# UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC U.S. Department of Transportation, Docket Management System 1200 New Jersey Ave, SE Washington, DC 20590 Regulatory Docket No.

_________________________________ IN THE MATTER OF THE PETITION FOR EXEMPTION AND RELIEF Andrew S. Coccari, Inc. d.b.a. Long Island Gymnasium Equipment Company

PETITIONS FOR EXEMPTION AND SEEKING RELIEF AND FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS CONCERNING COMMERCIAL OPERATION OF SMALL UNMANNED AERIAL SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 PUBLIC LAW 112-95

**P ETITIONER**  

### : Philip J. Coccari, President Andrew S. Coccari, Inc. d.b.a. Long Island Gymnasium Equipment Company 1400 Penataquit Avenue Bay Shore, NY 11706 (631) 666-9513 ・ pcoccari@ligym.com

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## Table of Contents

Introduction 3

..................................................................................................... Interests of the Petitioner 3

............................................................................... Relief from Specific Applicable Regulations 4

................................................... Impact to Safety 7

............................................................................................. Proposed Operations and Limitations 13

.......................................................... Public Interest 18

............................................................................................... Conclusion 20

.................................................................................................... Exhibits 21

.........................................................................................................

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# Introduction Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, Public Law 112-95 FEB. 14, 2012, Section 333 (herein referred to as “FMRA of 2012”), I, Philip J. Coccari, owner and operator of small unmanned aerial systems (sUAS), and employed by Andrew S. Coccari, Inc. d.b.a. Long Island Gymnasium Equipment Company (herein referred to as “LI Gym”), respectfully petition the FAA, on behalf of LI Gym, for an exemption from the herein listed Federal Aviation Regulations (FARs) so as to commence commercial operations of sUAS in the National Airspace System (NAS). Said operations shall be conducted within and under the conditions stipulated herein or as may be established by the FAA and/or as required by the FMRA of 2012, Section 333. LI Gym hereby petitions and requests exemption from the following FARs under Title 14 CFR: §§ 21(h), 61.113(a) & (b), 91.7(a), 91.9(b)(2), 91.103(b), 91.105, 91.109, 91.119, 91.121, 91.151(b), 91.215, 91.405(a), 91.407(a)(1), 91.409(a)(1)(a)(2), 91.417(a) (1) 

# Interests of the Petitioner LI Gym is a small business that was established back in 1980. LI Gym sells, installs, and services professional grade scoreboards, message boards, sporting equipment and sports apparatuses. Clientele ranges from private entities, schools and colleges, to owners of large sporting arenas. It is the intent of LI Gym to utilize sUAS in order to facilitate the following activities that are in furtherance of the business, for hire , and for direct compensation: 1) Aerial Photography and Videography Create and record high-resolution digital video and still imagery to be used in demonstrating, marketing and selling services or products. 2) Aerial Surveying Create and record high-resolution digital video and still imagery to be used to survey geographical locations of new and existing installation sites. 3) Aerial Inspections Create and record high-resolution digital video and still imagery to be used to aid in the inspection of existing scoreboards, message boards, sporting equipment and apparatuses.

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# Relief from Specific Applicable Regulations Pursuant to 14 CFR §11.61(b) and the FMRA of 2012, Section 333, Special Rules for Certain Unmanned Aircraft Systems, LI Gym hereby petitions the Administrator for the engagement of commercial operations utilizing the DJI Inspire 1 and DJI Phantom 3 Professional sUAS in the National Airspace System (NAS), and seeks relief and or exemption from the following FARs under Title 14 CFR: 

## §21, Subpart H Airworthiness Certificates In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft (UA) and its operation, the DJI Inspire 1 and DJI Phantom 3 Professional sUAS meet the conditions of FMRA of 2012, Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 CFR Part 21, Subpart H. 

## §61.113(a)(b) Private pilot privileges and limitations: Pilot in command Exemption from certain requirements of §61.113(a) and (b), entitled, “Private pilot privileges and limitations: Pilot in command”, is requested by LI Gym, to the extent necessary to allow a pilot in command (PIC) holding a private pilot or higher level certificate, as well as an airman medical certificate, and who has demonstrated, by meeting a minimum of 10 flight-hours of the designated UAVs, along the ability to safely operate and fly the DJI Inspire 1 and/or, the DJI Phantom 3 Professional sUAS in a manner consistent with this exemption; including but not limited to standard takeoff and landing procedures, flight attitudes consistent with the safe envelope of flight for the given UA, evasive maneuvers, emergency maneuvers and procedures as well as the ability to maintain safe distances from people, property, buildings, structures, and restricted airspace. 

## §91.7(a) Civil aircraft airworthiness LI Gym seeks exemption from the requirement of §91.7(a), entitled, “Civil aircraft airworthiness”, because the DJI Inspire 1 and DJI Phantom 3 Professional sUAS do not require an airworthiness certificate in accordance with Part 21, Subpart H. Furthermore, LI Gym will ensure, to the best of their knowledge and ability, that said UA are in airworthy condition and capable of safe flight by implementing a designated checklist. A preflight checklist shall be utilized in order to determine a “go” or “no-go” decision prior to each and every flight. The items on this list are based upon the operating limitations for that version of UA as specified in the manufacturer manual and operating software. sUAS checklist for the the DJI Inspire 1 and DJI Phantom 3 Professional sUAS is annexed hereto as Exhibit A and Exhibit B respectively.

