### SURPRISE
ARIZONA

U.S. DepartmentofTransportation DocketManagement System 1200NewJersey Avenue, SE Washington,D.C. 20590 November 9, 2015

Re: The City ofSurprise, Arizona Petitionfor Section 333 Exemption

BASIS FORPETITION City Attorney's Office 16000 N. Civic Center Plaza Surprise, AZ 85374

Ph 623-222-1120 Fax: 623-222-1101

Petitioner, the City of Surprise, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) andthe FAAModernization andReform Act of2012 (FMRA), Section 333, SpecialRules for Certain UnmannedAircraftSystems, hereby petitions the Administrator to commercially operate the DJI Inspire 1, in the National Airspace System (NAS), andfor an exemptionfrom therequirements of:
14 C.F.R §§ 61.113(a) & (b) 14 CFR45.23(b) 91.7(a), 91.121, 91.15l(b ), 91.405(a),91.407(a)(l),91.409(a)(l) & (a)(2), and91.417 (a) and (b).

Name and Address ofthe Petitioner The name andaddress ofthe Petitioner andpoint ofcontactis: Jacob Abramson Video Production Coordinator, Surprise 11 The City ofSurprise 16000N. Civic Center Plaza Surprise, AZ 85374 (623) 222-1423 Email:Jacob.abramson@surpriseaz.govU.S. Department ofTransportation November 2, 2015 Page 2

PREFACE The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under §40101 ofthe Act, that includes UAS, from the requirement that all civil aircraft must have a current airworthiness certificate. The Administrator may grant an exemption from a requirement ofaregulationprescribedunder subsection (a) or (b) ofthis section or any sections 44702

- 44716 ofthis title ifthe Administrator finds the exemption in the public interest. 49 U.S.C. §44701(±) See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1).

The City ofSurprise proposes to use an Unmanned Aerial Drones (DJI INSPIRE 1 ), for the following uses:

• Inspections ofcity-ownedroadrights ofway.
• Periodic inspectionsofcity-fundedinfrastructure improvementprojects.
• Evaluations within the city related to flora & fauna (vegetation & wildlife) issues.

• Assist with site security during city-sponsored events (i.e. 4th ofJuly, New Years, parades, etc.)
• Use for aerial photos and video for marketing purposes. This aircraft has four rotors and four motors in a quadcopter configuration. It is only capable ofvertical takeoff and landings. This UAS weighs 6.47 lbs., can fly, under normal conditions at a speed ofno more than 22 meters per second and has the capabilityto hover, and
move inthe vertical andhorizontal plane simultaneously. This UAS is equipped with GPS and auto-return function to the predetermined safe landing area as well as allowing reading ofmagnetic interference that can cause loss offGPS signal. The UAS will operate only in line of sight and will operate only within the limits of public rights ofway or easements. Such operations will be conducted to ensure that the UAS will "not create a hazard to users ofthe national airspace system or the public." (Reform Act Section 333 (b)). This exemption application is expressly submitted to fulfill Congress' goal in passing Section 333(a)through (c) of the Reform Act. This lawdirectsthe Secretary ofTransportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completionoftherule making requiredunder Section 333 ofthe Reform Act. In making this determination, the Secretary is required to determine which types ofUASs do not create a hazard to users ofthe NAS or the public or pose a threat to national security inlight ofthe following:

• TheUAS's size, weight, speed and operational capability;

• Operationofthe UAS inclose proximityto airports andpopulated areas; and

• Operationofthe UAS withinvisual line ofsight ofthe operator.U.S. Department ofTransportation November 2, 2015 Page 3

Reform Act§ 333 (a). Secretary determines that such vehicles "may operate safely in the national airspace system, the Secretary shall establishrequirements for the safe operation of such aircraft inthe national airspace system." Id. § 3 3 3(c). The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under §40101 ofthe Act, that includes UAS, from the requirement that all civil aircraft must have a currentairworthiness certificate. The Administrator may grant an exemption from a requirement of a regulation prescribedunder subsection (a) or (b) ofthis section or any sections 44702- 44716 ofthis title iftheAdministrator finds the exemption inthe public interest. 49 U.S.C. §4470l(f) See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1).

