UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: Michael J. Mazzone FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 14 C.F.R §§ 21; Subpart H, 45.23(b), 91.7(a), 91.9(b)(2), 91.103(b), 91.109, 91.119, 91.121, 91.151(b), 91.203(a) & (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) & (b), CONCERNING COMMERCIAL OPERATION OF DJI-FLAME WHEEL F450, DJI-FLAMEWHEEL F550, DJI-INSPIRE 1, DJI-INSPIRE 1 PRO, DJI INSPIRE 2, DJI-MATRICE 100, DJIPHANTOM 1, DJI-PHANTOM 2, DJI-PHANTOM 2 VISION+, DJI-PHANTOM 3STANDARD, DJI-PHANTOM 3 ADVANCED, DJI-PHANTOM 3 PROFESSIONAL, DJIPHANTOM 4, DJI-SPREADING WINGS S900, DJI-SPREADING WINGS S1000+ UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on 03/08/2016

Michael J. Mazzone 53 John Potter Rd. West Greenwich, RI 02817 (401) 225-5292 Michael.J.Mazzone@gmail.com

### Table of Contents Glossary of Abbreviations ................................................................................................................1

Introduction ......................................................................................................................................2

Basis for the Petition ........................................................................................................................3

Name & Address of the Petitioner ...................................................................................................4 The Specific Sections of 14 C.F.R. from which Michael J. Mazzone Seeks Exemption ................5 Reasons Why This Exemption Will Not Adversely Affect Safety Standards ................................11

Public Interest Benefits ..................................................................................................................12 Proposed Operations ......................................................................................................................13 sUASs for Proposed Operations ....................................................................................................14

Conclusion .....................................................................................................................................15

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### Glossary of Abbreviations

AGL Above Ground Level AOI Area of Interest ATC Air Traffic Control ATO Air Traffic Organization AV Aerial Vehicle CFR Code of Federal Regulations COA Certificate of Authorization FAA Federal Aviation Administration FAR Federal Aviation Regulation GCS Ground Control Station GPS Global Positioning System LOL Loss of Link NAS National Airspace System NOTAMNotice to Airman PIC Pilot In Command sUAS Small Unmanned Aircraft System Section 333 FAA Modernization and Reform Act of 2012 SO Safety Observer SOPStandard Operating Procedures UA Unmanned Aircraft VFR Visual Flight Rules VLOS Visual Line of Site VMC Visual Meteorological Conditions VTOL Vertical Takeoff and Landing

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### Introduction To Whom It May Concern; Pursuant to §333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, Michael J. Mazzone, operator of sUASs, hereby applies for an exemption from the listed FARs, to allow commercial operation of his sUASs, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by §333. As described more fully below, the requested exemption would permit the operation of small, unmanned and relatively inexpensive multi-rotor aircraft under controlled conditions in airspace that is 1.) contained 2.) predetermined and 3.) would provide increased safety and enhancements to the business operations of Michael J. Mazzone. Michael J. Mazzone, owner and PIC, has over (10) years of aviation experience. He graduated from the Florida Institute of Technology in 2010 with a degree in Aviation Management. In addition to his flight degree, he also obtained his Private, Instrument, Commercial, Multi-Engine & CFI-A ratings during his time spent at Florida Tech. In addition to being an active flight instructor, he also holds an Airline Pilot Transport certificate and works for SkyWest Airlines as a First Officer on the ERJ-175.

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### Basis For Petition Michael J. Mazzone submits this application in accordance with the Reform Act, 112 P.L. 95 §§331-334. He seeks relief from the listed federal aviation regulations pertaining to sUASs, which prevent Michael J. Mazzone from conducting business service flight operations within the U.S. national airspace system. The Reform Act in §332 provides for such integration of civil sUASs into our national airspace system, as it is in the public's interest to do so. Michael J. Mazzone’s lightweight sUASs meet the definition of "small unmanned aircraft" as set forth in §331. Combined with a sterling safety record in similar industries, Michael J. Mazzone’s light duty sUASs are ideal recipients of exemption by the intent of the Reform Act. Considerations for relief include a combination of sUAS physical characteristics, safety features, and safe practices identified in §333:

★ sUAS weight ★ sUAS overall size ★ sUAS speed over ground ★ sUAS flight zone characteristics ★ Non-operation near airports (civilian or military) ★ Tightly controlled operation in populated areas ★ Operation of the sUAS by VLOS

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### Name & Address of the Petitioner

Michael J. Mazzone 53 John Potter Rd. West Greenwich, RI 02817 (401) 225-5292 Michael.J.Mazzone@gmail.com

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### The Specific Sections of 14 C.F.R. from which Michael J. Mazzone Seeks Exemption Michael J. Mazzone kindly requests a grant of an exemption of the following sections of Title 14 of the Code of Federal Regulations:

★ 14 C.F.R. § 21; Subpart H ★ 14 C.F.R. § 45.23(b) ★ 14 C.F.R. § 91.7(a) ★ 14 C.F.R. § 91.9(b)(2) ★ 14 C.F.R. § 91.103(b) ★ 14 C.F.R. § 91.109 ★ 14 C.F.R. § 91.119 ★ 14 C.F.R. § 91.121 ★ 14 C.F.R. § 91.151(b) ★ 14 C.F.R. § 91.203(a) & (b) ★ 14 C.F.R. § 91.405(a) ★ 14 C.F.R. § 91.407(a)(1) ★ 14 C.F.R. § 91.409(a)(2) ★ 14 C.F.R. § 91.417(a) & (b) Specific consideration is outlined below: 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. § 21; Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203(a)(1). Given the size and limited operating area associated with the sUAS, an exemption from Part 21 Subpart H would be needed. This meets the requirements of an equivalent level of safety under Part 11 and §333 of the Reform Act. 1l1e Federal Aviation Act (49 U.S.C.§4470 1 (f)) and §333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular sUAS. In all cases, an analysis of these criteria demonstrates that the sUAS operated without an airworthiness certificate in a restricted environment and under the conditions proposed, will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft), operating with an airworthiness certificate without the restrictions and conditions proposed. The sUASs to be operated by Michael J. Mazzone are less than 11 kg (with maximal payload consisting of remote sensing instrumentation), carry no persons, carry no explosive or flammable materials (including combustible fuels), and operate exclusively within a secured area. These enhancements to current safety practices and regulations, which already apply to civil aircraft, provide a greater degree of safety to the public and property owners in comparison to conventional aircraft operations conducted with airworthiness certificates issued under 14 ( 5 )C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no intrinsic credible threat to national security posed by the sUASs, due to their size, speed of operation, location of operation, lack of intrinsic explosive materials or flammable liquid fuels, and inability to carry a substantial external load. 14 C.F.R. §45.23(b) Display of Marks: General 14 C.F.R. §45.23(b) requires that when “the Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited;' "restricted;' "light-sport;' "experimental;' or "provisional;' as applicable.” Even though the sUASs will not have an airworthiness certificate, an exemption may be needed, as the sUASs will have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be placed. Given the size of the sUASs, two-inch lettering will be impossible. An equivalent level of safety will be provided by having the sUASs marked on their fuselage, as required by §45.29(f), where the pilot and others working with the sUASs will see the identification as "Experimental". The FAA has issued the following exemptions to this regulation: Exemptions Nos. 10700, 8738, 10167 and 10167A. 14 C.F.R. §91.7(a): Civil Aircraft Airworthiness 14 C.F.R. §91.7(a) requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the sUAS, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft, the requirements contained in the manual for maintenance, and use of safety check lists prior to each flight, an equivalent level of safety will be provided. 14 C.F.R. §91.9(b)(2): Civil Aircraft Flight Manual 14 C.F.R. §91.9(b)(2) states that “no person may operate a U.S. registered civil aircraft: (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof.” The sUASs, given their size and configuration, have no ability to carry a physical flight manual onboard the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the pilot flying the sUAS will have immediate