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## §91.9(b)(2) Civil Aircraft Flight Manual, Marking, and Placard Requirements LI Gym seeks exemption from the requirement of §91.9(b)(2), entitled, “Civil aircraft flight manual, marking, and placard requirements”, because the the DJI Inspire 1 and DJI Phantom 3 Professional sUAS do not possess current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof

. 

## §91.105 Flight Crew Members at Stations LI Gym seeks exemption from the requirement of §91.105, entitled, “Flight crew members at stations”, because the the DJI Inspire 1 and DJI Phantom 3 Professional sUAS are by definition unmanned and therefore do not possess crew members. 

## §91.103(b) Preflight Action LI Gym seeks exemption from the requirement of §91.103(b), entitled, “Preflight action” “For any flight, runway lengths at airports of intended use, and the following takeoff and landing distance information:”, because the DJI Inspire 1 and DJI Phantom 3 Professional sUAS will, at no time, be operating from an airport and do not require the use of a runway. Therefore, this regulation simply does not apply to the operation of the DJI Inspire 1 and DJI Phantom 3 Professional sUAS

. 

## §91.109 Flight Instruction; Simulated Instrument Flight and Certain Flight Tests. LI Gym seeks exemption from the requirement of §91.109, entitled, “ Flight instruction; Simulated instrument flight and certain flight tests”, in its entirety, because the the DJI Inspire 1 and DJI Phantom 3 Professional sUAS are by definition unmanned and possess a Ground Control Station (GCS) consisting of two gimbal sticks in order to maneuver the UAV. Furthermore, there will no flight instruction or flight tests administered under this exemption. 

## §91.119 Minimum Safe Altitudes LI Gym seeks exemption from the requirement of §91.119, entitled “Minimum Safe Altitudes”. As contained in AC91.57A, §6 item (e) , entitled, “Model Aircraft Operations”, as follows: “Model aircraft operators should follow best practices including limiting operations to 400 feet above ground level (AGL).” Furthermore, under the provisions set forth by this exemption, operations of the herein specified UA’s shall be limited to 200 feet AGL or below. The basis of this exemption is due to the nature of the intended sUAS tasks specified herein, flights over sparsely populated areas could occur on a regular basis.

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## §91.121 Altimeter Settings LI Gym seeks exemption from the requirement of §91.121, entitled “Altimeter Settings” because the DJI Inspire 1 and DJI Phantom 3 Professional sUAS do not possess a traditional barometric altimeter. However, altitude information of said UA’s is provided to the pilot in command (PIC) via the Global Positioning System (GPS) equipment and radio telemetry data link of the respective sUAS. Realtime telemetry conveys altitude information from the UA to the ground control station (GCS) for active monitoring during the flight. This altitude information, together with visual line of sight (VLOS) by the PIC and/or the spotter, at or below 500 feet AGL, will ensure a level of safety equivalent to §91.121. 

## §91.151(b) Fuel requirements for flight in VFR conditions LI Gym seeks exemption from the requirement of §91.151(b), entitled “Fuel requirements for flight in VFR conditions”. Safety will not be affected by operation of the DJI Inspire 1 and DJI Phantom 3 UA while maintaining visual line of sight (VLOS), during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), as there exists, by design, enough battery power under a no-wind condition, for a total flight duration of approximately 18 and 20 minutes respectively, to the first intended GPS waypoint and then the first point of intended landing, and assuming normal cruising speed, to fly thereafter for at least 4 minutes. 

## §91.215 ATC Transponder and Altitude Reporting Equipment and Use LI Gym seeks exemption from the requirement of §91.215, entitled “ATC transponder and altitude reporting equipment and use”. Due to the small size, limited lifting capacity, and limited power reserves, the DJI Inspire 1 and DJI Phantom 3 Professional sUAS cannot be configured with, and operate, a traditional transponder and automatic altitude reporting equipment as specified in §91.215 (a) and (b). 

## §§ 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), 91.417(a) & (b) Accordingly, upon exemption from Part 21, Subpart H, these sections stated above stipulate requirements for maintenance that only apply to aircraft with an airworthiness certificate. Therefore, the petitioner hereby requests exemption from these sections as well. LI Gym submits that the requested exemption is proper since an equivalent level of safety will be ensured due to the fact that LI Gym will only use experienced technicians to perform maintenance, alterations, and upgrades or updates to either hardware or software on all sUAS components in accordance with the manufacturer’s guidelines. Furthermore, LI Gym will only procure DJI approved manufactured parts for all maintenance, repairs, alterations, and/or upgrades or updates to the herein stated UA. Records of any and all maintenance, alterations, and upgrades or updates to either hardware or software on all sUAS components shall be maintained by LI Gym in a separate electronic, computer readable, maintenance log. An example is annexed hereto as Exhibit C.

