Petitioner: PETITION FOR EXEMPTION TITLE
14, CODE OF FEDERAL REGULATIONS Mark Liponis, MD 71 Y okun
A venue Lenox, Massachusetts 01240 1-413-212-4565 mark.liponis@gmail.com Exemption from Sections

of 14 CFR: part 21; §§ 45.23(b); 61.113
(a) and (b); 91.9(b)(2); 91.103; 91.109; 91.119; 91.121; 91.151(a); 91.203(a)
and (b); 91.405(a); 91.407(a)(1); 91.409(a)(2);

and 91.417(a)
and (b)

. Extant
of relief: Petitioner desires exemption from the above named regulations

for the purpose

of conducting commercial aerial videography using Unmanned Aerial Systems (UAS) with Global Positioning System (GPS) control and stabilization. The petitioner supports

its request with the following information: The petitioner provides
the following information:

1. Unmanned Aircraft Systems (UAS);

2. UAS Pilot
in Command (PIC) Requirements;

3. UAS Operating Parameters;

4. Public Interest and Safety;

5. Summary

. 1. Unmanned Aircraft System: The UAS proposed

for use by the petitioner

are airframes provided

by DJI.com (DJI), used in conjunction
with DJI hardware/software controllers,
data signal processing,

and GPS stabilization

and navigation electronics

. Radio Control (RC) transmitters, propellers, electric motors, and batteries
are provided

by DJI (Da- Jiang Innovations Science and Technology

Co. Ltd.)
is located

at, Shenzhen, Guangdong Province, China. Please
be advised that most Unmanned Aerial Systems (UAS) are modular (plug-in and replaceable parts that are commonly used in UAS), and that on hardware/software

for controllers, data links, and GPS navigation

are the most commonly used programmable electronics for navigation
and control

in UAS usage. The systems have the size, weight, speed, and limited operating area associated with the aircraft

to be utilized

by the applicant,

an exemption from
14 CFR part 21
§ 91.203 (Airworthiness Certificates), subject

to certain conditions
and limitations,

is warranted and meets the requirements

for an equivalent level of safety under
14 CFR part
11 and Section 333 of the FAA Modernization

and Reform Act of2012 (PL 112-95)

. If these UAS are operated without

an airworthiness certificate

in the restricted environment

and under the conditions
and limitations proposed

by the petitioner

it will be at least as safe, or safer, than

a conventional aircraft (fixed wing or rotorcraft) operating with anairworthiness certificate issued under

14 CFR part 21, Subpart

H and not subject

to the proposed conditions
and limitations

. The UAS
to be operated under this request are less than 55 lbs (20 lbs. or less typically) fully loaded, flying

at speeds
of no more than 50 knots

, carrying neither

a pilot nor passenger (part 21
§ 61.113), carrying

no explosive materials

or flammable liquid fuels, and operates exclusively within

a secured area.
In addition,
the UAS have integrated safety features built into the design
of the UAS,
as described

in the UAS operating parameters,

to ensure the safety of persons and property within and surrounding

the limited operating area.
In the event the UAS loses communications,

its GPS signal,

or reaches 15% battery power, the UAS will have the capability

to automatically return

to the takeoff/PIC location within the limited operating area. Software

for the controller could be coded for use by
a particular unit so as to prevent interference

or hijacking (part 21


### § 91.1 09). Controllers
also have the capability

to abort

a flight
in the event of unpredicted obstacles

or emergencies. Distance from the PIC can be limited with DJI UAS software and the flights can be contained

in the restricted secure flight areas,
as well as preventing flights

in restricted areas such
as class

B airspaces. UAS have been proven

to have stable flight under severe gusty wind conditions

(up to 40 knots). Wind shear accidents
can be of minimal impact when using

a UAS with low mass and soft propellers such
as UAS, though through diligent weather planning, avoidance

is the best course. The UAS will have no airworthiness certificate,
and an exemption
may be needed from
14 CFR

§ 45.23
as the UAS will have no entrance

to the cabin, cockpit, or pilot station
on which the word "experimental"

can be placed. Given the size of the UAS, the two-inch lettering will be impossible.

An equivalent level of safety will be provided

by the UAS having flashing lights

to draw attention

to their operation. The maintenance requirements

in the pertinent sections

of 14 CFR, part 91 are only applicable

to aircraft with an airworthiness certificate

in accordance with part 43, therefore
the petitioner
has developed

an as needed maintenance process
for the UAS affected

by this exemption.
The petitioner intends

to follow any manufacturers' recommended instructions

and procedures when those maintenance procedures exist for certain components

of its UAS (§ 91.9, 91.405, 91.407, 91.417). 2. UAS Pilot
In Command (PIC) Requirements The petitioner
has experience

in unmanned aircraft photography

and videography.

Any PIC incapacitation during operations


### will be addressed

by loss of communication

time out software and automatic navigation return

to base/takeoff point activation. The petitioner
has experience flying UAS and the skill or ability

