IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Z

- DRONES , LLC.

FOR AN EXEMPTION SEEKING RELIEF F ROM THE REQUIREMENTS OF TITLE 12 OF THE CODE OF FEDERAL REGULATIONS SECTIONS: CONCERNING COMMERCIAL OPERATION OF THE: DJI INSPIRE 1 DJI S1000 PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)

Z

- DRONES,	LLC. JEFFREY	ZITA PO	BOX	2636 DOUGLAS , MI 49406 Tel:	(630)

- 707

- 4598BACKGROUND INFORMATION

Z

- DRONES , LLC. is in the business of consultation and pilot contracting, unmann ed aircraft operations.

Z

- DRONES seeks an exemption to operate several sUAS, listed below, for compensation or hire within the National Airspace System (“NAS”). The proposed aircraft all include vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) and tr ansportable Ground Control Stations (GCS). Regulatory exemptions laid out in this petition would allow Z

- DRONES to provide aerial photography and cinematography services, utilizing UA, for private and commercial interests in the United States.

AIRCRAFT MODELS INCLUDED IN THIS PETITION

1. DJI Inspire 1 2. DJI S1000

REGULATORY BASIS FOR PETITION
Pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012, Section 333, Special Rules for Certain Unmanned Aircraft Systems
, Z

- DRONES hereby petitions the Administrator to operate sUAS in the NAS, and for an exemp tion from the requirements of 14 C.F.R §§ 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).
In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, Z

- DRONES ’s operation of the listed UAS meets the conditions of Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.
Accordingly, Z

- DRONES requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate.

Z

- DRONES submits that the requested relief is proper since an equivalent level of safety will be ensured. Z

- DRONES will perform maintenance, alterations, or preve ntive maintenance on the UAS as prescribed by the manufacturers’ maintenance documentation where applicable, or by returning the aircraft to its manufacturer when operator maintenance is not recommended. Furthermore, Z

- DRONES will document and maintain all main tenance records for the aircraft used in the requested operations

.

Z

- DRONES seeks relief from Sec tion 91.7(a), entitled Civil aircraft airworthiness , because the selected sUAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Z

- DRONES submits that it will ensure that the unmanned aircraft are in an airwor thy condition prior to every flight, by determining that the UAS are in compliance with theapplicable UAS Operator and Maintenance Manuals, and that the UA are in condition for safe flight.

Z

- DRONES also seeks an exemption from the requirements of Section 91. 121, entitled Altimeter Settings , as the proposed UAS are equipped with a barometer and Global Positioning System (GPS) equipment, which ensures that a ground level pressure setting will be established prior to each flight. The UA barometer and GPS equipment ensure safety by providing the PIC with adequate information concerning altitude of the UA, above ground level (AGL), as shown on the heads

- up display of the GCS.
Additionally, Z

- DRONES seeks an exemption from the requirements of Section 91.151(b), Fuel requirements for flight in VFR conditions

. Z

- DRONES submits that safety will not be affected because flights will be terminated at or before battery levels which are recommended by the OEM for safe operation.

In accordance with 14 C.F.R. § 11.81, Z

- DRONES provides the following information in support of its petition for exemption:

A . The Specific Sections of 1 4 C.F.R. From Which Z

- DRONES Seeks Exemption.

1

. Z

- DRONES Seeks Exemption From The Requirements Of Section 91.7(a).

Section 91.7, entitled Civil airc raft airworthiness , subsection (a), states the following: (a) No person may operate a civil aircraft unless it is in an airworthy condition.

2

. Z

- DRONES Seeks Exemption From The Requirements Of Section 91.121.

Section 91.121, entitled Altimeter settings , subs ection (a), states the following, in relevant part:
(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

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

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

curr ent reported altimeter setting of an appropriate available station; or
(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure;

3

. Z

- DRONES Seeks Exempti on from The Requirements o f Section 91.151(b).Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states the following:
(b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.

4

. Z

- DRONES Seeks Exemption From The Requirement Of Section 91.405(a).

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

— (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.]