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# Impact to Safety The following states the reasons why granting this exemption would not adversely affect safety. In addition, it is further stated how LI Gym believes this exemption would provide a level of safety at least equal to that provided by the existing rule from which LI Gym seeks exemption. In consideration of the size, weight, speed, and limited operating area associated with the DJI Inspire 1 and DJI Phantom 3 Professional sUAS, LI Gym’s operation of these sUAS meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 CFR Part 21, Subpart H. Section 333 provides authority for a UAS to operate without airworthiness certification and 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. Specifically, FMRA Section 333 states, in part, the following: (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 rule making 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 types 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 or 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 49, 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 safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system. In seeking this exemption, LI Gym submits that the DJI Inspire 1 and DJI Phantom 3 Professional sUAS can operate safely in the NAS pursuant to FMRA of 2012, Section 333, as demonstrated by: (a) the safe characteristics of said UAVs; (b) the pilot certification requirement; and (c) the proposed operations and limitations stated herein.

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## DJI Inspire 1 and DJI Phantom 3 Professional sUAS Safe Characteristics The DJI Inspire 1 and DJI Phantom 3 Professional sUAS do not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering their size, weight, speed, and operational capabilities. The DJI Inspire 1 and DJI Phantom 3 Professional sUAS may be operated in either manual mode or GPS flight mode. When GPS flight mode is enabled the UAV can be programmed to remain within a defined operational area that is defined by waypoints in the operating software and thus limiting it’s operation to a prescribed geographic location that has been properly vetted for safety prior to flight. The DJI Inspire 1 and DJI Phantom 3 Professional sUAS is designed to automatically return to the designated point of departure or “home point” or begin a hovering maneuver in the event of a loss of signal to the ground control station. When the signal to the ground control station is lost for a period exceeding 3 seconds, the UAV will begin a hovering maneuver at it’s given altitude. If the UAV does not reacquire a signal back to the ground control station, it will enter a failsafe condition whereby it will commence flight on it’s own and return to the designated home point at it’s present altitude. Once reaching the home point it will hover for 15 seconds, then begin an automated descent and commence a safe landing. Immediately following this controlled landing, the UAV will shutdown it’s motors and propellers. The technical specifications of the DJI Inspire 1 and DJI Phantom 3 Professional sUAS are conveyed in the manufacturer’s user manual and are duplicated herein for reference. They include the operating radio frequencies that the UAS utilizes as well as maximum velocity limitations. For example, the documented maximum lateral velocity of the DJI Phantom 3 Professional is 16 m/s or 35.79 mph in a no-wind atmosphere; the documented maximum lateral velocity of the DJI Inspire 1 is 16 m/s or 49.21 mph in a no-wind atmosphere.

rev A1.1 Page of 8 23TECHNICAL SPECIFICATIONS OF THE DJI PHANTOM 3 PROFESSIONAL SUAS 

## A IRCRAFT Weight (including battery and propellers) 1280g ........... Diagonal size (including propellers) 590mm .................. Max Ascent Speed 5m/s .................................................... Max Descent Speed 3m/s ................................................. Hover Accuracy • Vertical: +/- 0.1 m (when VPS active) or +/- 0.5 m • Horizontal: +/- 1.5 m Max Speed 16 m/s (ATTI mode, no wind) ........................ Max Service Ceiling (MSL) 6000 m (Default altitude limit: 120 m above takeoff point) Operating Temperature 0°C to 40°C ................................ 

## GPS M ODE Constellation GPS/GLONASS .......................................... 

## G IMBAL Controllable Range Pitch -90° to +30° ............................. Stabilization 3-axis (pitch, roll, yaw) ................................ 

## R EMOTE 

## C ONTROLLER Operating Frequency 2.400GHz - 2.483GHz Max Distance Up to 5 km or 3.1 miles (unobstructed, free of interference) when FCC compliant Up to 3.5 km or 2.1 miles (unobstructed, free of interference) when CE compliant Video Output Port USB ..................................................... Operating Temperature 0°C- 40°C .................................... Battery 6000 mAh LiPo 2S ................................................ Mobile Device Holder For tablet or phone ...................... Receiver Sensitivity (1%PER) -101dBm ±2dBm ............. Transmitter Power (EIRP) FCC: 20dBm, CE: 16dBm ..... Working Voltage 1.2 A @7.4 V .......................................... 

## I NTELLIGENT 

## F LIGHT 

## B ATTERY Capacity / Voltage / Battery Type / Energy / Weight 4480 mAh, 15.2 V, 4S LiPo, 68 Wh, 365 g Max Flight Time Approx. 23 mins .................................... Operating Temperature -10°C to 40°C ............................. Max Charging Power 100W .............................................. 