RELIEF OVERVIEW Given the small size ofthe UAS involved and the restricted environment within which they will operate, the applicant falls squarely within that zone ofsafety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of UASs to commence immediately. Also due to the size of the UASs and the restricted areas inwhich the relevant UAS will operate, approval ofthe application presents no national securityissue.

Given the clear direction in Section 333 ofthe Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing UASs for aerial inspections, surveying, photography and videography, the grant ofthe requested exemptions is in the public interest. Accordingly, the applicant respectfully requests that the FAA grant the requested exemption.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The City ofSurprise proposes thatthe exemptionrequested herein applyto civil aircraft thathave the characteristics and that operate with the limitations listedherein. These limitations provide for at least an equivalent or even higher level ofsafety to operations under the current regulatory structure because the proposed operations represent a safety enhancement to the already safe aerial inspections, surveying and photography and videography operations conductedwithconventionalaircraft. These limitations and conditions to whichthe City ofSurprise agrees to be bound when conducting commercial operationsunder anFAAissuedexemptioninclude: 1. The UAS will weighlessthan55lbs. 2. Flights will be operated within line ofsight ofa Pilot-In Command (PIC) and aU.S. Department ofTransportation November2, 2015 Page4

Safety Observer (SO). 3. Maximum total flight time for each operational flight will be 30 minutes or less. Flights will be terminated at 25% battery power reserve should that occur prior to the 30 minute limit. 4. Flights will be operated at an altitude ofno more than 400 feet AGL or, notmore than 200 feet above an elevated platformfor whichfilming is planned. 5. Minimum crew for each operation will consist ofthe UAS Pilot and one Visual Observer. 6. The UAS will only operate within the defined project area, the boundaries of which will be determined by the UAS Pilot-In-Command (PIC) based on the site-specific activities and speed of the UAS required for the operation, and coordinated withthejurisdictional FAA FSDO and local government officials as applicable. 7. A briefing will be conducted in regards to the planned UAS operations prior to each day's operation. It will be mandatory that all personnel who will be performing duties within the boundaries of the project be present for this briefing. 8. The UAS Pilot and Safety Observer will be able to communicate by voice and/or two wayradio communication system at all times. 9. The operationsofthe UAS will be limitedto daylight-only operations. 10. Ifthe UAS loses communications or loses its GPS signal, the UAS will have the capability to return to a pre- determined location within the Project Perimeter and land safely. 11. The UAS will have the capability to abort flight in case ofunpredicted obstacles
oremergencies. 14 C.P.R. Part21, SubpartH: Airworthiness Certificates 14 C.P.R. §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized bythe Applicant, an exemption from Part 21 Subpart H meets the requirements ofan equivalent level ofsafety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 ofthe Reform Actboth authorize the FAAto 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 ofthe particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the 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 therestrictions and conditionsproposed. Inconsideration ofthe speed, weight, size, and limited operating areaassociated withthe unmanned aircraft and its operation, the City of Surprise's operation of DJI Inspire 1, UASU.S. Department ofTransportation November 2, 2015 Page 5

meets the conditions ofFMRA Section 333 and therefore, will not require an airworthiness certificatein accordance with 14 C.F.R. Part21, SubpartH. Accordingly, the City ofSurprise requests relieffrom Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate. The City of Surprise submits that the requested reliefis proper since an equivalent level ofsafety will be ensured. The City of Surprise will use experienced personnel or technicians as needed to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, the City of Surprise will document and maintain all maintenancerecords for the DJI Inspire 1UAS. Relief from certain requirements of Section 61.113(a) and (b), entitled Privatepilotprivileges andlimitations: Pilot in command, is requested by the City ofSurprise to the extent necessary to allow a Pilot in Command (PIC) meet or exceed the described requirements ofoperations setby manufacturer, and who has demonstrated, that the PIC is able to safely operate the DJI Inspire 1 UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. The City of Surprise seeks relief from Section 91.7(a), entitled Civil aircraftairworthiness, because the DJI Inspire 1 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, the City of Surprise submitsthat itwill ensure thatthe DJI Inspire 1UAS is in an airworthy condition, priorto every flight, by determining that the UASs are in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1Instruction Manual), and that the aircraft are in a conditionfor safe flight. The City ofSurprise also seeks an exemption from the requirements ofSection 91.121, entitled AltimeterSettings, as the DJI Inspire 1 will not have a typical barometric altimeter onboard. However, altitude information ofthe DJI Inspire 1 will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the ground control system (GCS) for active monitoring ofthe flight path. This altitude information, combinedwiththe City ofSurprise's operation ofthe DJI Inspire 1 UAS within visual line of sight, at or below 400 feet AGL, will ensure a level of safetyequivalentto Section91.121. Additionally, the City ofSurprise seeks an exemption from the requirements ofSection 91.151(b), entitled Fuel requirements forflight in VFR conditions. The City of Surprise submitsthat safety will notbe affectedby operation ofthe DJI Inspire 1during daylighthours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration of approximately 30 minutes to the first point of intended landing.U.S. Department ofTransportation November 2, 2015 Page 6