5

. Z

- DRONES Seeks Exemption From The Requirements Of Section 91.407(a)(1).

Section 9 1.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration , subsection (a)(1), states the following:
(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alterati on unless

-- (1) It has been approved for return to service by a person authorized under § 43.7 of this chapter[.]

6

. Z

- DRONES Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2).

Section 91.409, entitled Inspections , subsection (a ), states the following: (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft
unless, within the preceding 12 c alendar months, it has had

-- (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by § 43.7 of this chapter; or
(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.

Z

- DRONES Proprietary	&	Competition	Sensitive.	File	Securely.	Page 9 of 32

7

. Z

- DRONES Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b).Section 91.417, entitled Maintenance records , subsections (a) and (b), state the following:
(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section:
(1) Records of the maintenance, preventive ma intenance, and alteration and records of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include

-- (i) A description (or reference to data acceptable to the Administrator) of the work performed; and
(ii) The date of completion of the work performed; and
(iii) The signature, and certificate number of the person approving the aircraft fo r return to service.
(2) Records containing the following information:
(i) The total time in service of the airframe, each engine, each propeller, and each rotor.
(ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance.
(iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis.
(iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained.
(v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or saf ety

Z

- DRONES Proprietary	&	Competition	Sensitive.	File	Securely.	Page 10 of 32
directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required.
(vi) Copies of the forms prescribe d by § 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances.
(b) The owner or operator shall retain the following records for the periods prescribed:(1) The records specifi ed in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed.
(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold.
(3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.

B . The Ex tent Of Relief Z

- DRONES Seeks And The Reason Z

- DRONES Seeks The Relief.

1 . Extent of Relief Z

- DRONES Seeks And The Reason Z

- DRONES Seeks Relief From Section 91.7(a).
Relief from Section 91.7(a), entitled Civil aircraft airworthiness, is requested to the extent required to allow Z

- DRONES to determine that the operations UAS is in an airworthy condition prior to every flight by ensuring that the UAS is in compliance with the applicable operations and maintenance manuals, and that the UA is in condition for safe flight. Copies of the Inspire 1 and S1000 operator’s manuals are attached as exhibits A and B.

Z

- DRONES seeks the requested relief because the proposed sUAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Z

DRONES will ensure that the sUAS is i n an airworthy condition based upon its compliance with the operating documents prior to every flight, and as stated in the conditions and limitations below.

2 . Extent of Relief Z

- DRONES Seeks And The Reason Z

- DRONES Seeks Relief From Section 91.121.

Relief from S ection 91.121, entitled Altimeter settings, may be required to allow flight operations of the proposed UAS, which utilize barometer and GPS equipment, to ensure that a ground level pressure setting will be established prior to each flight, and in order to report altitude to the PIC. Z

- DRONES seeks the requested relief because the proposed UAS do not utilize a typical barometric altimeter that may be set as contemplated by Section 91.121. As more fully set forth below, an equivalent level of safety will be mainta ined since the sUAS are equipped with a barometer and GPS equipment, which will ensure that a ground level pressure setting will be established prior to each flight, and provides the PIC with altitude information of the UA, above ground level (AGL), on the heads

- up display of the ground control station (GCS).

3 . Extent Of Relief Z

- DRONES Seeks And The Reason Z

- DRONES Seeks Relief From Section 91.151(b).
Relief from Section 91.151(b), entitled Fu el Requirements for flight in VFR conditions, is requested to the extent required to allow flights of the battery powered UA, during daylight hours in visual meteorological conditions under visual flight rules (VFR), to continue for a total duration not gr eater than that recommended by the manufacturer for safe operation. Z

- DRONESseeks the requested relief, because without an exemption from Section 91.151(b), the flight time duration of the battery powered UA will severely constrain the practicality of any aeri al photography operations which Z

- DRONES proposes to conduct pursuant to this Petition.