## C AMERA Sensor Sony EXMOR 1/2.3” Effective pixels: 12.4 M .... (total pixels: 12.76 M) Lens FOV 94° 20 mm (35 mm format equivalent) f/2.8, . focus at ∞ ISO Range 100-3200 (video) 100-1600 (photo) ................ Shutter Speed 8s -1/8000s ................................................ Image Max Size 4000 x 3000 ............................................. Still Photography Modes • Single Shot • Burst Shooting: 3/5/7 shots • Auto Exposure Bracketing (AEB): 3/5 • Bracketed Frames at 0.7EV Bias • Time-lapse 

## V IDEO 

## R ECORDING 

## M ODES • UHD: 4096x2160p 24/25, 3840x2160p 24/25/30 • FHD: 1920x1080p 24/25/30/48/50/60 • HD: 1280x720p 24/25/30/48/50/60 Supported SD Card Types Micro SD ................................ Max capacity: 64 GB. Class 10 or UHS-1 rating required Max Bitrate of Video Storage 60 Mbps ............................ Supported File Formats • FAT32/exFAT • Photo: JPEG, DNG • Video: MP4, MOV (MPEG-4 AVC/H.264) Operating Temperature 0°C to 40°C ................................ 

## V ISION 

## P OSITIONING Max Velocity Less than 8 m/s (when 2 m above ............ ground) Altitude Range / Operating Range 50 cm-300 cm .......... Operating Environment Surface with clear pattern and adequate lighting (Lux > 15) 

## B ATTERY 

## C HARGER Voltage 17.4 V .................................................................... Rated Power 100W ............................................................

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## A PP 

## /L IVE 

## V IEW Mobile App DJI GO ............................................................ EIRP 100mW ...................................................................... Power Spectral Density 6.9mW/MHz ............................... Live View Working Frequenc y 2.4GHz ISM Live View Quality 720P @ 30fps (depending on conditions and mobile device) Latency 220ms (depending on conditions and mobile device) Required Operating Systems • iOS 8.0 or later • Android 4.1.2 or later 

## R ECOMMENDED 

## D EVICES iOS iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air Wi-Fi + Cellular, iPad mini 2, iPad mini 2 Wi-Fi + Cellular, iPad Air 2, iPad Air 2 Wi-Fi + Cellular, iPad mini 3, and iPad mini 3 Wi-Fi + Cellular. This app is optimized for iPhone 5s, iPhone 6, and iPhone 6 Plus. Android Samsung tabs 705c, Samsung S6, Samsung S5, Samsung NOTE4, Samsung NOTE3, Google Nexus 9, Google Nexus 7 II, Ascend Mate7, Huawei P8 Max, Nubia Z7 mini, Sony Xperia Z3, MI 3, MI PAD, Smartisan T1. *Support for additional Android devices available as testing and development continues. 

## DJI P HANTOM 

## 3 P ROFESSIONAL 

## I MAGE 

## R EFERENCE

rev A1.1 Page of 10 23TECHNICAL SPECIFICATIONS OF THE DJI INSPIRE 1 SUAS 

## A IRCRAFT Model T600 ......................................................................... Weight (Battery Included) 2935g ...................................... Hovering Accuracy (GPS mode) Vertical: 0.5 m, Horizontal: 2.5 m Max Angular Velocity Pitch: 300°/s, Yaw: 150°/s ............ Max Tilt Angle 35° .............................................................. Max Ascent Speed 5 m/s ................................................... Max Descent Speed 4 m/s ................................................ Max Speed 22 m/s (ATTI mode, no wind) ........................ Max Service Ceiling Above Sea Level 4500 m (Default altitude limit: 120 m above takeoff point) Max Wind Speed Resistance 10 m/s ................................ Max Flight Time Approx. 18 mins .................................... Motor Model DJI 3510H ..................................................... Propeller Model DJI 1345T ................................................ Indoor Hovering Enabled by default ................................ Operating Temperature Range -10° to 40°C .................... Diagonal Distance 559 to 581 mm ................................... Dimensions 438x451x301 mm .......................................... Power Spectral Density 9.06mW/MHz ............................. 

## V ISION 

## P OSITIONING 

## S YSTEM Velocity Range Below 8 m/s (2 m above ground) ........... Altitude Range 5-500 cm ................................................... Operating Environment Brightly lit (lux > 15) patterned surfaces Operating Range 0-250 cm ............................................... 

## G IMBAL Model ZENMUSE X3 .......................................................... Operating Current Station: 750 mA, Motion: 900 mA ..... Angular Vibration Range ±0.03° ....................................... Mounting Detachable ........................................................ Controllable Range Pitch: -90° to +30°, Pan: ±320° ........ Mechanical Range Pitch: -125° to +45°, Pan: ±330° ....... Max Controllable Speed Pitch: 120°/s, Pan: 180°/s ........ 