EXTENT AND REASONINGWHYTHE CITY OF SURPRISE SEEKS RELIEF FROM THE LISTED SECTIONS ABOVE 1. Section 61.113(a) & b). Relief from Section 61.113(a) and (b) entitled Privatepilotprivileges andlimitations: Pilot in command, is requested to the extent necessary to allow a PIC meet all requirements as described in the DJI Inspire 1 owner's manual to conductthe proposedUAS flight operationsfor compensationor hire. This reliefis requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC ofan aircraft in connection with any business or employmentif: (1) The flight is only incidentalto that business or employment; and (2) The aircraftdoes notcarrypassengers orproperty for compensation orhire. As set forth more fully below, the City ofSurprise submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the DJI Inspire 1 UAS unless that PIC has demonstrated that the PIC is able to safely operate either the DJI Inspire 1 UAS in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures. Further, the City of Surprise submits that all flights of the DJI Inspire 1 1 UAS, conducted by the PIC pursuantto the grant ofthis Petition: (1) will be incidental to the City of Surprise 'sbusiness; and (2) will not carry passengers orpropertyfor compensationorhire. 2. Section 91.7(a). Relief from Section 91.7(a) entitled Civil aircraftairworthiness, is requested to the extent required to allow the City of Surprise to determine that the DJI Inspire 1 UASs are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., the City ofSurprise Operations Manual, Monthly Maintenance Log, and DJI Inspire 1InstructionManual). The City ofSurprise seeks the requested reliefbecause the DJI Inspire 1 UAS does not require an airworthiness certificate in accordance with 14 C.P.R. Part 21, Subpart H. Therefore, the City of Surprise will ensure that the DJI Inspire 1 UAS are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1Instruction Manual) prior to every flight, and further, determine thatthe aircraft are in conditionfor safe flight, as statedinthe conditions and limitations below. 3. Section 91.121. Relieffrom Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the DJI Inspire 1 UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), the City of Surprise seeks the requested relief because the DJIU.S. Department ofTransportation November 2, 2015 Page 7

Inspire 1 UA altimeter may be set on the ground to zero feet AGL, rather than the local barometricpressure orfield altitude, before eachflight. Consideringthe limited altitude ofthe proposed operations,relieffrom 14 CPR91.121 is sought to the extent necessary to comply with the applicable conditions and limitations stated below. As more fully set forth herein, an equivalentlevel ofsafety will be maintained since the DJI Inspire 1 UAS are equipped with a barometric pressure sensor and GPS equipment, which automatically ensuresthata ground level pressure settingwill be establishedpriorto eachflight, andprovidesthe PIC with altitude information ofthe UAonthe heads-up display ofthe GCS. 4. Section91.151(b). Relieffrom Section91.151(b) entitledFuelrequirements for flight inVFRconditions, is requestedto the extent requiredto allow flights ofthe batterypowered DJI Inspire 1UA during daylighthours invisualmeteorological conditions (VMC), undervisual flight rules (VFR), for a total duration of30 minutes to the first point ofintended landing and, assuming normal cruising speed. The City of Surprise seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered DJI Inspire 1 UA will severely constrainthepracticality ofany aerial video or still photo flight operations thatthe City ofSurprise proposes to conductpursuantto this Petition. Significantly, as set forth below, the technical specifications ofthe DJI Inspire 1 UAS, the DJI Inspire 1 operating documents, and the City of Surprise 's proposed operating limitations, ensure that the City ofSurprise will safely operate the battery powered DJI Inspire 1 UA during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enoughbatterypowerto fly for atotal duration of 15 minutesto the first point ofintendedlanding and, assumingnormal cruising speed, to fly afterthatfor at least 3minutes.
5. 14 CFR45.23(b). Marking ofthe Aircraft. Applicable codes ofFederal Regulation require aircraft to be marked according to certain specifications. UAV Field Services UASs are, by definition, unmanned. They therefore do not have a cabin, cockpit or pilot station on which to mark certain words orphrases. Further, two inch lettering is difficult to place on such small aircraft. Regardless, UAV Field Services will mark its UAS in the largest possible lettering by placing the "N" number on its fuselage as required by 14 CFR 45.29 (f) so that the pilot, technician, spotter and others working with the UAV will see the markings. The FAA has previously issued exemptions to this regulationthroughExemptionNo. 10167 and 10700.
6. Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Since Sections 91.405(a), 91.407(a)(l), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only applyto aircraft with an airworthiness certificate, the City ofSurprise requests relieffrom these Sections because the DJI Inspire 1UAS do not require airworthiness certificates. As set forth
more fully below, the DJI Inspire 1 UAS meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordinglythe City ofSurprise will use trained technicians to perform maintenance, alterations, or preventive maintenance onthe UASs usingU.S. DepartmentofTransportation November 2, 2015 Page 8

