group, Inc. Seeks Exemption

From The Requirements Of Sections e1.409(a)(1)

And 91.aOe(a)(2).
section 91.409,

entitledInspections,

subsection

(a), states

the following: (a) Except as provided in paragraph (c) of this section, no person may operate an airqaft unless,

within the preceding12 calendar months,it hashad -- (1) An annualinspection in accordance

with part43 of this chapter and has been approved

for return

to service

by a person

authorized

by $ 43.7 ofthis chapter; or (2) An inspection for the issuanceof an airworthiness certificate in accordance with part 21 of this chapter. 

## s 43.7

Propelled

Media Group Inc.'s Petitionfor 333 Exemption8' Propelled Media Group, Inc. Seeks Exemption From The Requirements Of Sections

9r.4r7(a) And 91.41

7(b). Section 9I'411, entitled Maintenance records, subsections (a) and (b), state the following: (a) Exceptfor work performedin accordance with $$ 91.411and gl,4l3, eachregistered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records

of the maintenance,

preventive

maintenance,

and alteration

and records

of the 1O0-hour,

annual, progressive,

andother required

or approved

inspections,

asappropriate, for each aircraft (including the airframe) and each engine, propellero rotor, and appliance of an aircraft. The recordsmust 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 approving the aircraft for return to service. (2) Records

containing

the following information: (i) The total time in service of the airframe,eachengine, eachpropeller,and each rotor. (ii) The curent status

of life-limited partsof eachairframe, engine, propeller, rotor, andappliance. (iii) The time sincelast overhaul of all items installed

on the aircraftwhich are required to be overhauled

on a specified

time basis. (iv) The cument inspection statusof the afuqaft, including the time since the last inspectionrequired by the inspectionprogram under which the aircraft and its appliances

aremaintained. (v) The current status of applicable airworthiness directives (AD) and safety directivesincluding, for each,the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and datewhen the next action is required. (vi) Copies of the forms prescribed by g a3.9(d) of this chapterfor each major alteration to the airframe and currently installed engines, rotors, propellers,

and appliances. (b) The owner or operator shall retainthe following records for the periods

prescribed:

PropelledMedia Group Inc.'s Petitionfor 333 Exemption(1) The recordsspecifiedin paragraph (aXl) of this section shall be retaineduntil the work is repeated

or superseded

by other work or for 1 year after the work is performed. (2) The records specified in paragraph (aX2) of this section shall be retained and transferred

with the aircraft at the time the aircraftis sold. (3) A list of defects

furnishedto a registered owner or operatorunder $ 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 Propelled Media Group, Inc. SeeksAnd The Reason Propelled Media Group,Inc. Seeks The Relief. 1. Extent Of Relief Propelled Media Group, Inc. Seeks And The Reason

Propelled Media Group,Inc. Seeks

Relief From Section

61.113(a)

And (b). Relief from Section61.113(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 curency requirements, to conductthe proposedUAS flight operations for compensation

or hire. This relief is requested sincethe limitations set forth in Section61.113(a) and (b) state

that a private pilot may, for compensation or hire, act as PIC of an afucraft 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 camy

passengers

or property

for compensation

or hire. As set forth more fully below, Propelled Media Group, Inc. submits that an equivalent

level of safety will be maintained because no PIC will be allowed to operatethe DJI Phantom 3 ProfessionalUAS unless that PIC has met cerlain flight-hour and currency requirements, demonstrating

that the PIC is ableto safelyoperate eitherthe DJI Phantom 3 Professional

UAS in a manner consistentwith the operations specificationsas described in this exemption, including evasive and emergencymaneuvers, as well as maintaining appropriate distances

from people, vessels, vehicles and structures. Further, Propelled Media Group, Inc. submits that all flights of the DJI Phantom 3 Professional UAS, conducted

by the PIC pursuantto the grant of this Petition: (1) will be incidental to Propelled Media Group, Inc. business;and (2) will not carry passengers or property for compensation

or hire.

2. Extent Of Relief Propelled Media Group, Inc. Seeks And The Reason Propelled Media Groupo Inc. Seeks

Relief From Section 91.7(a). Relief from Section 91.7(a) efiitled Civil aircraft airworthiness, is requested to the extent requiredto allow Propelled Media Group, Inc. to determine that the DJI Phantom 3 Professional UAS are in airworlhy condition prior to every flight by ensuring that the UAS is in compliance

1 0 Propelled Media Group Inc.'s Petitionfor 333 Exemptionwith the operating documents(i.e., Propelled Media Group, Inc. Aerial OperationsManual,

Monthly Maintenance

Log, and DJI Phantom 3 Professional

Instruction

Marrual). Propelled

Media Group, Inc. seeks the requested

relief because

the DJI phantom3 professional UAS do not require

an airworthiness

cerlificate

in accordance

with 14 C.F.R..

part2l,subpart H. Therefore,

Propelled

Media Group, Inc. will ensure thatthe DJI Phantom

3 professional

UAS are in airworthy condition basedupon its compliance with the operating

documents

(i.e., Monthly Maintenance

Log, and DJI Phantom 3 Professional)

prior to every flight, and further,determine tlrat the aftqaft are in condition for safeflight, as statedin the conditions ancl limitations below.