## C AMERA Name X3 ............................................................................. Model FC350 ...................................................................... Total Pixels 12.76M ............................................................ Effective Pixels 12.4M ....................................................... Image Max Size 4000x3000 ............................................... ISO Range 100-3200 (video), 100-1600 (photo) ............... Electronic Shutter Speed 8s ҆ 1/8000s .......................... FOV (Field of View) 94° ..................................................... CMOS Sony EXMOR 1/2.3” ............................................... Lens 20mm (35mm format equivalent)f/2.8 focus at ∞ 9 Elements in 9 groups Anti-distortion 

## S TILL 

## P HOTOGRAPHY 

## M ODES Single shoot Burst shooting: 3/5/7 frames Auto Exposure Bracketing (AEB): 3/5 bracketed frames at 0.7EV Bias Time-lapse 

## V IDEO 

## R ECORDING 

## M ODES UHD (4K): 4096x2160p24/25, 3840x2160p24/25/30 FHD: 1920x1080p24/25/30/48/50/60 HD: 1280x720p24/25/30/48/50/60 Max Bitrate of Video Storage 60 Mbps ............................ Supported File Formats FAT32/exFAT Photo: JPEG, DNG Video: MP4/MOV (MPEG-4 AVC/H.264) Supported SD Card Types Micro SD ................................ Max capacity: 64 GB. Class 10 or UHS-1 rating required. Operating Temperature Range 0° to 40° C ......................

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## B ATTERY 

## (S TANDARD 

## ) Name Intelligent Flight Battery ........................................ Model TB47 ........................................................................ Capacity 4500 mAh ........................................................... Voltage 22.2V ..................................................................... Battery Type LiPo 6S High voltage battery ..................... Energy 99.9 Wh .................................................................. Net Weight 570g ................................................................. Operating Temperature Range -10° to 40°C .................... Storage Temperature Range Less than 3 months: -20° to 45° C More than 3 months: 22° C to 28° C Charging Temperature Range 0° to 40°C ........................ Max Charging Power 180W .............................................. 

## B ATTERY 

## (O PTIONAL 

## ) Name Intelligent Flight Battery ........................................ Model TB48 ........................................................................ Capacity 5700 mAh ........................................................... Voltage 22.8V ..................................................................... Battery Type LiPo 6S ......................................................... Energy 129.96 Wh .............................................................. Net Weight 670g ................................................................. Operating Temperature Range -10° to 40°C .................... Storage Temperature Range Less than 3 months: -20 to 45° C More than 3 months: 22° to 28° C Charging Temperature Range 0° to 40°C ........................ Max Charging Power 180W .............................................. 

## C HARGER Model A14-100P1A ............................................................ Voltage 26.3V ..................................................................... Rated Power 100W ............................................................ 

## R EMOTE 

## C ONTROLLER Name C1 ............................................................................. Operating Frequency 922.7~927.7 MHz (Japan Only) 5.725~5.825 GHz 2.400~2.483 GHz Maximum Transmitting Distance Up to 5 km or 3.1 miles (unobstructed, free of interference) when FCC compliant Up to 3.5 km or 2.1 miles (unobstructed, free of interference) when CE compliant EIRP 10dBm@900m, 13dBm@5.8G, 20dBm@2.4G ........ Video Output Port USB, mini-HDMI ................................. Power Supply Built-in battery .......................................... Charging DJI charger ........................................................ Dual User Capability Host-and-Slave connection .......... Mobile Device Holder Tablet or Phone ............................ Max Mobile Device Width 170mm .................................... Output Power 9 W ............................................................. Operating Temperature Range -10° to 40°C .................... Storage Temperature Range Less than 3 months: -20° to 45° C More than 3 months: 22° to 28° C Charging Temperature Range 0-40°C .............................. Battery 6000 mAh LiPo 2S ................................................



## DJI G O 

## A PP Mobile Device System Requirements iOS 8.0 or later, Android 4.1.2 or later Supported Mobile Devices iOS * Compatible with iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air Wi-Fi + Cellular, iPad mini 2, iPad mini 2

Wi-Fi + Cellular, iPad Air 2, iPad Air 2 Wi-Fi + Cellular, iPad mini 3, and iPad mini 3 Wi-Fi + Cellular. This app is optimized for iPhone 5s, iPhone 6, and iPhone 6 Plus. Android * Compatible with Samsung tabs 705c, Samsung S6, Samsung S5, Samsung NOTE4, Samsung NOTE3, Google

Nexus 9, Google Nexus 7 II, Ascend Mate7, Huawei P8 Max, Nubia Z7 mini,Sony Xperia Z3, MI 3, MI PAD, Smartisan T1. *Support for additional Android devices available as testing and development continues.

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## DJI I NSPIRE 

## 1 I MAGE 

## R EFERENCE



# Proposed Operations and Limitations In seeking this exemption, LI Gym proposes to operate the DJI Inspire 1 and DJI Phantom 3 Professional sUAS for the commercial purpose of conducting aerial video and photography, aerial surveying, and aerial inspections of equipment, over certain areas of United States, pursuant to the following specific operating limitations. 1. sUAS that are owned and operated by LI Gym shall be flown only by certificated pilots hired directly by LI Gym , possessing at least a private pilot certificate and valid airman medical certificate; and are competent in piloting and operating sUAS. 2. LI Gym shall not permit any pilot in command (PIC) to operate sUAS unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safely operate the sUAS in a manner consistent with operations stated under this exemption, including but not limited to, evasive and emergency maneuvers. PIC qualification flight hours must be logged in a manner consistent with 14 CFR §61.51(b). PIC training flights shall be permitted under the terms of the exemption with the condition that training operations be only conducted during dedicated training sessions. 3. All flight operations shall be conducted in the presence of an additional individual who will act as an safety observer or “spotter”. The spotter will be responsible for observing flight operations as well as the operating environment and will aid in ensuring safe operations. The spotter may also be utilized to satisfy the visual line-of-sight (VLOS) requirement as per Section 333(b)(1) , as long as the PIC maintains VLOS capability. The spotter and the PIC must be able to verbally communicate at all times.