the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the City of Surprise aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, the City of Surprise will document and maintain all maintenance records for the DJI Inspire 1UAS. The reasons for grantingthis request are entirelybeneficialto the public and community as awhole. Granting the present Petition will further the public interest by allowing the City of Surprise to safely, efficiently, and economicallyperfmm aerial video and photographic surveys and inspections ofconstruction sites, rights ofway, utility easements, and other sites withinthe City ofSurprise, Arizona. This exemption application is expressly submitted to fulfill Congress' goal in passing Section 333(a) through (c) of the Reform Act. This law directs the Secretary ofTransportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion ofthe rulemaking required under Section 332 ofthe Reform Act. Inmakingthis determination, the Secretary is requiredto determine whichtypes of UAS do not create a hazard to users ofthe NAS or the public or pose a threat to national securityin lightofthe following:

• The UAS's size, weight, speed and operational capability;

• OperationoftheUAS incloseproximityto airports and populated areas; and

• Operationofthe UAS withinvisual line ofsight ofthe operator.
Reform Act§ 333 (a). Lastly, the Secretary determines that such vehicles "may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operationofsuch aircraft inthe national airspace system." Id. §333(c).

Given the small size ofthe UAS involved and the restricted sterile environment within which they will operate, the applicant falls squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations ofUASs to commence immediately. Also due to the size ofthe UASs and the restricted areas in which the relevant UAS will operate, approval ofthe application presents no national security issue. Giventhe clear direction in Section 333 ofthe Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing UASs for movie and television operations, the grant ofthe requested exemptions is inthe public interest. Accordingly, the applicant respectfully requests that the FAA grant the requested exemptionwithoutdelay.

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U.S. Department ofTransportation November 2, 2015 Page 9

REASONS BENEFICIAL TO THE PUBLIC/COMMUNITY 1. The PublicWill Benefitfrom Decreased CongestionoftheNAS. The DJI Inspire 1 UAS are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount ofmanned aircraft needed to perform aerial acquisitions, an exemption allowing the use ofa DJI Inspire 1 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety oflife and property inthe air and onthe ground. Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The DJI Inspire 1 UA does not require an airport to takeoffor land. Likewise, a reduction ofmanned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handled by airtraffic control during the ground, takeoff, departure, arrival, and landing phases offlight operations. 2. The Public Will BenefitFrom The Safety And Efficiency OfThe DJI Inspire 1UAS. Conducting aerial acquisitions with the DJI Inspire 1 UAS, instead ofmanned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, the DJI Inspire 1 UAS produces 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 ofleaded aviation fuel. The DJI Inspire 1 UA, while reducing the carbon footprint ofaerial acquisitions, also eliminates noisepollution, as the UAs are propelled by battery powered electric motors, rather than an internal combustion engine.By using the DJI Inspire 1UAS to perform aerial observation, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantiallyreduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI Inspire 1 UA (weighing approximately 6pounds 5 ounces, attheirmaximum gross weights with awingspan of36 inches, and with no fuel onboard), has less physicalpotential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan ofapproximately 42 feet, a length of34feet, and afuel capacity of 180 gallons). 3. Performing Aerial Video and Photography, Surveys and Inspections, Operations with the DJI Inspire 1UAS Will Benefitthe Economy.
In addition to being safe and efficient, the DJI Inspire 1 UAS are also provides an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation ofthe DJI Inspire 1 UAS will allow the City ofSurprise, to provide quality services to the residents and businesses ofthe City and the Region at minimum costs. Specifically, with the rising cost ofaviation fuel and the Environmental Protection Agency ("EPA") regulatoryU.S. Department ofTransportation November 2, 2015 Page 10