4 . Extent Of Relief Z

- DRONES Seeks And The Reason Z

- DRONES Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b).
Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, Z

- DRONES requests relief from these Sections because the UAS do not require an airworthiness certificate. As set forth more fully below, the selec ted UAS meet the conditions of Section 333 of the FMRA for operation without an airworthiness certificate. Accordingly, Z

- DRONES will perform maintenance, alterations, or preventive maintenance on the UAS as prescribed by the manufacturers’ maintenance document ation where applicable, or by returning the aircraft to its manufacturer when operator maintenance is not recommended.

C . Reasons Why Granting Z

- DRONES ’s Request Would Be In The Public Interest; That Is, How It Would Benefit The Public As A Whole.
Granting the present Petition will further the public interest by allowing Z

- DRONES to safely, efficiently, and economically perform commercial aerial photography and cinematography. Additionally, our services will aid in increasing safety and proper operating procedures for these aircraft both in commercial and private markets to reduce risk and potential accid ents. Notably, the benefits of Z

- DRONES ’s proposed operations of the listed UAS will be realized without implicating any privacy issues.

1. The Public Will Benefit From The Aerial Photography And Cinematography.

Z

- DRONES ’s photography and cinematography program will provide safe, efficient, and economical imaging to the public. The exemption process under FMRA section 333 allows the FAA to hand pick the safest operators to spearhead the UAS serv ice market in the United States, which increases the safety for the public as a whole. This petition and its supporting documents prove Z

- DRONES to be exactly the type of operator the FAA should wish to proliferate based on its dual mandate to increase safety a nd economic prosperity. Z

- DRONES has empirically proven itself to be safer than many other UAS operators, and UAS in general pose a much smaller risk to the public than manned, combustion engine aircraft generally used for aerial photography. To utilize an anal ogy from microeconomics, granting this petition will increase the supply of safe, lawful aerial photography operators in the United States, which will drive down the demand for and use of less safe manned aircraft operators or illegal UAS operators.

Aeria l imaging which uses UA is inherently cheaper than operations which rely on manned aircraft, meaning that Z

- DRONES will be able to provide the same services to the general public at a tremendous discount. This will create an economic benefit for the public, in addition to the safety benefit.Finally, the exemptions granted by this petition would allow Z

- DRONES to operate as an aid to law enforcement agencies, search and rescue operations, and accident investigation efforts. Z

DRONES will provide timely strategic and inve stigative information to these operations, which could help save lives and reduce property losses. Granting the specified exemptions will provide not only safety and economic benefit to the public, but also an increased effectiveness of pre

existing publi c services.

2. The Public Will Benefit From Decreased Congestion Of The NAS.

The DJI Inspire 1 and S1000 serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized in many commercial industries. By reducing the amount of manned aircraft needed, an exemption allowing the use of these aircraft would reduce the 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.
Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced . These aircraft do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting commercial operations would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arriv al, and landing phases of flight operations.

3. The Public Will Benefit From The Safety And Efficiency Of These Aircraft.
Conducting commercial ope rations with the DJI Inspire 1 and S1000, instead of manned aircraft, will greatly b enefit the public by drastically reducing the levels of air and noise pollution generated during traditional commercial aviation operations. All models use only battery power and electric motors. These aircraft produce no air pollution, and are the most vi able environmentally conscious alternative to cabin class, internal combustion aircraft that are typically utilized in commercial operations. SUAS also reduce noise pollution, as the electric motors produce far less noise.
By using these aircraft to perfo rm commercial aerial operations, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, these aircraft all weigh less than 55 pounds at their maximum gross weight, and therefore have less physical potential for collateral damage to life and property on the ground, and in the air, compa red to typical manned aircraft.

4. There Are No Privacy Issues.
Similar to manned commercial operations that have been conducted for decades, Z

- DRONES ’s proposed operations will not implicate any privacy issues. Specifically, these aircraft will be operated only in rural areas and in accordance with all Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. 91.119. Most significantly, these aircraft will not be operated closer than 500 feet to any person, vessel, vehic le, or structure, which is not directly involved in the operations. Privacy and safety of any persons in the vicinity of operationsare of great importance to Z

- DRONES and Z

- DRONES will comply with all local, state and federal laws applicable to the safety and priva cy of people in the vicinity of sUAS
operations. Unless required to safely return the aircraft in an emergency situation, aircraft visual sensors will not focus on anything but Z

- DRONES ’s a ssets, and if any images or video of non

- Z

DRONES assets is accidentally captured, the data will be immediately erased from the UAS camera, sensors, ground stations etc. at the local landing site.