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### 4. All flights will be conducted during daylight hours only and under visual meteorological conditions (VMC). sUAS operations will not be conducted during night, as defined in 14 CFR §1.1. If night operations is required, a special request shall be made at the FAA Standards District Office (FSDO) closest to proposed area of operations. 5. The UAV shall remain clear and yield the right of way to all manned aviation operations and activities at all times. 6. The UAV 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 upon request. 7. The UAV shall only be flown while maintaining VLOS at all times as per Section 333(b) (1) . At no time shall the pilot-in-command (PIC) rely solely on electronic visual telemetry as to constitute the use of “first person view” (FPV) during any flight operations. 8. The location where sUAS will be flown shall be vetted for safety prior to the commencement of any UAV flight. sUAS safety considerations include, but are not limited to, weather conditions, airspace, obstructions, people, property, UAV limitations, and loss-link of radio signal to ground control station equipment. 9. In accordance with 14 CFR §91.7(b), the appropriate sUAS checklist shall be utilized in order to convey the necessary procedures for conducting a preflight safety risk assessment in order to determine that the sUAS is in a condition for safe flight . The result of the tasks outlined on the checklist shall be used to determine a “go” or “no-go” decision for each and every flight. sUAS checklists for the DJI Inspire 1 and DJI Phantom 3 Professional is annexed hereto as Exhibit A and Exhibit B respectively. 10. Prior to the commencement of each flight operation, the designated PIC shall conduct a preflight inspection utilizing the appropriate checklist for the sUAS. The checklist shall insure that each component that comprises the sUAS meets the criteria for safe operation as set forth by the manufacturers operating manual and for the conditions in which the UAV is to be flown. If the preflight inspection reveals a condition that could affect the safe operation of the sUAS, the UAV is prohibited from flying until the necessary remedy can be affected to restore safe operation to the system. If maintenance is required in order to supply a remedy for an unsafe condition, then said maintenance must be logged appropriately. 11. The UAV shall be programmed to return it’s designated point of takeoff within the prescribed operating flight area and commence a safe landing should it loses communication with the ground control station. If during this failsafe condition, the PIC determines that communication to the ground control station has been restored, the

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### PIC shall take command of the UAV and commence a safe landing as soon as practicable. 12. The DJI sUAS software provides a realtime battery capacity indicator, expressed in units of time, that informs the PIC how much power is left in the battery in order to supply sufficient power for the UA to sustain flight. The PIC will be able to quickly determine if enroute operations are to be terminated and a safe landing should commence. The PIC will make every effort to fly the UA back to the point at which the flight commenced and perform a safe landing. In addition, the software implements a “LOW” and "CRITICAL" battery level warning indication. If inconsistent drain on the battery occurs due to flight conditions or maneuvers, the UA shall be programmed to intervene normal flight operations and initiate an automated direct flight path back to it’s point of origin and commence a landing. The PIC will monitor battery capacity during all phases of flight in order to avoid this condition. 13. Commencement of sUAS operations is prohibited unless (considering forecasted weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UAV with at least 20% battery power remaining. 14. All UAVs operated in accordance with this exemption shall be identified by serial number, registered in accordance with 14 CFR §47, and have the appropriate identification (N-Number) markings in accordance with 14 CFR §45 (c). Markings shall be as large as practicable. 15. All sUAS operations shall be conducted on and over private or controlled-access property with expressed permission from the land owner/controller or authorized representative and shall be obtained prior to the commencement of any and all stated operations. 16. When able, locations of operation shall be subdivided in to specific areas in order to facilitate safe operation. These areas are to be identified as a sUAS Preflight Area, sUAS Operations Area, sUAS Crew Support Area. 1. A sUAS Preflight Area will be identified and properly delineated from all other areas. This area shall contain all sUAS equipment and will remain under positive control and supervision by authorized personnel at all times, and have restricted access to authorized personnel only. 2. A UAV Operations Area will be identified prior to the commencement of any flight. It shall include a take-off spot, a given flight path, and a landing spot. All flight paths of the designated flight area shall remain within visual line-of-sight (VLOS); the take-off and landing spot might not be colocated. The pilot-in-command (PIC) shall also identify emergency or abort procedures prior to every flight, along with an associated emergency landing spot should the flight need to be aborted or a failsafe condition occur during the flight. These procedures shall be conveyed to the designated spotter prior to every flight. All flights will be verbally announced by