actionsphasing outleaded aviationfuels, agencies must adopt newand alternative technology in continue to provide required services at reasonable costs. Operating the battery powered DJI Inspire 1 UAS is one such technology that not only allows agencies and companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational costofatraditional manned aircraft. By operating the DJI Inspire 1 UAS, the City of Surprise can maintain and hopefully improve our ability to operate and maintain critical infrastructure and at the same time collect important data for further development ofsystem-wide modeling ofwater, water, stormwater and roadway systems as well as provide accurate and current data related to environmental issues such as groundcover, vegetation & wildlife habitats. 4. There Are No Privacy Issues. Similarto the manned aerial acquisition flight operations that have been conducted for decades, the City of Surprise's proposed operation of the DJI Inspire 1 UAS will not implicate any privacy issues. Specifically, the DJI Inspire 1 UAS will be operated only in compliance with operating documents (i.e., the City of Surprise Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual) which requires property owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, includingthe maximum altitude limitations as perthe requirements of 14 C.F.R. §91.119.

THE REASONS WHY 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 THE CITY OF SURPRISE SEEKS EXEMPTION. 1. Reasons why the DJI Inspire 1 UA Meet the Conditions ofthe FAA Modernization and Reform Actof2012 (FMRA) Section 333. Inconsideration ofthe size, weight, speed, and limited operating area associated withthe unmanned aircraft and its operation, the City ofSurprise's operation ofthe DJI Inspire 1UAS meet the conditions ofFMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part21, SubpartH. In seeking this exemption, the City ofSurprise submits that the DJI Inspire 1UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI Inspire 1 UAS; (b) the pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications oftheDJI Inspire 1UAS DemonstrateIts Safe Characteristics. The DJI Inspire 1UAS do not create ahazardto users ofthe NAS orthepublic,
or otherwise pose a threat to national security considering its size, weight, speed, and operational capability.

1. Technical Specifications ofthe DJI Inspire 1UAS.

### U.S. Department ofTransportation November 2, 2015 Page 11

The technical specifications ofthe DJI Inspire 1 UAS are set forth by the DJI Inspire 1 Specifications andData Sheetattached. The DJI Inspire 1 UAS Autonomous Flight and Navigation Modes Enable the UAS to Remain WithinaDefined OperationalArea.
The DJI Inspire 1 UAS may be operated in both manual and fully autonomous flight modes. A complete description ofthe flight and navigational modes ofthe DJI Inspire 1UAS are included inthe UserManuals.
ii. The DJI Inspire 1 UASs Are Designed For Automatic Return To Horne Point Or 

### Hover In The Event Of Loss Of The Control Link Or Navigation. When the Control Link is lost, the DJI Inspire 1 UA will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Inspire 1UA does notreacquire control link datafrom the GCS, the UAs will assume that the Control Link is lost and the UAs will return to the horne position (i.e., failsafe mode) via GPS, and will descend to the takeoffpositionand shutdown. A complete description ofthe Failsafe Functions ofthe DJI Inspire 1UA
are setforth inthe DJI Inspire 1UserManual, attached.

111. 

