UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIA TION ADMINISTRATION

WASHINGTON, DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: Alternative Digital Solutions, LLC (ADS, L LC)

Submitted on October 15, 2015

Alternative Digital Solutions, LLC 120 Peachtree Eas t Shopping Center Peachtree City, Georgia. 30269 (678)378

- 1871 Operating O fficer: Ronald C. Romuno

Alternate Contact Information: Ronald.C.Romuno@FAA.gov

A80, Atlanta TRACON Safety Office Federal Aviation Administration (678)364

- 6114TABLE OF CONTENTS Page

GL OSSARY OF ABBREVIATIONS....................................... ..............................................3

SUMMARY............................................. ................................................................................ 4

INTRODUCTION.....................................................................................................4

LIST OF REGULATIONS FOR EXEMPTION................................................... ...................5

PROCESSES, PROCEDURES, AND RESPONSIBILITIES................................................5

PUBLIC BENEIFT..........................................................................................................9

PRIVACY CONCERNS...................................... ...........................................................10

SAFETY CONCERNS...................................................................................................10

CONCLUSION................................................................................. .......................................15

CHECKLISTS............................................................................................................16

DJI Phantom 2 SPEC SHEET .........................................................................................17GL OSSARY OF ABBREVIATIONS

ADS Alternative Digital Solutions, LLC 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 Lo ss of Link NAS National Airspace System NOTAM Notice to Airman PIC Pilot In Command Section 333 FAA Modernization and Reform Act of 2012 (FMRA) SO Safety

Obse rv er SOP Standard Operating Procedures UA Unmanned Aircraft UAS Unmanned Aircraft System VF R Visual Flight Rules VL OS Visual Line of Site VMC Visual Meteorological Conditions VTO L Vertical Takeoff and Landing DJI UAV m anufacturer ESC Electronic speed control FPV First Person View LI

- PO Lithium Polymer battery RCV Radio Controlled vehicle**INTRODUCTION** Alternative Digital Solutions, LLC (ADS) is a Real Estate Support Company with the focus on providing video and still photography, both interior and exterior, to clients throughout the Atlanta Metr o area.
The objective of ADS aerial video and photography operations is to provide high quality imaging for a variety of commercial, public, and residential uses

. Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F.R. Part 11, Alternative Digital Solutions, LLC , hereby applies for an exemption from the Federal Aviation Regulations (FARs) listed below to allow operation of a Small Unmanned Aircraft System (sUAS) commercially in airspace regulated by the Fe deral Aviation Administration (FAA) so long as such operations are conducted with and under the conditions outlined herein or as may be established by

the FAA as required by Section 333.

The requested exemption would permit ADS to pursue commercial inter ests in providing services to clients using a small advanced sUAV in the following areas: Real Estate, Marketing, Land Management/Surveying, and Special Events. ADS states that all sUAS flights will occur over private or controlled access property and will do so with the property owner's consent and knowledge and that only people who have consented or otherwise have agreed to be within the UAS’ radius during filming and photography applications.

Ronald C Romuno, Operating Officer and sUAV Pilot (Pilot Cer tificate # 69545978)
, has demonstrated the ability to safely and effectively fly the sUAS DJI Phantom 2 which will be used for all commercial and private purposes. Ronald C Romuno complies with local ordinances and laws regarding the operation of sUAS, and adheres to all weather and environmental restrictions or limitations in reference to the operations of sUAS. Additionally , ADS will ensure that any other individual who operates an sUAV for ADS will meet all pilot requirements with respect to license,

m edical clearance, etc. and complies with all Federal, State and Local regulations.

All flights will occur in ordinance with any state or local laws regarding privacy. We
, Alternative Digital solutions, LLC , request the exemption because we are committed to comply ing with all of the rules, guidelines, limitations, and future legislation set forth by the FAA. We agree to operate the sUAS in the manner that we have described, and for the purposes that we have described. Without the exemption request granted, we would be unable to safely and effectively

run our business, and it is our intention to comply with the FAA and obtain an exemption of the following regulations.