( 6 )access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 32827, and 10700. 14 C.F.R. §91.103: Preflight Action 14 C.F.R. §91.103 requires each PIC to take certain actions before flight to ensure the safety of its operation. As FAA approved Rotorcraft Flight Manuals will not be provided for the aircraft, an exemption will be needed. The PIC will take all actions, including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight. 14 C.F.R. §91.105: Flight Crew Members at Stations 14 C.F.R. §91.105 requires that “during takeoff and landing, and while en route, each required flight crew member shall: (1) Be at the crew member station and (2) Keep the safety belt fastened while at the crew member station.” Furthermore, it states that, “each required flight crew member of a U.S.-registered civil aircraft shall, during takeoff and landing, keep his or her shoulder harness fastened while at his or her assigned duty station.” Since the sUASs (which will become U.S. registered aircraft upon Michael J. Mazzone being granted the exemption) are incapable of carrying crew members, an exemption will be needed. Michael J. Mazzone will ensure however that he, the qualified PIC, will maintain a VLOS at all times with the rotorcraft. 14 C.F.R. §91.109: Flight Instruction 14 C.F.R. §91.109 details that “no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction, unless that aircraft has fully functioning dual controls.” sUASs and remotely-piloted aircraft, by their design, do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft, more specifically, Exemption nos. 5778K & 9862A. An equivalent level of safety will be provided with the fact that neither a pilot nor passengers will be carried in the aircraft, and by the smaller size and slower speed of the sUAS. Enhancing this safety is the technology inherent in the remote controls, utilizing digital communications that are paired to the sUAS, making it nearly impossible to unintentionally or intentionally have the control communications interrupted. 14 C.F.R. §91.119: Minimum Safe Altitudes 14 C.F.R. §91.119 establishes safe altitudes for operation of civil aircraft. §91.119(d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the ( 7 )FAA. As this exemption is for a sUAS that closely mimics the behavior of a helicopter, and the exemption requests authority to operate at altitudes up to 400 AGL, an exemption may be needed to allow such operations. As set forth herein, the sUAS will never operate at higher than 400 AGL or beyond unaided VLOS, whichever is closer. It will however be operated in a secure area, where buildings and people will not be exposed to operations without their pre-obtained permission. The equivalent level of safety will be achieved given the size, weight and speed of the sUAS, as well as the location where it is operated. No flight operation will be taken without the permission of the property owner, in the case of private property, or the permission of local officials, in the case of public property or private property with public interests. Because of the advanced notice to the property owner and participants in the remote sensing activity, all affected individuals will be aware of the planned flight operations. Compared to flight operations with aircraft or rotorcraft weighing far more than the maximum 11 kg proposed herein, as well as the lack of flammable fuel, any risk associated with these operations is far less than those thatpresently exist with conventional aircraft operating at or below 500 AGL. In addition, the lowaltitude operations of the sUAS will ensure separation between small sUAS operations and the operations of conventional aircraft that must comply with §91.119. 14 C.F.R. §91. 121 Altimeter Settings 14 C.F.R. §91.121 requires that each person operating an aircraft maintain a cruising altitude by reference to an altimeter that is set “to the elevation of the departure airport or an appropriate altimeter setting available before departure.” As the sUAS does not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator confirming the altitude of the launch site shown on the GPS altitude indicator before flight. The PIC will also ensure effective pairing with multiple GPS sources to guarantee accurate detection of height. 14 C.F.R. §91.15l(b): Fuel Requirements for Flight in VFR Conditions 14 C.F.R. §91.151(b) prohibits an individual from beginning “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.” The shortest life of a battery powering a sUAS operated by Michael J. Mazzone is (15) minutes of powered flight. Consequently, these sUASs will not be able to meet the (20) minute reserve requirement in 14 C.F.R. §91.151(b). Operating the sUAS in a tightly controlled area where only informed persons and property owners or official representatives who have signed waivers will be allowed, having less than (20) minutes of reserve power, does not endanger the type of risks that section 9l.l51(b) was intended to alleviate, given the size and speed of these sUASs. Michael J. Mazzone believes that an equivalent level of safety can be achieved by limiting flights to less than 25% of battery power. This restriction would be more than adequate to return the sUAS to its planned landing zone ( 8 )from anywhere in its limited operating area. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808. 14 C.F.R. §91.203(a) & (b): Civil Aircraft: Certifications Required 14 C.F.R. §91.203 provides in pertinent to parts (a) & (b): “(a) Except as provided in §91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate.” “(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.” Fully loaded, the heaviest sUAS in Michael J. Mazzone’s fleet weighs no more than 11kg and is operated without an onboard pilot. As such, there is no ability or location to carry certification and registration documents or to display them on the sUAS. An equivalent level of safety will be achieved by keeping these documents at the ground control point, where the pilot flying the sUAS will have immediate access to them, to the extent applicable. The FAA has issued numerous exemptions to this regulation. These include Exemption nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. 14 C.F.R. 91.405(a); 407(a)(1); 409(a)(2); 417(a)&(b): Maintenance, Inspections & Records These regulations require that an aircraft operator or owner “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 repaired as prescribed in part 43 of this chapter;” and others shall inspect or maintain the aircraft in compliance with Part 43. Given that this section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to our operation. Maintenance will be accomplished by the operator, pursuant to the flight manual. An equivalent level of safety will be achieved because these sUASs are very limited in size, will carry a small payload, and will operate only in designated areas for limited periods of time. If mechanical issues arise, the sUAS can land immediately and will be operating from no higher than 400 feet AGL. The PIC will, (1) ensure that the sUAS is in working order prior to initiating flight, (2) will perform required maintenance, and (3) will keep a log of any maintenance performed. Moreover, the PIC is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. An exemption granted to Michael J. Mazzone would permit his operation of lightweight, unmanned, remotely controlled, sUASs in a tightly controlled environment. Technical enhancements to current safety controls will allow Michael J. Mazzone to operate exceeding ( 9 )current safety specifications, and stay ahead of, or meet, new safety specifications being implemented by the FAA and Department of Transportation. Furthermore, Michael J. Mazzone conducts his operations in compliance with protocols described herein or as otherwise established by the FAA.