### The DJI Inspire 1GCS AndIts Operation. A complete description ofthe operation and specifications ofthe DJI Inspire 1GCS and flight control software is provided inthe DJI Inspire 1 UserManual. b. Flights ofDJI Inspire 1 UAS Will be Conducted Pursuant to Specific Operating Limitations. In seekingthis exemption, the City ofSurprise proposes to commercially operate DJI Inspire 1 UAS for the special purpose of conducting aerial video and photography over certain areas of United States, pursuant to the following specific operating limitations: 1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: DJI Inspire 1Unmanned Aircraft Systems. Proposed operations ofany other aircraft will require a new petitionor apetitionto amendthis grant. 2. UAS operations under this exemption will be limited to conducting operations for thepurpose ofaerial video andphotography. 3. The UA may notbe flown at an indicated airspeed exceeding 30 knots. 4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL), as indicated by the procedures specified in the operatingU.S. Department ofTransportation November 2, 2015 Page 12

documents unless a special request is made and approved by ATC. All altitudes reported to ATC mustbe infeet AGL. 5. The UAs must be operated within visual line ofsight (VLOS) ofthe PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified onthe PIC's FAA-issuedairman medical certificate. 6. The use offirst person view camera to satisfY the visual line ofsite by the PIC or safety observer (SO) is notpermitted. 7. All operations must utilize a safety observer (SO). The SO may be used to satisfY the VLOS requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the SO can perform the functions prescribed inthe operating documents. 8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is notpermittedto operate the cameraor other instruments. 9. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. Ifa discrepancy exists betweenthe conditions and limitations contained inthe grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant ofexemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator's responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents ifit petitions for extension or amendment to the grant ofexemption. Ifthe operator determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its grant ofexemption. The FAA's UAS Integration Office (AFS-80) may be contacted ifquestions arise regarding updates
orrevisions 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. Ifthe inspection reveals a condition that affects the safe operation ofthe UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraftrecords. 11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement ofa flight critical component,U.S. Department ofTransportation November 2, 2015 Page 13

must undergo a functional test flight. The PIC who conducts the functional test flight mustmake an entry inthe aircraftrecords. 12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections ofthe operating documents. 13. The operator must follow the UAS manufacturer's aircraft/component, maintenance, overhaul, replacement, inspection, and life limitrequirements. 14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status ofreplacement/overhaul component parts must be noted inthe aircraft records, including total time in service, description ofwork accomplished, and the signature ofthe authorized person returning the UAS to service. 15. Each UASs operated underthis exemption must comply with all manufacturer SafetyBulletins. 16. The authorized person must make an entry in the aircraft record of the corrective actiontaken againstdiscrepancies discoveredbetweeninspections. 17. The PIC must meet or exceed all requirements as set forth by manufacturer in order to justifiably operate the DJI Inspire 1, or hold an equivalent pilot license approvedbytheFAA. 18. The operator may not permit any PIC to operate unless the PIC meets the operator's qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes oftraining the operator's PICs are permitted under the terms 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 operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.P.R.§ 91.119. 19. UAS operations may notbe conducted during night, as defined in 14 C.P.R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Ifflight at night is required, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized. 20. The UA may not operate within 5 nautical miles ofan airport reference point
as denoted on a current FAA-published aeronautical chart unless a letter of agreement with that airport's management is obtained, and the operation is conducted in accordance with a NOT AM as required by the operator's COA. The

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U.S. Department ofTransportation November 2, 2015 Page 14

letter of agreement with the airport management must be made available to the Administratoruponrequest. 21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 22. Ifthe UAloses communications or loses its GPS signal, itmustreturnto apredetermined location within the planned operating area and land or be recovered in accordance withthe operating documents. 23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance withthe operating documents. 24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enoughpowerto fly at normal cruising speed tothe intended landing point and land the UA with25% batterypowerremaining. 25. The operator must obtain an AirTraffic Organization (ATO) issued Certificate ofWaiver or Authorization (COA) prior to conducting any operations under the grant ofexemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class ofairspace, altitude level andpotential transponderrequirements. 26. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (N-Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings mustbe as large as practicable. 27. Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 28. The UA must remain clear and yield the right ofway to all manned aviation operations and activities at all times. 29. The UAS maynotbe operatedbythe PIC from any moving device orvehicle. 30. All operations shall be conducted over publicly owned or controlled property. Any operation over privately owned property would require permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted. 31. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries ofthe operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB)

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per instructions contained onthe NTSB Web site: www.ntsb.gov.

The City of Surprise affirms all information listed above to be true and binding upon FAA's findings of exemption regarding commercial operations of listed UAS, until further notice of laws or regulations decided by the government/FAA. Thank you for your consideration.

yours,

acob Abramson Video Production Coordinator, Surprise 11



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