The following contains a list of regulations from which we are seeking exemption, and a c omplete list of responsibilities we assume as operator; it also contains information regarding the aircraft, public benefit and safety features, and similar petitions requests granted

.**Regulations from which exemption is requested:** 14 C.F.R. Part 21 14 C.F.R. 45.23(b) 14 C.F.R. 61.113(a) & (b) 14 C.F.R. 91.7(a) 14 C.F.R. 91.9(b) (2) 14 C.F.R. 91.109 14 C.F.R. 91.119 14 C.F.R. 91.121 14 C.F.R. 91.151(a) 14 C.F.R. 91.203(a) & (b) 14 C.F.R. 91.205(b) 14 C.F.R. 91.215 14 C.F.R. 91.401

- 91 .417

**PROCESSES, PROCEDURES, AND RESPONSIBILITIES**

We
, Alternative Digital Solutions, LLC, WO UL D ASSUME THE FOLLOWING RESPONSIBILITIES IF MY EXEMPTION IS APPROVED.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2 whe n weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed

- set motion picture and television filming are not permi tted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may

use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer.

4. The UA will be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA will be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate or U.S. driver’s l icense.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS cap ability. The VO 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 o f the flight. The PIC must ensure that the VO can perform the duties required of the VO.7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and 4 limitations in th is exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may upd ate or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The operator must also present updated and revis ed documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS

− 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g., replacement of a flight critical c omponent, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by

a PIC with a VO and must remain at least 500 feet from other people. The functional test flight mu st be conducted in such a manner so as to not pose an undue hazard to persons and property

. 9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

- flight inspection see attachment and determine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g., inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufact urer’s mainten a nce, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.

13. Under this grant of exemptio n, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Pue rto Rico, a territory , a possession, or the Federal government. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 514. The operator may not pe rmit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from pe rsons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience

- build ing) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedica ted 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 accordan ce with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Adminis trator or any law enforcement official upon request.

17. 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.

18. If the UAS loses communicat ions or loses its GPS signal, the UA must return to a pre

- determined location within the private or controlled

- access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from begin ning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufactur er if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be conducted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct opera tions that cannot be conducted under the terms of the attached COA. 622. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N −Number) marking s in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available t o the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

24. The UA must remain clear and give way to all manned aviat ion operations and activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation ari ses where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and b. The owner/controller of any vessels, vehicles or struct ures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard. The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled

- access property with permission from the property owner/controller or authorized representative. Permission from p roperty owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applica ble 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) per instructions contained on the NTSB Web site: www.ntsb.gov.**PUBLIC BENEFIT**

**1. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 2**  **UASs.** Conducting aerial acquisitions with the DJI Phantom 2 UASs, instead of manned 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 Phantom 2 UASs produce no air pollution, and is the most viab le environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are ty pically utilized for aerial video and photography, while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The DJI Phantom 2 UAs, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAs are propelled by battery powered electric motors, rather than an internal combustion engine.

By using the DJI Phantom 2 UASs to perform aerial acquisitions, 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 fli ght crew members located onboard the aircraft, the DJI Phantom 2 UAs (weighing 5 pounds 7 ounces, at its maximum gross weights with a diagonal length of 1 3.78 inches, and with no fuel on board), has less physical potential 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 of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

**2. Performing Aerial Video and Photography Operations With**  **The DJI Phantom 2**  **UASs Will Benefit The Economy.**  In addition to being safe and efficient, the DJI Phantom 2 UAS is also an economical alternative to using manned aircraft to conduct similar aerial op erations. As such, operation of the DJI Phantom 2 UAS will allow United States based companies, like ADS , to remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protecti on Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology

in order to remain competitive. Operating the battery powered DJI Phantom 2 UAS not only allows companies gr eater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft. By operating the DJI Phantom 2 UAS, companies such as ADS can remain competitive and profitable, an d therefore, provide greater job stability to employees and contractors, which will ultimately contribute to growth of the U.S. economy . Improved financial performance of U.S. companies, through commercial use of the DJI Phantom 2 UAS, provides a stable wo rkforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the United States and abroad.**PRIVACY CONCERNS**

Similar to the manned aerial acquisition flight operations that have been conducted for decades, ADS proposed operation of the DJI Phantom 2 UAS would not implicate any privacy issues. Specifically, the DJI Phantom 2 U AS will be operated only in compliance with operating documents such as the Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Instruction Manual) which requires property owner involvement as well as local law enforcement notification, an d in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.