3. Extent Of Relief Propelled Media Group, Inc. Seeks And The Reason

propelled Media Group, Inc. Seeks

Relief From Section

gl.l2l. Relief from Section 91.727, entrtled Altimeter settings, may be required to allow flight operations

of the DJI Phantom

3 Professional

UAS, which utllize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information

from the UA to the PIC at the groundcontrol station(GCS). Since the FAA requires that any altitudeinformationconcerning UAS operations

be reporled

to air traffic control fA1.Cl in feet above ground level (AGL), Propelled Media Group, Inc. seeksthe requested relief because the DJI Phantom

3 Professional

UA's altimetermay be set on the groundto zero feet AGL, rather

thanthe local barometric pressure or field altitude,

beforeeach

llight. Considering

the limitedaltitude

of the proposed

operations,

relieffrom 14 CFR 91.121 is sought to the extentnecessary to comply with the applicable conditions

and limitationsstated

below. As more fully set forth herein, an equivalent level of safety will be maintained since the DJI Phantom 3 Professional UAS are equipped with a barometric pressule sensor and GpS equipment,

which automatically

ensures that a ground level pressure setting will be established prior to eachflight, and providesthe PIC with altitude information of the UA on the heads-up display of the GCS.

4. Extent Of Relief Propelled Media Group, Inc. Seeks And The Reason

propelled Media Group, Inc. Seeks

Relief From Section

91.151(b). Relief from Section91.151(b)entitled Fuel requirements for flight in VFR conditions, is requested

to the extent required to allow flights of the battery powered DJI phantom 3 Professional

UAS during daylighthoursin visual meteorological conditions

(VMC), under

visual flight rules (VFR), for a total duration of 23 minutes. Propelled Media Group, Inc. seeks the requested

relief because

without an exemption from Section 91.151(b), the flighttime duration of the batterypoweredDJI Phantom 3 Professional

UAS will severely

constrain

the practicality of any aerialvideo or still photo flight operations that Propelled

Media Group, Inc. proposes to conduct pursuant to this Petition. Significantly,

as setforth below, the technicalspecifications of the DJI Phantom

3 Professional UAS, the DJI Phantom3 Professional operatingdocuments,

and PropelledMedia Group, Inc. l l PropelledMedia Group Inc.'s Petitionfor 333 Exemptionproposed operating

limitations, ensure

that PropelledMedia Group, Inc. will safely operate the battery powered

DJI Phantom

3 Professional

UAS during daylight hoursin visual meteorological conditions(VMC), undervisual flight rules (VFR), with enough batterypower to fly for a total duration of 23 minutes.

5. Extent Of Relief Propelled Media Group, Inc. Seeks And The ReasonPropelled Media Group, Inc. Seeks

Relief From Sections 91.405(a),

91.a07@)(D,

91.409(axl) & (a)(2), And 91.4r7(a)

& (b). Since Sections

91.405(a),91.a07@)(1),9L409(aX1) & (a)(2),

and91 .417(a) & (b) only apply

to aircraftwith an airworthiness certificate,

Propelled

Media Group, Inc. requests relief from these Sections because the DJI Phantom

3 Professional

UAS do not requireairworlhiness certificates. As set forth more fully below, the DJI Phantom 3 Professional UAS meet the conditions of FMRA Section 333 for operation without an airworthiness certificate.

Accordingly, Propelled Media Group, Inc. will use trained technicians

to perform maintenance, alterations,

or preventive maintenance

on the UAS using the methods, techniques,

and practices

prescribed

in the UAS operating

documents

(i.e., the Propelled

Media Group, Inc. Aerial Operations Manual, Monthly Maintenance

Log, and DJI Phantom 3 Professional

Instruction

Manual). Furthermore, Propellecl Media Group, Inc. will document and maintain all maintenance records for the DJI Phantom

3 Professional

UAS.

D. The Reasons

Why Granting Propelled Media Group, Inc. RequestWould Be In The Public Interest;That Is, How It Would BenefitThe PubticAs A Whole. Granting

the present

Petitionwill furtherthe public interest by allowing Propelled

Media Group, Inc. to safely, efficiently, and economically perform aerial video and photography of construction

sites, real estate,

events and civic landscape

over certain

areas of the United States. Additionally, use of the DJI Phantom 3 Professional

UAS will decrease

congestion

of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of Propelled

Media Group, Inc. proposed operation

of the DJI Phantom

3 Prof'essional

UAS will be rcahzed without implicating any privacy issues.

1. The Public Will Benefit From Decreased Congestion

Of The NAS. The DJI Phantom3 Professional UAS is battery powered and serves as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a D.TIPhantom3 Professional UAS would reducethe amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground.
12 Propelled Media Group Inc.'s Petitionfor 333 ExemptionFurthermore, by reducing the number of manned aircraft operating in the NAS, congestion

aroundairports caused by arriving and deparlingaircraft will be reduced. The DJI Phantom3 ProfessionalUAS do not require an airport to takeoff or land. Likewise, a reduction of manned aftcraft conducting aerial video and photography missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations.
2. The Public Will Benefit From The Safety And Efficiency Of The DJI phantom 3 Professionat

UAS. Conducting aerialacquisitions with the DJI Phantom3 Professional UAS, insteadof manned airctaft, will greatlybenefitthe public by drastically reducing the levelsof air and noisepollution generated

during traditional aerial video and still photographyflight operations. By using battery power and electricmotors, the DJI Phantom

3 Professional

UAS produce

no air pollution, and is the most viable environmentally 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 Phantom 3 Professional