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### Reasons Why This Exemption Will Not Adversely Affect Safety Standards Michael J. Mazzone contends that operation of his sUASs will not “create a hazard to users of the national airspace system or the public”, as stated in 112 P.L. 95 §333(b). Given the diminutive size and weight of Michael J. Mazzone’s sUASs, combined with their operation in cordoned-off and well-controlled areas, Michael J. Mazzone’s sUASs fall within Congress’s contemplated safety zone. They have an established safety record, bolstered by a multi-point preflight checklist. As PIC, Michael J. Mazzone maintains awareness of his surroundings and has intimate knowledge of the behavior of the various sUAS platforms in many weather conditions. This safety record and implemented operational practices demonstrate an awareness of public safety. Michael J. Mazzone’s operations routinely provide a level of safety that at least, and in nearly every instance, exceed, existing rules. Michael J. Mazzone will attain the maximal level of insurance to rectify accidental damage or injury. Michael J. Mazzone does not operate his sUASs on or near airports and will only operate his fleet on private grounds, with cordoned-off areas or areas under the control of the property owner, unless additional authorization has been granted. Michael J. Mazzone determines the areas needed to fulfill the clients’ goals. He only operates his sUASs in these flight zones, and only in compliance with well regarded safety protocols set forth initially by the RC sUAS trade and hobby groups, and recently codified by relevant FARs. Michael J. Mazzone has implemented the following practices to ensure safe operation of his sUASs:

★ Operation by unaided VLOS only ★ Operation in phases 10 minutes in length ★ Operation to minimal 25% battery power ★ Operation of device to GPS aided readout to 400ft at maximum ★ Numerous pre-programmed fail-safes that ensure specific behavior per issue ★ Employ controlled lifecycle management of components to guard against multiple failures ★ Preform a site check day(s) before flight to identify potential issues ★ Subscribe to relevant local weather and safety alerts ★ Expertly choose data collection instruments and accessories to minimize flight requirements or expertise Michael J. Mazzone has experience in similar fields and has adapted this experience in his use of sUASs to increase safety. In combination to the ever expanding knowledge repositories from hobbyists and experts alike, Michael J. Mazzone is constantly evolving his practices when there is a clear benefit to operations or increased safety element.