to safely operate

an unmanned aerial vehicle, operating

at 400 feet AGL or lower, within strictly controlled pre-approved airspace. 3
. UAS Operating ParametersTheaircraftwillbeoperatedwithinasecureenvironment,whichnoonewillbeallowedtoenterunlesstheyarepartoftheproduction,havebeenfullybriefedoftheriskspriortooperationoftheUAS,andhaveconsentedtotherisksassociatedwithbeingintheoperatingarea.Shouldtherebeamishap,theUASbeingflownposesignificantlylessofathreatthanthehelicoptersandfixedwingaircraftnowbeingemployedbecausetheyareafractionofthesize,carrynoflammablefuel,anddonotcarrycreworpassengers.Fromexperience,thisisincontrasttoconventionalaircraftthatareflowntothesite,carryflammablefuel,carrypassengersandcrew,andoperateinamuchlargerarea.TheUASbatteriesareselfmonitoredforsafeusage,overheating,andreturntostartingpointwhendischargedto30%,andarelimitedtohowmanytimestheycanbechargedsafelybeforeproperdisposal.Flightcontrolsoftwarewillbeconstantlyupdatedasrequiredandwillprovidefeedbacktothemanufacturerformaintenance,design,andsafetyupdating(§91.405,91.407,91.409,91.417).AllUASflightswillbeoperatedwithinvisuallineofsight(VLOS)ofapilotand/orobserver,andthattheUASflightswillbelimitedtoamaximumaltitudeof400feetAGL(§91.119).Theoperatorwillensurethatonlyconsentingproductionpersonnelwillbeallowedwithin100feetoftheUAoperation,butthisradiusmaybereducedto30feetbaseduponanequivalentlevelofsafetydetermination, withtheadvancepermissionofthelocalFlightStandardsDistrictOffice(FSDO)andanyneededNOTAMpublishinanadequatetimeperiod.Thepetitionerassertsthatanequivalentlevelofsafetycanbeachievedgiventhesize,weight,andspeedoftheUAS,aswellasthelocationwhereitisoperated.TheUASwillbeoperatedwithinasafeoperatingperimeter,theboundariesofwhichwillbedeterminedbyproductionpersonnelandtheUASPICbasedonthesitespecificfilmingactivitiesandspeedoftheUASrequiredfortheoperation,andcoordinatedwiththejurisdictionalFAAFSDOandlocalgovernmentofficialsasapplicable.Withrespecttopreflightactions,thepetitionernotesitmayneedanexemptionfrom14CFR§91.103,becauseitwillnothaveapprovedrotorcraftflightmanuals.ThepetitionerassertsthatanequivalentlevelofsafetywillbeachievedbythePICtakingallpreflightactionsassetbythemanufactureroftheUASandthepilot'sownoperatingsafetyprocedurestocomplywithinsurancerequirementsincludingreviewingweather,flightbatteryrequirements,landingandtakeoffdistanceclearances,adequateGPSsignalacquisition,andaircraftperformancedataacquisitiononthecontrollerbeforeinitiationofflight( §91.7and91.103willbeadheredto).Withrespecttothefuelrequirements,thepetitionernotesthat,inordertomeetthe30minutereserverequirementsin14CFR§91.151,UASflightswouldhavetobelimitedtoapproximatelyzerominutes.Thepetitionerarguesthat,giventhelimitationsontheUA'sproposedflightareaandthelocationofitsproposedoperationswithinapredeterminedarea,alongertimeframeforflightindaylightornightVFRconditionsisreasonable.Thepetitionerbelievesthatanequivalentlevelofsafetycanbeachievedbylimitingflightsto25minutesor30%ofbatterypower,whicheveroccursfirst.Thepetitionerrequestsanexemptionfrom14CFR§91.121,asitsUAShaveGPSaltitudereadoutsinsteadofabarometricaltimeter.Thepetitionerassertsthatan

# equivalent level of safety will be achieved. Specifically,

the altitude information
will be provided

to the UAS PIC via

a digitally encoded telemetric data feed. Prior
to each flight, a zero altitude initiation point will be established

and confirmed

for accuracy

by the PIC. 4. Public Interest and Safety Given the small size of the UAS involved and the restricted secure environment within which

it will operate,

its proposed operation falls within that zone of safety

in which Congress envisioned
that the FAA must, by exemption, allow this commercial operation ofUAS

to commence immediately. Also, due to the size of the UAS and the restricted areas
in which the UAS will operate, approval

of the application presents

no national security issue. UAS systems
the petitioner
will use can be programmed

in multiple ways to provide security and safety. The petitioner points out that given the clear direction

in Section 333, the strong equivalent level of safety surrounding

the proposed operations, and the significant public benefit, including enhanced safety, reduction

in environmental impacts, and including reduced emissions associated

with allowing UAS for movie and television operations, granting
the requested exemptions

is in the public interest. The petitioner's

use ofUAS
for documentary

or educational videography

will add to the public's knowledge base, allow for the public

to experience video views of points
of interest heretofore

not available,
and further constitutional rights

to free speech. The petitioner

is also

a medical doctor, with

a great sense of personal and public safety, with

a keen understanding

of the adage ''safety first." 5. Summary The petitioner requests

an exemption

for himself, Mark Liponis, from Title 14, Code of Federal Rules pertaining

to the safe, commercial usage of unmanned aerial systems (UAS)

in controlled secured video production areas. Exemption from Sections

of 14 CFR: part 21; 

# §§ 45.23(b); 61.113
(a) and (b); 91.9(b)(2); 91.103; 91.109; 91.119; 91.121; 91.151(a); 91.203(a)
and (b); 91.405(a); 91.407(a)(l); 91.409(a)(2);

and 91.417(a)
and (b) are requested.
The petitioner supports
his request with the following information

I. Unmanned Aircraft Systems (UAS); this section describes
the UAS maximum capabilities

and the failsafe and abort safety mechanisms

that are programmed into the UAS;

2. UAS Pilot
In Command (PIC) Requirements;

this section describes

the pilot asking for the exemptions

and his experience
and knowledge base, description

of safe flight duties and preparation.

3. UAS Operating Parameters;

this section describes the operating procedures
that will be carried out to meet regulations

and provide safety

in operations, secure environment,

and procedures when working with the local FSDO and local government authorities;

4. Public Interest and Safety; this section addresses some of the advantages ofUAS operations, especially

the advantage

for the public being privy
to the exceptional views UAS videos provide.