UAS, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAS are propelled by battery powered electric motors, rather than an internal combustion

engine. By using the DJI Phantom3 Professional UAS to perform aerialacquisitions, the substantial

risk to life and property in the air and on the ground, which is usually associated with traditional mannedaircraftflight operations, will be substantially

reduced or completelyeliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI Phantom 3 Professional

UAS (weighing approximately 2.8 pounds at their maximum gross weight with diagonaldimensionof 23.2 inches,and with no fuel on board), has less physical potentialfor collateral damageto life and property on the ground, and in the air, comparedto the manned aircraft that typically conductsimilar operations (weighing approximately 6,000 pounds

with a wingspan

of approxim

ately 42 feet,a lengthof 34 feet,and a fuel capacity of 180gallons). 3. Performing Aerial Video and Photography Operations With The DJI Phantom 3 ProfessionalUAS Will Benefit The Economy. In addition to being safe and efficient, the DJI Phantom 3 Professional UAS are also an economical alternative to using manned aircraft to conduct similar aerial operations.As such, operation

of the DJI Phantom

3 Professional

UAS will allow United States based companies,

like Propelled Media Group, Inc., to remain competitive and contribute to growth of the U.S. economy. Specifically,with the rising cost of aviation fuel and the EnvironmentalProtection Agency ("EPA") regulatory actions phasingout leaded

aviationfuels, U.S. owned and operated companies

must adopt new and alternativetechnology in order to remain competitive. Operating the battery powered DJI Phantom 3 Professional UAS is one such technologythat not only allows companies

greateroperationalflexibility compared to manned aircraft, but provides such flexibility without the high operationalcost of a traditional manned aircr:aft.

I J PropelledMedia Group Inc.'s Petitionfor 3 j3 ExemptionBy operating the DJI Phantom

3 Professional

UAS, companies

such as propelledMedia Group, Inc., can remain competitive and profitable, and therefore,provide greater job stability io employees

and contractors,

which will ultimately contributeto growth of the U.S. economy. Improvedfinancial performance of U.S. companies,

throughcommercial

useof the DJI phantom 3 Professional

UAS, provides a stableworkforce that increases consumer

spending;

improves local, state, and federal tax revenues; and allows companies to invesi in research and development

in order to remain competitive both in the United States and abroad. 4. There Are No Privacy Issues. Similar to the manned aerial acquisition

flight operations

that have beenconducted for decades, Propelled

Media Group,Inc. proposed operation

of the DJI Phantom

3 Professional

UAS will not implicateany privacy issues. Specifically,

the DJI Phantom

3 Professional

UAS will be operated only in compliance with operating documents (i.e., Propelled Media Group, Inc. Aerial Operations

Manual, Monthly Maintenance Log, and DJI Phantom 3 Professional Instruction Manual) which requires property owner involvement as well as local law enforcement notification, and in accordance with the Federal

Aviation Regulations, including the minimum altitude requirements

of 14 C.F.R.

$ 91

. 119.

E. The ReasonsWhy Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To That provided By The Rule From which Propelled Media Group,Inc. seeksExemption. l. Reasons

Why The DJI Phantom 3 Professional UAS Meet The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section333. In consideration

of the size, weight, speed,and limited operatin g arcaassociated

with the unmanned

aircraft and its operation, Propelled

Media Group, Inc. operation of the DJI phantom 3 ProfessionalUAS meet the conditions of FMRA Section 333, and, will not require an airworthiness

certificate

in accordance

with 14 c.F.R. part2r, Subpart H. Section 333 provides

authorityfor a UAS to operate without airworthiness

ceftificationand sets forth requirements

for consideringwhether a UAS will create ahazard,tousers of the NAS or the public, or otherwise

posea threat

to nationalsecurity.

Specifically,

FMRA Section

333 states

the following, in part:

(a) In General.--Notwithstanding any other requirement of this subtitle, and not later than 180days after the date of enactment of this Act, the Secretaryof Transportation shall determine if certain unmanned aircraft systems tnay operate safely in the national airspace systembefore completion of the plan and rulemaking required by section 332 of thisAct or theguidance required by section

334 of thisAct. (b) Assessment

of (Jnmanned

Aircraft Systems.--In

making the determination under subsection

(a), the Secretary

shall determine,

at a minimum--

I 4 PropelledMedia Group Inc.'s Petitionfor 333 Exemption(1) which types of unmanned aircraft systems,

tf ony, 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 o certfficate of waiver, certificate of authorization, or airworthiness certffication under section 44704 of title 49, tlnited States Code, is required

for the operation of unmanned aircraft systems

identffied underparagraph (l). (c) Requirements

for Safe Operation.--If the Secretary

determines

under this section that certain unmannedaircraft systems mqy operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems

in the national airspacesystem. In seeking this exemption, Propelled Media Group, Inc. submits that the DJI phantom 3 Professional UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated

by: (a) the characteristics of the DJI Phantom3 Professional UAS; (b) the pilot certification

requirement;

and (c) the specific

operating

limitations.

a. The Specifications

Of The DJI Phantom 3 ProfessionalUAS Demonstrate Its Safe Characteristics.
The DJI Phantom

3 Professional

UAS does

not createahazard.to

users of the NAS or the public, or otherwise

posea threat

to national

security considering

its size, weight, speed,

and operational capability.
i. Technical

specifications

of rhe DJI phantom 3 professional uAS. The technical specifications of the DJI Phantom3 Professional UAS are set forth by the DJI Phantom3 Professional user Manual, attached hereto asAppendix A. ii. The DJI Phantom3 Professional UAS Global Positioning Modes EnableThe UAS To Remain Within A Defined Operational Area. The DJI Phantom 3 ProfessionalUAS may be operatedin both manual and global positioning flight modes.