rev A1.1 Page of 15 23

### the PIC prior to commencement and shall only take place in the identified sUAS Operations Area. 3. A sUAS Crew Support Area will be identified and delineated from every other defined area of operation. This area shall contain all elements necessary in supporting the crew associated with sUAS operations. At no time shall the Crew Support Area be colocated with the sUAS Preflight Area or sUAS Operations Area. The sanctity of each area shall be preserved in order to maintain safety of the equipment and support crew. 17. Under no circumstance shall flights commence in airspace that prohibits sUAS operations. Every flight will be in accordance with current FARs, advisory circulars, and NOTAMS, and in conjunction with local, state and federal law. 18. The documents required fewer than 14 CFR §91.9(b)(2) and §91.203 must be available to the PIC at the Ground Control Station of the UAS any time the UAV is in operation. These documents must be made available to the Administrator or any law enforcement official upon request. 19. All pertinent operating documents as well as the grant of exemption must be accessible during any sUAS 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 shall take precedence. Otherwise, the operator shall follow the procedures outlined in the specified operating documents. The operator may update or revise the operating documents as necessary in order to maintain safe operations. 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 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 FAA granted the exemption, then the operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS-80) shall be contacted if questions arise regarding updates or revisions to the operating documents to the extent that they could pertain to the exemption under which they were granted. 20. Any sUAS that has undergone maintenance or alteration that could affect the operation or flight characteristics of the UAV or one of it’s components, must undergo a functional test flight. The test flight may be limited to the extent of the operation or flight characteristics related to the maintenance or alteration that was made to the sUAS. An entry for each test flight shall be made in the aircraft maintenance log. 21. The owner shall adhere to the sUAS manufacturer’s UAV component maintenance, replacement, inspection, overhaul, and life-limited requirements if so published by said manufacturer. Any and all maintenance or alterations to the sUAS must be logged in

rev A1.1 Page of 16 23

### the appropriate maintenance log and be accompanied by the signature of the authorized person returning the sUAS to service. 22. Each sUAS operated under this exemption shall comply with all manufacturer safety bulletins if so published by said manufacturer. 23. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the 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) per instructions contained on the NTSB web site at http://www.ntsb.gov

.

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# Public Interest Granting this exemption will further the public interest by allowing LI Gym to safely, efficiently, and economically perform aerial video and photography, aerial surveying, and aerial inspections over certain areas of the United States. In addition, the use of the DJI Inspire 1 and DJI Phantom 3 Professional sUAS will decrease congestion of the National Airspace (NAS), reduce pollution, and provide significant benefits to the economy. Notably, the benefits of LI Gym’s proposed operation of said sUAS will be realized without implicating any privacy issues. 

## The Public Will Benefit From Decreased Congestion Of The NAS The DJI Inspire 1 and DJI Phantom 3 Professional sUAS are battery-powered and provide a safe, efficient, and economical alternative to manned aircraft that are traditionally utilized in obtaining aerial imagery. The DJI Inspire 1 and DJI Phantom 3 Professional sUAS do not require an airport for takeoff or landing. By reducing the amount of manned aircraft in the NAS needed to perform low-altitude aerial imagery by way of this exemption, thus allowing the use of said sUAS, a reduction in noise pollution and carbon-based emissions pollution would occur. And most importantly, the safety of people and property in the air and on the ground would increase dramatically. Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. And, this reduction of manned aircraft will result in fewer aircraft that must be handled by air traffic control during the ground, departure, enroute, arrival, and landing phases of flight operations in the NAS. 

## The Public Will Benefit From The Safety And Efficiency Of sUAS Conducting aerial imagery utilizing the DJI Inspire 1 and DJI Phantom 3 Professional sUAS instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution as compared to that generated during traditional low-altitude aerial imagery flight operations. Moreover, by using battery-powered electric motors, the DJI Inspire 1 and DJI Phantom 3 Professional sUAS produce zero air pollution. This is in stark contrast to the pollution generated by the approximately 20-30 gallons per hour of leaded aviation fuel that is burned by traditional cabin class, 6-cylinder, internal combustion aircraft engines during low-altitude aerial video and photography operations. In addition, the DJI Inspire 1 and DJI Phantom 3 Professional sUAS also greatly reduce noise pollution due to the fact that they utilize relatively quiet, battery-powered electric motors rather than an internal combustion engine. By using the DJI Inspire 1 and DJI Phantom 3 Professional sUAS for the acquisition of aerial imagery, the risk to life and property in the air and on the ground will be substantially reduced or in some cases, completely eliminated when compared to traditional manned

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### aircraft flight operations. Risk to life is immediately eliminated due to the fact that sUAS, by definition, do not possess a flight crew onboard. In addition, the DJI Inspire 1 and DJI Phantom 3 Professional sUAS weigh 6.47 pounds and 2.82 pounds respectively and therefore possess less mass than traditional manned aircraft weighing approximately 6,000 pounds. Since the amount of force produced by an object is it’s mass multiplied by it’s acceleration, the DJI Inspire 1 and DJI Phantom 3 Professional sUAS, by the laws of physics, possess less force and therefore less potential for physical damage to life and property on the ground and in the air

. 