D . The Reasons Why Granting The Exemption Would Not Adversely A ffect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which Z

- DRONES Seeks Exemption.
1. Reasons Why The DJI Inspire 1, DJI S1000 UAS Meet The Conditions Of The FAA Modernizat ion and Reform Act of 2012 (FMRA) Section 333.
In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and their operation, Z

- DRONES ’s operations of the DJI Inspire 1 and DJI S1000 UAS m eet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.
Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part:
(a) In General.

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

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

-- (1) Which type s of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system o r the public or pose a threat to national security; and
(2) Whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 4 9, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1).
(c) Requirements for Safe Operation.

-- If the Secretary determines under this section that certain unmanned aircraft systems may operate safel y in the national airspace system, the Secretary shallestablish requirements for the safe operation of such aircraft systems in the national airspace system.
In seeking this exemption, Z

- DRONES submits that the included UAS can operate safely in the NAS pursu ant to FMRA Section 333, as demonstrated by: (a) the characteristics of these UAS; (b) the pilot certification requirement; and (c) the specific operating limitations.
Copies of the Inspire 1 and S1000 ’ s operator’s manuals are attached as exhibits A and B. The

2 . Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety.
The level of safety establ ished by Section 91.7(a) will be maintained because prior to every flight, Z

- DRONES will ensure that the UAS is in an airworthy condition and safe for flight based upon the UAS’s compliance with its operating documents and as stated in the conditions and limita tions herein.
Additionally, the FAA has previously granted relief from Section 91.7(a), specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11 109, 11110, 11112, 11136, 11138).

3 . Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety.
The equivalent level of safety established by Section 91.121 will be maintained because the UAS is equipped with a digitally encoded barometric altimeter and GPS triangulation equipment, with a zero altitude initiation point being established prior to each flight. As such, the PIC on the UAS is provided the altitude of the UA above ground level ( AGL) via a heads

- up display of the ground control station (GCS). The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 110 64, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138).

4 . Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely Affect Safety.
A grant of this exemption would ensure the equivalent level of safety established by 14 C.F.R. Section 91.151(b) because the operator will always have detailed information on the charge and state of the battery, and preset battery failsafe’s will prevent any loss of flight control due to power loss. Furthermore, previous exemptions granted b y the FAA concerning Section 91.151(b) establish that safety is not adversely affected when the technical characteristics and operating limitations of a UAS are considered.
The ground control station (GCS) provides a battery indicator on the heads

- up disp lay, which indicates the UA’s current remaining battery power measured in volts, and thus provides the PIC with constant awareness of the real

- time battery voltage during a flight.Spe cific details on battery failsafes can be found in the Inspire 1 and S1000 operator’s manuals, which are attached as exhibits A and B.

Likewise, as set forth above, Z

- DRONES has p roposed specific operating limitations in this Petition that will maintain the equivalent level of safety established by Section 91.151(b), including the following: (1) the UA will only be operated during daylight hours (i.e. between the end of morning civ il twilight and the beginning of evening civil twilight, as published in the American Air Almanac, converted to local time); (2) The UA will only be operated pursuant to visual flight rules (VFR) in visual meteorological conditions (VMC); and (3) the durat ion of each flight shall not exceed the maximum time or battery charge level recommended by the manufacturer for safe operations.
Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affect ed when the technical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreov er, the FAA has previously granted relief from Section 91.151, specific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11 109, 11110, 11136, 11138).