A complete

description

of the flight and navigational modesof the DJI phantom3 Professional

UAS is provided at pages 11 of the DJI Phantom 3 Professional User Manual attached hereto as Appendix A.
iii. The DJI Phantom 3 ProfessionalUAS Is DesignedFor Automatic Return To Home Point Or Hover In The Event Of LossOf The Control Link Or Navigation. When the Control Link is lost, the DJI Phantom3 Professional UAS will remain stationary, in flight, for 3 seconds

or more. If, after 3 seconds, the DJI Phantom

3 Professional

UAS doesnot reacquirecontrol link data from the GCS, the UAS will assume that the Control Link is lost and

l 5 PropelledMedia Group Inc.'s Petitionfor 333 Exemptionthe will returnto the home position (i.e.,failsafemode)via GPS,andwill descend to the takeoff positionand shutdown.
A complete

description

of the Failsafe

Functions

of the DJI Phantom

3 Professional

UAS are set forth at pages 12 through 14 of the DJI Phantom 3 ProfessionalUser Manual, attached hereto as AppendixA.

iv. The DJI Phantom3 Professional GCS And Its Operation. A complete

description

of the operation

and specifications

of the DJI Phantom3 Professional UAS and flight control software is provided at pages23 through 29 of the DJI Phantom 3 Professional

User Manual. DJI Phantom 3 Professional User Manual is attached hereto as AppendixA.
b. Flight Operations

Of DJI Phantom3 Professional UAS Is Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer. Propelled

Media Group, Inc. video productionstaff will be the only persons to act as a pilot in command(PIC) of the DJI Phantom3 Professional UAS. Additionally, a safety observer will assist him at all timesduringflight time.

c. Flights Of DJI Phantom3 Professional UAS Will Be ConductedPursuantTo Specific Operating Limitations.
In seeking

this exemption,

PropelledMedia Group, Inc. proposes to commerciallyoperate DJI Phantom

3 Professional

UAS for the special

purpose of conducting

aerialvideo and photography over certain

areas of United States,

pursuant to the following specific operating

limitations.
1. Operations

authorized

by this grant of exemption will be limited to the following aftqaft described

in the operating

documents,

rotorcraft UAS weighing lessthan 55 pounds maximum gross weight: DJI Phantom 3 ProfessionalUnmanned Aircraft Systems.

Proposed

operations

of any other aircraft will require a new petition or a petition to amend

this grant.
2. UAS operations

under this exemption

will be limited to conducting operations

for the purpose

ofaerial video andphotography.
3. The UAS may not be flown at an indicated airspeed exceeding

20 knots.
4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL), as indicatedby the procedures specifiedin the operating documents

unlessa special requestis made and approved by ATC. All altitudes reportedto ATC must be in feetAGL.
5. The UAS must be operated within visual line of sight (VLOS) of the PIC at all times. This requires

the PIC to be able to use human vision unaidedby any device

1 6 Propelled Media Group Inc.'s Petitionfor 333 ExemptionI 7 other than corrective lenses, as specifiedon the PIC's FAA-issued airman medical certificate.
6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted.
7. All operations

must utilize a safetyobserver (SO). The SO may be usedto satisfy the VLOS requirement as long asthe PIC alwaysmaintains VLOS capability.

The SO and PIC must be able to communicate verbally at all times. Electronicmessaging or texting is not permitted during flight operations.The PIC must be designated before the flight and cannottransfer his or her designationfor the duration of the fliglrt. The PIC must ensure that the SO can perform the functions prescribed in the operating documents.
8. The SO must not perform any otherdutiesbeyond assisting

the PIC with seeing

and avoiding other air traffic and other ground based obstacles/obstructions and is not permitted to operate

the camera

or other instruments. 9. The operatingdocuments and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy

exists between

the conditions and limitations containedin the grant of exemption

andthe procedures

outlined in the operating documents,

the conditions

and limitations containedin the grant of exemptiontake precedence and must be followed. Otherwise, the operator must follow the proceduresas outlined in its operating documents. The operator may update or revise its operating documents. ti is the opetator's responsibility to track such revisions and present updated and revised documents

to the Administrator upon request. The operator must also presentupdated and revised documentsif it petitions for extensionor amendment io the grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA grantedthe exemption, then the operator must petition for amendment

to its grant of exemption. The FAA's UAS IntegrationOffice (AFS-80) may be contacted if questions arise regarding updates or revisions to the operating documents.
10. Prior to each

flight the PIC must inspect the UAS to ensure

that it is in a 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 beenperformed and the UAS is found to be in a condition for safeflight. The Ground Control Station must be included in the preflight inspection. All maintenance

and alterations

must be properly documented in the aircraftrecords. 11. Any UAS that has undergone maintenanceor alterations that affect the UAS operationor flight characteristics, e.g. replacement

of a flight critical component, must undergoa functional test flight. The PIC who conductsthe functional test flisht must make an entry in the aircraft records.

Propelled

Media Group Inc.'s Petitionfor 333 Exemption12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections of the operating

documents. 13. The operator must foliow the UAS manufacturer's aircraftlcomponent, maintenance,

overhaul, replacement, inspection,and life limit requirements. 14. The operatormust carry out its maintenance, inspections,

and record keeping requirements,

in accordance

with the operating

documents.