## Performing Aerial Video and Photography Operations Utilizing sUAS Will Benefit The Economy In addition to being safe and efficient, the DJI Inspire 1 and DJI Phantom 3 Professional sUAS are also an economical alternative to using manned aircraft to conduct aerial imagery flights operations. It follows that companies based in the United States, like LI Gym, which are allowed to utilized sUAS, will remain competitive and contribute to the overall growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (EPA) regulatory actions that are phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternativetechnologies in order to remain competitive in a global market. Operating the batterypowered DJI Inspire 1 and DJI Phantom 3 Professional sUAS is one such technology that not only allows companies greater operational flexibility compared to traditional manned aircraft, but provides this flexibility without the high operational costs associated with traditional manned aircraft. By operating the DJI Inspire 1 and DJI Phantom 3 Professional sUAS, LI Gym can remain competitive and profitable, and therefore provide greater job stability to employees and contractors - which will ultimately contribute to the overall growth of the U.S. economy. Improved financial performance of U.S. companies, through the commercial use of sUAS provides a stable workforce 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. 

## There Are No Privacy Issues Similar to traditional manned aircraft flight operations that have been implemented for decades to acquire aerial imagery, LI Gym’s proposed operation of the DJI Inspire 1 and DJI Phantom 3 Professional sUAS will not impose any privacy issues. No sUAS flight operations will commence without the expressed permission of the property owner. Furthermore, all sUAS flight operations will be in compliance with local, state and federal laws when applicable and in accordance with the terms and stipulations set forth in this exemption and the FAA.

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# Conclusion As set forth herein, LI Gym respectfully seeks an exemption pursuant to 14 CFR §11.61 and Section 333 of the FMRA of 2012, which will permit safe operation of the DJI Inspire 1 and DJI Phantom 3 Professional sUAS commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography, aerial surveying, and aerial inspections of equipment over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FMRA of 2012, while also advancing the interests of the public by allowing LI Gym to safely, efficiently, and economically operate the DJI Inspire 1 and DJI Phantom 3 Professional sUAS commercially within the NAS. Respectfully,

submitted this 30 th 

### day of December 2015 Philip J. Coccari, President Andrew S. Coccari, Inc. d.b.a. Long Island Gymnasium Equipment Company 1400 Penataquit Avenue Bay Shore, NY 11706 (631) 666-9513 ・ pcoccari@ligym.com

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# Exhibits Exhibit A - DJI Inspire 1 sUAS Checklist

rev A1.1 Page of 21 23 Checklist DJI - Inspire 1 

### PreFlight

➡ Landing Gear Extended ➡ Install Props - Check Position/Secured ➡ Install Gimbal/Camera - Secured ➡ Motors - Secured ➡ VPS - Clear ➡ Gimbal Dampeners - Secured ➡ SD Card - Installed ➡ Lens Cover - Remove ➡ Gimbal Lock - Remove ➡ Battery - Installed/Charged ➡ Tablet Computer - Installed/Secured ➡ USB - Connected ➡ Tablet On - Charged ➡ TX On - Charged ➡ TX Antennas - Erect/Parallel ➡ DJI App - Invoked ➡ Neck Strap - On/Attached 

### Before Take-off

➡ Power - On ➡ Battery -Charged ➡ Camera - Live ➡ State - Validate ➡ Compass - Calibrated ➡ Camera Settings - Verified ➡ Satellites - Acquire d ➡ Home Point - Recorded 

### Take-off ๏ Environment - Cleared & Secured ๏ Obstructions - None ๏ Flight Plan - Reviewed CLEARED FOR DEPARTURE 

### Before Landing ๏ Environment - Secured ๏ Obstructions - None ๏ Landing Gear - Extended 

### After Landing

➡ PH3 Power - Off ➡ TX - Off ➡ DJI APP - Closed ➡ Tablet - Off

## Exhibit B - DJI Phantom 3 Professional sUAS Checklist

rev A1.1 Page of 22 23 Checklist DJI - Phantom 3 Professional 

### PreFlight

➡ Install Props - Check Position/Secured ➡ Gimbal/Camera - Secured ➡ Motors - Secured ➡ VPS - Clear ➡ Gimbal Dampeners - Secured ➡ SD Card - Installed ➡ Lens Cover - Remove ➡ Gimbal Lock - Remove ➡ Battery - Installed/Charged ➡ Tablet Computer - Installed/Secured ➡ USB - Connected ➡ Tablet On - Charged ➡ TX On - Charged ➡ TX Antennas - Erect/Parallel ➡ DJI App - Invoked ➡ Neck Strap - On/Attached 

### Before Take-off

➡ Power - On ➡ Battery -Charged ➡ Camera - Live ➡ State - Validate ➡ Compass - Calibrated ➡ Camera Settings - Verified ➡ Satellites - Acquire d ➡ Home Point - Recorded 

### Take-off ๏ Environment - Cleared & Secured ๏ Obstructions - None ๏ Flight Plan - Reviewed CLEARED FOR DEPARTURE 

### Before Landing ๏ Environment - Secured ๏ Obstructions - None ๏ Landing Gear - Extended 

### After Landing

➡ PH3 Power - Off ➡ TX - Off ➡ DJI APP - Closed ➡ Tablet - Off

## Exhibit C - Example sUAS Maintenance Log

rev A1.1 Page of 23 23 DJI Phantom 3 Professional Service Log [N-Number] Service and Maintenance Record Date Total Time Maintenance Performed