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### Public Interest Benefits Michael J. Mazzone believes that granting this exemption request furthers the public interest by providing safe (by way of an unmanned system) and efficient means to meet technical problems solvable by elevated data collection instruments. Michael J. Mazzone’s client base is typically small to medium sized business', looking to increase their public awareness through use of photographic and video-graphic presentation. By moving these functions onto sUASs, the potential for loss of life or property is diminished, due to the greater control in a smaller and safer aircraft that holds no persons. Additionally, there are no reactive or combustible materials onboard the sUAS and thus the potential for fire or explosions is greatly diminished. Furthermore, the small size and extreme maneuverability of Michael J. Mazzone’s sUASs allow him to avoid hazards. Lastly, due to the nature of the remote sensing instrumentation onboard, the sUAS can maintain a safe distance between the aircraft and the object(s) undergoing scrutiny. Accordingly, Michael J. Mazzone’s sUASs have operated and will continue to operate at and above current safety levels. The impact to the general public, financial and otherwise, would be extremely minimal. Indeed, it's been demonstrated that sUASs have the ability to drastically increase the information available to policymakers at a fraction of the cost of measuring this data by terrestrial means. One such impact would be inconvenience to directly proximal and non-essential personnel that would be displaced from public or business owned-property if it is deemed to be unsafe. In this case we relay our needs for a flight zone with the requirement that it be safe from casual intrusions and allow the business time to shift operations in order to minimize potential safety issues. This is best performed with the aid of safety personnel that actively steer non-essential persons around the flight zone. The effect of an exemption for Michael J. Mazzone on the quality of the natural and social environments utilizing sUASs, minimizes the requirement for conventional aircraft. This eliminates the need for an onboard pilot, time consuming adherence to regulations surrounding bookkeeping and submission of flight paths to local civilian or military airports, and detrimental effects to the environment caused by operating a combustible fuel based, large scale aircraft, with restrictions on the proximity to the target for remote sensing.

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### Proposed Operations Michael J. Mazzone wishes to provide high quality imaging for a variety of commercial and public uses, specifically targeting:

★ Aerial surveying ★ Aerial video and photography of real estate for landowners, business owners and farmers ★ Aerial video and photography for special events ★ Bridge, flare-stack, pipeline, cell tower, wind turbine, and electrical power line inspections ★ Construction site inspection & monitoring ★ General aerial photography and videography ★ Mosquito & insect control ★ Public entity support operations ★ Search & rescue operations under the authority & support of local authority officials ★ Training to persons individually, or belonging to, both private & public organizations, to increase awareness & improve safety for current & future UAS operations within the NAS ★ Wildlife & forestry monitoring

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### sUASs for Proposed Operations Michael J. Mazzone is seeking an exemption to commercially operate (15) sUAS makes and models, as follows:

★ 1.) DJI - Flame Wheel F450 ★ 2.) DJI - Flame Wheel F550 ★ 3.) DJI - Inspire 1 ★ 4.) DJI - Inspire 1 PRO ★ 5.) DJI - Inspire 2 ★ 6.) DJI - Matrice 100 ★ 7.) DJI - Phantom 1 ★ 8.) DJI - Phantom 2 ★ 9.) DJI - Phantom 2 Vision+ ★ 10.) DJI - Phantom 3 Standard ★ 11.) DJI - Phantom 3 Advanced ★ 12.) DJI - Phantom 3 Professional ★ 13.) DJI - Phantom 4 ★ 14.) DJI - Spreading Wings S900 ★ 15.) DJI - Spreading Wings S1000+

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### Conclusion Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed. Michael J. Mazzone seeks an exemption from the following rules: 14 C.F.R §§ 21; Subpart H, 45.23(b), 91.7(a), 91.9(b)(2), 91.103(b), 91.109, 91.119, 91.121, 91.151(b), 91.203(a) & (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) & (b) to operate commercially, a small unmanned vehicle (11 kg or less) in elevated photographic and remote-sensing operations. Approval of exemptions allowing commercial operations of sUASs will enhance safety, by reducing risk associated with conventional aircraft operations and other means of elevated remote-sensing involving persons. The public benefit, served by approval of this petition, is increased awareness of characteristics of difficult imaging targets. A sUAS weighing 1l kg or less and powered by sealed batteries, eliminates virtually all associated risk inherent in operating conventional aircraft in close proximity to buildings or persons or otherwise elevating persons to a position they would be able to collect needed data. The operation of sUASs, weighing less than 11 kg, conducted in the strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including exempting Michael J. Mazzone from the requirements of Part 21 and allowing commercial operations. The FAA has been given the authority to issue the exemption to Michael J. Mazzone pursuant to the Federal Aviation Act, 85 P.L. 726 (1958), and as such, Michael J. Mazzone humbly seeks your consideration and approval of this petition. Sincerely, 

## Michael J. Mazzone

Michael J. Mazzone

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