Maintenance,

inspection, alterations,and statusof replacement/overhaul componentparts must be noted in the aftcraft' records,including total time in service,descriptionof work accomplished, and the signature

of the authorizedpersonreturning the uAS to service. 15. Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins.
16.The authorized

person must make an entry in the airqaftrecord of the corrective action takenagainst

discrepancies

discovered

between inspections. 17.The PIC must possess at least a privatepilot certificate and at least

a current

thirdclass medical certificate. 18. The operator may not permit any PIC to operate unless the PIC meets the operator's qualification criteria and demonstrates the ability to safely operatethe UAS in a manner

consistent

with how the UAS will be operated under the exemption, including evasive and emergency maneuversand maintaining appropriate distances from persons,

vessels, vehiclesand structures. PIC qualificationflight hours must be logged in a manner

consistent

with 14 C.F.R.$ 61.51(b). Flights for the purposes

of training the operator's PICs are permitted under the terms of the exemption. However, training operations may only be conducted during dedicated training sessions'

During training,proficiency, and experience-building flights, all persons

not essential

for flight operationsare considerednonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipantsin accordance with 14 c.F.R. g 91.119. 19.UAS operations

may not be conducted

duringnight,asdefined in 14 c.F.R. $ 1.1. All operations

must be conducted

under visual meteorological conditions(VMC). If flight at night is required, a special

request will be madeat the FAA office closesr to proposed

areaof operations.

Flights under special

visual flight rules (SVFR) are not authorized.
20. The UA may not operatewithin 5 nautical miles of an airport referencepoint as denoted on a cunent FAA-published aeronauticalchart unless a letter of agreement with that airport's management is obtained, and the operation is conducted in accordance

with a NOTAM as required by the operator's COA. The letter of agreement

with the airport management must be made available to the Administrator upon request.

l 8 PropelledMedia Group Inc.'s Petitionfor 333 Exemption21' The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally

from a cloud or whenvisibility is less than 3 statute

miles from the pIC. 22'rf the uA losescommunications or losesits GPS signal, it must return to apre- determined location within the planned operating ur"uind land or be recovered in accordance

with the operatingdocuments. 23' The PIC must abortthe flight in the event of unpredicted

obstacles

or emergencies in accordance

with the operatingdocuments. 24' The PIC is prohibited from beginning a flight unless (considering wind and forecastweather conditions) there is enoughpower to fly at normal cruising speed to the intendedlanding point and randthe uA with 25%obattery power remaining. 25' The operatormust obtain an Air Traffic Organization(ATo) issuedCertificate of Waiver or Authorization (CoA) prior to conducti ng anyoperationsunder the grant of exemption'This CoA will also require the operator to iequest a Notice to Airman (l{oTAM) not more than 72 hours in advance, but not less ihan 48 hours prior to the operation'All operations shall be conducted

in accordance

with airspace

re,quirements in the ATo issued CoA including class of airspace, altitude lwel anj potential transponder

requirements. 26' All afuctaft

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(NNumber) markings in accordance with 14 c.F.R. part 45,subpart c. Markings must be as largeaspracticable.
27' Ptiot to conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the FederalCommunications Commission (FCC) or other appropriate government

oversight agencyrequirements. 28. The documents

required fewer than 14 C.F.R. 91.9 and gI.203 must be available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made available to the Administrator or inn law enforcement

official upon request. 29' The UA must remain clear and yield the right of way to all manned aviation operations

andactivities

at all times. 30' The UAS may not be operated by the PIC from any moving device or vehicle. 

### 31. Flight operations

mustbe conducted

at least 500 persons (persons otherthan the pIC, SO, operator vessels, vehicles, and structures

unless: feet from all nonparticipating

trainees or essential

persons),

a. Barriers or structures are present that sufficiently protect nonparticipating personsfrom the UA and/or debris in the event of an accident. ihe operatoi must ensurethat nonparticipating persons remain under such protection. If a


### t 9 PropelledMedia Group Inc.'s petitionfor 333 Exemptionsituation ariseswhere nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease

immediatel

y and,lor; b' The airctaft is operated near vessels, vehicles or structures where the owner/controller

of suchvessels,

vehicles or structures

has granted

pelnission and the PIC has made a safety assessment of the risk of operatingcloser to thoseobjectsand determined that it doesnot present an undue hazard,,

and.; c' Operations

nearer to the PIC, SO, operator trainees or essential

persons do not present

an undue

hazardtothose

persons per $ 91.1

19(a). 32' All operations

shall be conducted

over private or controlled-access propertywith permission

from the land owner/controller or authorizedrepresentative. permission from land owner/controller or authorized representativewill be obtained for each flight to be conducted. 33' Any incident,accident, or flight operation

that transgresses

the lateralor vertical boundaries

of the operational

areaas definedby the applicable COA must be reported to the FAA's UAS Integrationoffice (AFS-80) within 24 hours.Accidentsmust be repofted to the National Transportation Safety Board OfTSB) per instructions contained

on the NTSB Web site:www.ntsb.sov.