5 . Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety.
In seeking this exemption, Z

- DRONES submits that an equivalent leve l of safety with regard to the regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because Z

- DRONES and the manufacturers of each aircraft, will use trained t echnicians to perform maintenance, alterations, or preventive maintenance on the unmanned aircraft system using the methods, techniques, and practices prescribed in the manufacturer’s maintenance manual. Furthermore, Z

DRONES will document and maintain all main tenance records for each of the individual aircraft.
Since each UAS will be inspected as prescribed by the manufacturer’s maintenance manual, Z

DRONES will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). The Aircraft Maintenance Manuals set forth Scheduled Maintenance Inspection Procedures for each system and component. Inspection intervals for the aircraft include preflight and post flight inspections, as well as scheduled inspections every 25 hours, 50 hours, 75 hours, and 100 hours of operation.
Likewise, the exemption sought will not adversely affect safety because Z

- DRONES will perform maintenance, alterations or preventive maintenanc e on the UAS using the methods, techniques, and practices prescribed by the manufacturer’s maintenance manuals for each respective aircraft.
Furthermore, the exemption sought would maintain an equivalent level of safety established by Sections 91.407, 91.417(a) and 91.417(b) because all maintenance of the aircraft will beperformed by manufacturer approved technicians, who will document and maintain maintenance records for the UAS. A Maintenance Action Form must be completed and saved in the maintenance logs for all maintenance that is performed on the UAS. The procedures for maintaining the maintenance logs for the UAS are fully set forth in the Z

- DRONES Operations Manual, Exhibit Q. Details on the Kittyhawk.io logging program can be found in the Kittyhawk Sell Sheet, attached as Exhibit C.
Significantly, previous exemptions g ranted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), 91.417(a) & (b) establish that safety is not adversely affected when the technical characteristics and operating limitations of a UAS are considered. The FAA has previous ly granted relief specific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138).

6 . The FAA May Prescribe Any Other Co nditions For Safe Operation.
In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Z

- DRONES requests that the FAA prescribe special conditions for the intended operation of each UAS, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C. F.R §§ 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UA for the limited purpose of conducting aerial photography over rural

areas of the United States. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to op erate without airworthiness certification in accordance with any requirements that must be established for the safe operation of the UAS in the NAS.
Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of each UAS, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special Conditions, states the following:
If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or unusual design feature of the aircraft, aircraft engine or p ropeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FAA find s necessary to establish a level of safety equivalent to that established in the regulations.

See 14 C.F.R. § 21.16.
Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for Z

- DRONES ’s intended operati on of the DJI Inspire 1 and S1000
,which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C .F.R. Part 21, Subpart H, and 14 C.F.R Sections 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

F. A Summary That Can Be Published In The Federal Register , Stating:

The R ules From Which Z

- DRONES Seeks Exemption:

Z

- DRONES , LLC. seeks exemp tion from the requirements of 1 4 C.F.R. Sections ), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

A Brief Description Of The Nature Of The Exemption Z

- DRONES Seeks:
This exemption will permit Z

- DRONES , LLC. to commercially operate Unmanned Aircraft Systems for the purpose of conducting aerial photography and cinematography over certain rural areas of the United States.

G. Any Additional Infor mation, Views, Or Arguments Available To Support Z

- DRONES ’s Request.
This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. As such, Z

- DRONES ’s request for exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above.
FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to us ers of the NAS or the public, or otherwise pose a threat to national security, and further, provides the authority for such UAS to operate without airworthiness certification.

As discussed in detail above, Z

- DRONES will operate the specified UAS safely in the NAS without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.

CONCLUSION

As set forth herein, Z

- DRONES seeks an exemption pursu ant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI Inspire 1, 3DR Solo, and SteadiDrone Mavrik UAS commercially, without an airworthiness certificate, for the limited purpose of conducting aerial photography and cinematography within the stated operational guidelines. By granting this Petition, the FAA Administrator will be fulfilling the Congressi onal mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing Z

- DRONES to safely, efficiently, and economically operate these UAS commercially within the NAS.

WHEREFORE , in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, Z

- DRONES respectfully requests that theAdministrator grant this Petition for an exemption from the req uirements of 1 4 C.F.R Sections 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Z

- DRONES to operate the specified UAS for the purpose of conducting aerial photography and cinematography over rural areas of the United States.