**SAFETY CONCERNS**

In seeking this exemption, ADS submits that the DJI Phantom 2 UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI Phantom 2 UASs; (b) the pilot certification requirement; and (c) the specific operating limitations.

i. **The Specifications Of The DJ I**  **Phantom 2 UAS Demonstrate Its Safe Characteristics.**  The DJI Phantom 2 UAS do es not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security

considering its size, weight, speed, and operational capability. ii. **Te chnical Specifications Of The DJI**  **Phantom 2 UAS.**  The DJI Phantom 2 Specifications and Data Sheet, attached hereto as Appendix A and B, set the technical specifications of the DJI Phantom 2 UAS forth. iii. **The DJI Phantom 2**  **UAS Autonomous Flight And Naviga tion Modes Enable The UAS To**  **Remain Within A Defined Operational Area.** The DJI Phantom 2 UAS may be operated in both manual and fully autonomous flight modes. A complete description of the flight and navigational modes of the DJI Phantom 2 UAS is provided on pages 30 through 44 of the DJI Phantom 2 User Manuals. DJI Phantom 2 User Manual is attached. iv. **The DJI Phantom 2**  **UAS Is**  **Designed For Automatic Return To Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation.**  When the Control Link is lost, the DJI Phantom 2 UA will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 2 UA do es not reacquire control link data from the GCS, the UA will assume that the Control Link is lost and the UA will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown. A complete description of the Failsafe Functions for the DJI Phantom 2 is provided on pages 27 and 28 of the DJI Phantom 2 User Manual

. DJI Phantom 2 User Manual is attached.

v. **The DJI Phantom 2**  **GCS And Its Operation.** A complete description of the operation and specifications of the DJI Phantom 2 GCS and flight control software is provided on pages 30 through 4 4 of the DJI Phantom 2 User Manual. DJI Ph antom 2 User Manual is attached.vi. **Flight Operations Of DJI Phantom 2**  **UAS Are Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer.**  ADS will only utilize certificated pilots who possess a current and valid airman medic al certificate to act as a pilot in command (PIC) of the DJI Phantom 2 UAS. Additionally, a safety observer will assist all pilots during flight time. vii. **Flights Of DJI Phantom 2**  **UAS Will Be Conducted Pursuant To Specific Operating Limitations.**  In seeki ng this exemption, ADS proposes to commercially operate the DJI Phantom 2 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 au thorized 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 Phantom 2 Unmanned Aircraft Systems. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant. 2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photography. 3. The UAs may

not be flown at an indicated airspeed exceeding 20 knots. 4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL), as indicated by

the procedures specified in the operating documents unless a special request is made and approved by ATC. All altitudes repor ted to ATC must be in feet AGL. 5. The UAs must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate. 6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted. 7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC alw ay s 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 designat ion for the duration of the flight. The PIC must ensure that the SO can perform the functions prescribed in the 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 not permitted to operate the camera or 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. If a discrepancy exists between the conditions and limitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption take precedence and must be followed. O therwise, 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 th e Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FA A granted the exemption, then the operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operating documents.10. Prior to eac h flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has 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 aircraft records. 11. Any UAS that has undergo ne maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraf t records. 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 of the operating documents. 13. The operator must follow the UAS manufact urer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. 14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature of the authorized person returning the UAS to service. 15. Each UASs operated under this exemption must comply with all manufacturer Safety Bulletins. 16. The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections. 17. T he PIC must possess at least a private pilot certificate and at least a current third

- class medical certificate. 18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safely 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 ho urs must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator’s PICs are permitted under the terms of the exemption. However, training operations may only be conducted during dedicated training sessi ons. 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.F.R. § 91.119. 19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will be 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 of an 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 NOTAM as required by the operator’s COA. The letter of agreement with the airport management must be made available to the Administrator up on request. 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. If the UA loses communications or loses its GPS signal, it must return to a pre

- determined location within the planned operating area and land or be recovered in accordance with the operating documents. 23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating do cuments.24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 25% battery power remaining. 25. 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 must be as large as practicable. 26. 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. 27. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made available to the Administrator or any law enforcement official upo n request. 28. The UA must remain clear and yield the right of way to all manned aviation operations and activities at all times. 29. The UAS may not be operated by the PIC from any moving device or vehicle. 30. Flight operations must be conducted at le ast 500 feet from all nonparticipating persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight ope rations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of the risk of opera ting closer to those objects and determined that it does not present an undue hazard, and; c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a). 31. All operations shal l be conducted over private or controlled

- access property with 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.