2' Reasons

Why An Exemption From The RequirementsOf Section 6r.ll3(a) And (b) Would Not Adversely Affect Safefy. Propelled

Media Group, Inc. submits that the equivalent

level of safety established by Section 6 1 ' I 1 3(a) and (b) will be maintained because no PIC will be allowedto operate the DJI phantom 3 Professional

UAS unlessthat PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the DJI phantom 3 professional UAS in a mannerconsistent with the exemption,

including evasiveand emergency maneuvers and maintaining

appropriate

distances

from people,

vessels, vehicles and structures. Considering Propelled Media Group, Inc. proposed area of operations,and the operating limitations set forth-above; the parallel natuie of private pilot aeronautical knowledge requirements

to those of commercialpilot requirements lSee Exemption No. 1 1062); a1d the airmanship

skills necessary

to safely operate

the DJI Phantom3 professional UAS, propelled Media Group, Inc. submits that the additional mannedairmanship experience of a commercially certificatedpilot would not correlate to the airmanshipskills necessary for propelled Media Group,Inc. specific

proposed

flight operations. The FAA has previously granted relief from Section 61.113(a)and (b) specific to UA.S, in circumstances

similar, in all material respects, to those presented

herein 1eg. Exemption Nos. 11062,11063,17064,11065, 11066,11067,110g0,

1110b, 11110, rrrL2,ttna,1113g,

11150, 11153, 11156, 11159, 11159, 11160, 11161).

20 Propelled Media Group Inc.'s Petitionfor 333 ExemptionPropelled Media Group, Inc. will not allow any PIC to operate the DJI phantom 3 professional UAS unless

that PIC hasdemonstrated, by meeting

minimum flighrhour requirements or the DJI Phantom

3 Professional

UAS training and currencyrequirements, that the pIC is able to safely operatethe DJI Phantom 3 Professional UAS in a manner consistent with this exernption, including evasive

and emergency

maneuvers

and maintaining

appropriate

distances

from people, vessels, vehicles and structures. Specifically,

the PIC must haveaccumulated and logged,

in a manner

consistent

with 14 C.F.R.$ 61'51(b),

25 hours

of totaltime as a UAS rotorcraft pilot (with a minimum of 5 hours o[those hoursasa UAS pilot operating the same

makeand model of UAS to be usecl for operations

under the exemption).

In addition to the hour requirements, the PIC must accomplish 3 takeolTs

and landings in the preceding

90 days(for cunencypurposes). As in Exemption

Nos. 17062, 11138,

and 11153,

prior documented

flight experience

that was obtained in compliancewith applicableregulations will ensurean equivalent level of safety during Propelled

Media Group, Inc. proposed operations.

The Administratorhas held that prior documented

flight experience

that was obtained

in compliance

with applicable

regulations

would ensure safe operations,

stating asfollows: In Exemption No' 11062, the FAA requiredthat prior to conducting operations

1brthe pwpose of motion picturefilming (or similar operations), the PIC must haveaccumulated and logged,

in a manner

consistent

with 14 CFR 61.51(b),25 hoursof total time as a UAS rotorcraftpilot including at least 10 hours loggedas a UAS pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the pIC must also have accumulated

and loggeda minimum of 5 hours as a UAS pilot operating the same

make ' and model of UAS to be usedfor operations underthe exemption.

For clarification,

the FAA considers

these minimum hour requirements to be inclusiverather

than additive;i.e. 5 hoursmakeand model time may be includedin the 10 hoursof multi-rotortime andthe 10 hoursmay be includedin the total25 hoursof UAS rotorcrafttime. In additionto the hour requirements,

the PIC must accomplish 3 takeoffsand landingsin the preceding 90 days (for currency purposes).The FAA finds that at a minimum, the flighrhour requirements

in Exemption

No. 11062

areappropriate

to practice

and build proficielcy in the skills necessary

to safelyconduct

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-building

flights can also be conducted under the grant of exemption to accomplish

the required

flight time. During training,proficiency, and experience-tuilding flights the PIC is required to operatethe UA with appropriate distancesin accorrJance with 14 C.F.R 91.119. Exemption

No. 11138

atpage 15. Accordingly, Propelled Media Group,Inc. will ensure safe operations

by not allowin

g any p,IC to operate the DJI Phantom 3 Professional UAS unlessthat PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely operatethe DJI Phantom

3 Professional

UAS in a mannerconsistent with the exemption,

including evasive

and 21 Propelled Media Group Inc.'s Petitionfor 333 Exeryttionemergency maneuvers

and maintaining appropriatedistances from people, vessels,

vehicles and structures.

3' ReasonsWhy An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety. The equivalent

level of safety

established

by Section91.7(a)

will be maintained

because prior to every flight, Propelled Media Group, Inc. will ensure that the DJI Phantom

3 professioneLl

UAS is in an airworthy conditionbased upon the UAS's compliance with its operating

documents

and asstated

in the conditions

and limitationsherein. Additionally, the FAA has previously grantedrelief from Section 91.7(a) specific to UAS, in circumstances

similar, in all material respects, to those presented

herein 1e.i. nxemption Nos. 77062,11063,71064,11065,11066,71067,11090,1110g,11110, 17772,nI2A,1113g,11150, 11153, 11156, 11157,11159,

11159, 11160, 11161).

4. ReasonsWhy An Exemption From The Requirements Of Section gl.Ill Would Not Adversely Affect Safety. The equivalentlevel of safety established by Section gL1zl will be maintainedbecause the altitudeinformation

of the DJI Phantom

3 Professional

UAS will be provided

to the pIC via GpS equipment artd aradio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path and altitude.This altitude information, combined with Propelled Media Group, Inc. operationof the DJI Phantom 3 Professional UAS within visual line of sight,at or below 500 feet AGL, will ensure a level of safetyequivalent to Section 9I'121' The altitude information will be generated by GPS equipment installed onboardthe airqaft' Prior to eachflight, a zeroaltitude initiation point is automatically established

by the UAS at groundlevel. The FAA has previously granted relief from SectionSLI2I specificto UAS, in circumstances similar,in all material respects,

to those presented

herein(e.g.Exemption Nos. 11062,11063, 11064,11065,11066,

11067,11090,11109,

11112,11136,1113g,11150,11153, i1156, 11757, 11158, 1l159, 11160, 11161).

5. Reasons

Why An Exemption From The Requirements Of Section91.151(b)

Would Not Advers ely Affect Safety. A grant of this exemption would ensure

an equivalent

level of safety established by 14 C.F.R. Section 91.151(b)

asa resultof (1) the technical specifications

of the DJI Phantom

3 professional UAS; (2) the limitations on the propose'J flight operations;

and (3) the location of the proposed flight operations.

Accordingly, Propelled Media Group, Inc. will ensure that it will safely

operate



### 22 Propelled Media Group Inc.'s Petitionfor 333 Exemptionthe battery poweredDJI Phantom 3 Professional

UAS during daylight hours in vFR conditions, with enough

battery power to fly for a total duratio'of 23 minutes. Here,as in Exemption No. 11109,

the technical

specifications

of the DJI phantom3 professional UAS; the limitations on the proposed flight operations;and the location of the pr:oposed operations,

will ensure

an equivalent

levelof safety

established

by 14 C.F.R.

Section 9l.l5l(b). Furthermore,

safety will be ensured

asthe DJI Phantom

3 Professional

UAS provide audibleand visual warnings

to the PIC at the GCS when the UAS experiences low batteiy voltage,

the first warning occurring at approximately 33o/o remaining battery power, and, againat approximately l0o/o remaining

battery power.At the critically low battery level, the DJI phantorn 3 professional UAS will descend

and land automatically. Significantly,

previousexemptions

granted by the FAA concerning Section 9l

.i 5l establish

that safety is not adversely

affected whenthe technical

characteristics

and operating

limitationsi

of the UAS are considered.

Relief has been grantedfor manned aircraft to operate

at less than the minimums prescribed in Section

91.151,including ExemptionNos. 2egg,5745, and 10650. Moreover,

the FAA has previouslygrantedrelief from Section91.151 specific to UAS, in circumstances

similar, in all material respects, to those presented

herein (e.g. Exemption Nos. 8811, l0g0g, 10673,71042,11062,11063, 11064,1106i,

n066,11067,110g0,

1110g, 11110, 11136, 1 1 139, 1 r 150, 1 1 153, l 1 156, rrr57, I I 15g,

71759, 1 I 160, 1 1 161).

6' Reasons Why An Exemption From The Requirements of Sections 91'405(a),

91.407(a)(l),91.409(axl) & (a)(2),And 91.417(a) & (b) Woutd Nor Adversety Affect Safety.
In seekingthis exemptiou, Propelled Media Group, Inc. submits that the equivalentlevel of safety with regard to the regulatory maintenance and alteration requirements establisfred

by Sections 91.405(a),9r.a07@)Q),91.409(a)(1) & (a)(z),and

91 .417(a)&(b) will be metbr:cause Propelled

Media Group, Inc' will usetrained technicians

to perform maintenance, alteratigns,

or preventive

maintenance

on the UAS using the methods, techniques,

and practices

prescribed

in the operating

documents

(i.e., Propelled

Media Group, Inc. Aerial operationsManual, Mpnthly Maintenance

Log, and DJI Phantom 3 Professional

Instruction

Manual). Furthermore, propelled Media Group, Inc. will document and maintain all maintenance records for the DJI phantom 3 Professional

UAS. Since the DJI Phantom3 Professional UAS will be inspected as prescribed

by the operatilg documents,

Propelled

Media Group, Inc. will maintainthe equivalent level of safetyestablished by Sections

91.405(a),91.a09@)(t), and 91.a09@)(2).

A copyof the DJI phantom 3 professional User Manuals are attached hereto as Appendix A and B; a copy of the DJI phanlom 3 Professional

UAS Maintenance

LoG is attached

hereto asAppendix c. Likewise,the exemption sought will not adversely

affect safetybecause

propelledMedia Group, Inc' will use trainedtechnicians to perform maintenance, alteration, o, pr"u"ntive maintenance on the UAS usingthe methods, techniques,

andpractices

prescribed

by thi operating

documents.

Z J PropelledMedia Group Inc.'s Petitionfor 333 ExemptionFurthermore,the exemption sought would maintain an equivalent level of safety established by Sections

9I'407,91.aI7@) and 91 .4I7(b), because

all maintenance

of the DJI phantom 3 Professional

UAS will be performed by trained technicians. Maintenance

will be documented and maintainedutilizing the monthly maintenance log. Significantly, previous exemptions granted by the FAA concerning sections 91.405(a), 9r'407(a)(r),91'409(a)(1) & (a)(2), and,gl.ania) & (b) establish that safery

is not adversety affectedwhen the technic al charucteristics

and oplrating limitations of the UAS are considered. In consideration

of PropelledMedia Group, Inc. proposed operatinglimitations, the operating documents,

and the technical

aspects of the DJI Phantom

3 Professional

uAS, propelled Media Group, Inc' submits that safety will not be adversely affected by granting exemption fiom 14 

### c.F.R. Sections 9r.405(a),

9r.a07@)(r)

and (a)(2),9r.a09@)(2),

and ol.utlay 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, 77067,11090,

i1109,11110,11112,71136,tt]:s,11150,11153,11156, 17157,1115g,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) and14C'F'R' $ 21.