**CO NCLUSION**  Alternative Digital Solutions, LLC (ADS) seeks an exemption pursuant 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 Phantom 2 UAS commercially, without an a irworthiness certificate, for the limited purpose of conducting aerial video and photography over certain areas of the United States. ADS respectfully

requests that the Administrator grant this Petition for an exemption and allow ADS to operate the DJI Pha ntom 2 UAS commercially for the purpose of conducting aerial video and photography over certain areas of the United States.

Current Phantom 2 UAS to be flown has the FAA Registered N Number: N599YB**CHECK LISTS**

**Pre**

**- flight**  · Reviewed targeted area through Google Earth for any obstructions · Reviewed area for any FAA restricted fly zones or other areas of concern · Reviewed safety requirements with sponsor / owner (sign

- off required back of form) · Posted “Aerial Photography” in process sign at opening / curb · Visit each neighbor to announce that aerial photography will be taking place · Posted “Launch/Landing” zone sign calling for 50’ parameter · Walked the hover area or path of flight to che ck for any areas on concern

**Flight Set**

**- up**  · Advise any one within “Launch/Landing” area of safety and 50’ requirement · Unpack and check DJI Phantom 2 for any visible signs of damage · Turn on Remote Controller and observe that both power and Wi

- Fi are green · Ensure launch zone is clear and turn on DJI Phantom 2 battery · Toggle S1 & S2 switches five times to set GPS recal l & failsafe landing zone · Wait for solid GPS lights (Solid Green slow flashing) · Spin DJI Phantom 2 360 degrees both h orizont al ly and v ertically to ensure lock · Review Launch Site one last time before lift off · Engage motors and start straight horizontal lift to desired altitude

**Flight** · Monitor both GPS Lock (# satellites) / Battery Level every minute · Watch for any ch anges to the “Launch/Landing” area of safety and advise as necessary · Watch for any irregular craft behavior and land immediately if necessary · Return the craft to the landing area within 20% of battery life

**Post**

**- Flight**  · Announce that the craft is returning for landing · Visual check that the 50’ rule is observed
, o therwise hover until 50’ is observed · Slowly bring the DJI Phantom 2 in for a landing · Turn off Battery on Craft first, then the Remote Controller · Store all equipment in their cas es before allowing observe r s to approach

### General Features
Li ghtweight, multi

- functional integrated aircraft and

c amera Camera remote

- control by DJI VI SI ON APP Range Extender increases Wi

- Fi distance to 300m
Anti

- vibration camera platform with single axis

s tabili z ation
Low

- voltage protection
Virtual Radar aircraft locator on mobile device Range of camera tilt options Multiple, continuous and timed capture options HD Video Recording (1080/p30 or 1080/60i) RAW and JPEG picture formats

Aircraft **Battery** 5200mAh Li Po **Weight (Battery & Propellers Included)** 1160g **Hover Accuracy (Ready To Fly)** Vertical: 0.8m; Horizontal: 2.5m **Max Yaw Angular Velocity** 200°/s **Max Tilt Angle** 35° **Max Ascent / Descent Speed** Ascent: 6m/s; Descent: 2m/s **Max Flight Speed** 15m/s (Not Recommend ed) **Diagonal Length** 350mm **Tilting Range Of Gimbal** 0°

- 60°

Transmitter **Operating Frequency** 5.728GHz

- 5.8GHz **Communication Distance (Open Area)** CE: 300m; FCC: 500m **Receiver Sensitivity (1%PER)**

- 93dBm **Transmitter Power** General Features

### CE: 25mw; FCC: 125mw **Working Voltage** 80 mA @6V **Battery** 4 AA Batteries

Camera **Resolution** 14 Megapixels **FOV** 120°/ 110°/ 85° **Sensor Size** 1/2.3" **Functionality**

 

### Support of multi

- capture, continuous capture and timed capture

 

### Support of HD Recording (1080/p30 or 1080/60i)

 

### Supports of both RAW and JPEG pict ure format
Range Extender **Operating Frequency** 2412

- 2462MHz **Communication Distance (Open Area)** 300m **Transmitter Power** <=17dBm **Power Consumption** 1.5W

DJI VI SI ON App **System Requirement Of Mobile Device** iOS version 6.1 or above/ Android sy stem version 4.0 or

a bove **Mobile Device Support**

 

### iOS recommended: iPhone 4s, iPhone 5, iPhone 5s, iPhone 6, iPhone 6 Plus, iPod touch 5 (available but not recommended: iPad 3, iPad 4, iPad mini)

 

### Android recommended: Samsung Galaxy S3, S4, Note 2, Note 3 or phones of similar con figuration