16entitled

Special Conditions,

Propelled

Media Group, Inc.requests

that the FAA prescribe

special conditions

for the intended

operation

of the DJI phantom

3 professional uAS, whichcontain

such safety standards

thattheAdministrator

findsnecessary

to establish

a level of safety equivalent

to that established

by 14C.F.R.

part2T,subpart

H, and 14C.Ir.R

$$ 61.113(a)

& (b), 91.7 (a),9r.r2r,91.1s1(b),

ot.+0s1a7,9r.407(a)(r),9r.409(a)(1) & (a)(2),

and 9l'417(a)& (b)' Such

special conditions

will permit

safe operation

of the UAS for the limited purpose of conducting

aerial video andphotography

over certain

areas of the United Sta1es

for orththe requirements

for considering

whether a the public, or otherwise

pose a threat o national ,r such UAS to operate without airworthiness s that mustbe established for the safe

operation
special conditions pursuantto 14 C.F.R. 3 Professional

UAS, sincethe airworthiness regulations

of 14C'F.R.Part

2l do not contain

adequate or appropriate

safety standards,

due to the novelor unusual

design features of the aircraft.

Section2L

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 airrxaft, urcraft angine,or propeller because of a novel or unusual

design feature of the afucraft,

aircraft.ngin. or propeller, he prescribes

special conditions

and amendments

theretofor the product.The special conditions

are issued

in accordance

with Part 11 of this chapter and contain

suchsafety

. A L + PropelledMedia Group Inc.'s petition for 333 Exemotion

### standards for the aircraft, aircraftengineor propeller as the FAA finds necessary to establish a level of safety equivalent

to that established

in theresulations. 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 Propelled

Media Group,Inc. intended operation

of the DJI Phantom 3 Professional

UAS, which contain

suchsafety

standards

that the Administrator

finds necessary

to establish

a level of safety

equivalent

o that established

by 14 C.F.R. part 21, Subpart H, and 14 c.F.R Sections 61.113(a)

& (b),9r.7(a),

gr.r2r,91.151(b),

91.405(a), 91.a07@)(1),91.409(aX1) & (a)(2),and

91 .an@) & (b).
r d Summary

That Can Be Published in the Federal

Register,

stating: The Rules from which Propelled

MediaGroup,Inc.

seeks Exemption: Propelled

Media Group, Inc.seeks

exemptionfrom

therequirements

of t4 C.F.R

Sections 6r.il3(a)&(b), 9r.7(a), 9r.r2r, 9L151(b), 9r.405(a),

91.407(a)(i),

9r.409(a)(1)

& (a)(2), and 91.4t7@)

a (U.

A Brief Description

Of The Nature Of The Exemption PropelledMedia Group,Inc. Seeks: This exemption will permit Propelled Media Group, Inc. to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States. ' Any Additional Informationo Views, Or Arguments Available To Support Propelled

Media Groupo

Inc. Request. This Petition is made pursuant to the FAA Modernizationand Reform Act of 2012 (FMRA) Section

333,which directs

the Secretary

of Transportation

to determine

if certainUAS may operate

safelyin the NAS. As such,Propelled Media Group, Inc. 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 createa hazard to usersof the NAS or the public, or otherwise poses athreatto national security;and further' provides the authority for such UAS to operate without airworthinesscertification. As discussed

in detail above, Propelled Media Group, Inc. will operatethe DJI phantom 3 Professional UAS safely in the NAS, without creating a hazard, to users of the NAS, or the public, or otherwise

posea threat

to national

security.

25 PropelledMedia Group Inc.'s Petitionfor 333 Exemption

### CONCLUSION

As setforth herein,

Propelled

Media Group,

Inc. seeks

an exemption

pursuantto14 c.F.R. $ 11'61 andsection

333of the FAA Modemizationand Reform Act of 2012

(FMRA), which will permit safe operationof the DJI Phantom3 Professional UAS commercially,

without an airworthiness

certificate,

for the limited purpose of conducting

aerialvideo and photography over certain areas of the United

States. By granting

this Petition,

the FAA Administrator

will be fulfilling the Congressional mandate of the FAA Mode

rnizationand

Reform Act of 2lr2,while alsoadvancing

the interests

of the public,by allowing Propelled

Media Group,

Inc. to safely, efficiently,

andeconomically

operate the DJI Phantom

3 Professional

UAS commercially

within theNAS. WHEREFORE, in accordance with the Federal Aviation Regulationsand the FAA Modernization

andReform

Act of 2012,

Section 333,Propelled

MediaGroup,

Inc. respectfully requests thatthe Administrator

grant this Petition

for an exemption

from the requirements

of 14 c.F.R sections

61.113(a)

8. (b), 91.7(a),

gr.r2r,91.151(b),

9r.405(a),9r.407(a)(1), 9l'a09@)(l)& (a)(2),

and91 .afi@) & (b), andpermitPropelled MediaGroup,

Inc. ro operare the DJI Phantom

3 Professional

UAS commercially

for the purpose

of conducting

aerial video and photography

overcertain

areas of the UnitedStates.

Dated: December

28, 2015

Verytruly

Counsel for Propelled

Media, LLC

26 PropelledMedia Group Inc.'s petitionfor 333 Exemption

### Appendices:

A - Link to DJI Phantom 3 professional

Manual:click on link below

27 PropelledMedia Group Inc.'s Petitionfor 333 Exemption