1 October	26 ,	2015

In	Reply	Refer	To: Liftoff	Aerials	LLC Cory	Fechner 600	N	Lilac	Drive (612)	987

- 4568 Suite	209
info@liftoffaerials.com Minneapolis, MN	55422

Subject : Request	 for Exemption	 from 14	CFR §	61.23(a)	and	(c),	61.101(e)(4) and	 (5),	 61.113(a),	 61.315(a),	 91.7(a),	 91.119(c),	 91.121, 91.151(a)(1),	 91.405(a),	 91.407(a)(1),	 91.409(a)(1)	 and	 (2),	 and 91.417(a)	and	(b),	to	the	extent	necessary	to	allow Liftoff	Aerials	LLC

to	o perate	Unmanned	Aerial	Systems	to perform	aerial	data	collection in	the	National	Airspace	System

Enclosure : (1)

Technical	Brochures for DJI	Phantom	3,	Located:

http://download.dji

innovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_ v1.0_en.pdf Technical	Brochures	for	Tarot	680,	Located:

http://www.tarot

- rc.com/index.php?main_page=product_info&products_id=195 Technical	Brochures	for	DJI	S800	EVO,	Located:

http://download.dji

innovations.com/downloads/s800evo/en/S800_EVO_User_Manual_v1 .10_en.pdf

References : (1)	Approved	Exemption	13125 (2)	Approved	Exemption	13117 (3)	Approved	Exemption	13124

Dear	Sir	or	Madam,

Liftoff	 Aerials	 LLC (herein	 after	 “ Liftoff ” or	 “the	 operator” )	 respectfully	 requests review	of	the	following	application for	exemption	from	14	CFR	§§	61.23(a)	and	(c), 61.101(e)(4)	and	(5), 61.113(a),	61.315(a),	91.7(a),	91.119(c),	91.121,	91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and	(2),	and	91.417(a)	and	(b)	as	it	relates to the	operation	of	Unmanned	Aerial	Sys tems (UAS) to	perform	aerial	data	collection. This	application	is	submitted	p ursuant	to	Section	333	of	the	FAA	Moder nization	and

Reform	Act	of	2012 (FMRA)

.2 This	 exemption	 will	 permit Liftoff to	 operate	 UAS	 for	 the	 purpose	 of	 conducting

commercial	video	a nd	photography	of	residential	real	estate,	commercial	real	estate, construction	sites,	landscapes	and	events	over	certain	areas	of	the	United	States.

Background

Liftoff is	 a	 premier	 marketing	 strategy	 firm	 focused	 on	 unique	 solutions	 for	 its

clients. L iftoff provides	personalized	modeling,	brand	listing,	and	analytics	services, as	 well	 as	 media	 creation	 and	 editing	 services. The	 objective	 of	 this	 exemption application	is	 for Liftoff to	better	serve	its	customers	and	community	by	providing unique,	high

- quality	media	in	a	safe	and	compliant	manner.

UAS to	be	Used	During	Operations

Liftoff requests	an	exemption	 to	 operate all	 variants	 of the	DJI	 Phantom	 3	 ( herein

after	“Phantom	3” ) ,	Tarot	680, and	DJI	S800	EVO (herein	after	“S800”) (collectively

referred to	as	UAS) for	hire	within	the	National	Air space System	(NAS)

. Enclosure (1) contains	 copies	 of	 the	 technical	 data	 manuals	 associated	 with	 each	 UAS platform. Previous	examples	 of	exemptions	granted	 to	 companies	 seeking	 similar

authorizations	are	include d	in References	(1),	(2), and (3). T he	Phantom	3 ,	Tarot

680 and	 S800	 are	 vertical	 takeoff	 and	 landing	 (VTOL)	 UAS’	 which	 utilize	 ground

control	 stations (GCS)	 that	 will	 operate between	 the	 2.4	 GHz	 and	 2.483	 GHz frequencies.	 	 These	 frequencies	 are	 the	 ones proscribed	 by	 the	 manufacturer	 and

will	not	be	altered. An	authorized	Pilot	 In	Control	(PIC),	who	holds	a	private	pilot

certificate	 and	 at	 least	 a	 current	 third

- class	 medical	 certificate,	 and	 undergoes	 at least	 twenty	 (20)	 training	 flights	 lasting no	 less than 20	 minutes	 on	 each	 UAS platform,	will	operate	the	UAS

.

T he	Phantom	3 ,	Tarot	680 and	S800	will	be	identified	by	serial	number,	registered in	accordance	with	14	CFR	part	47,	and	have	identification	(N−Number)	markings	in accordance	 with	 14	 CFR	 part	 45,	 Subpart	 C.	 The	 markings	 will	 be	 as	 large	 as practical. T he	Phantom	3 ,	Tarot	680 and S800	may	be	fitted	with	eithe r	GoPro	Hero (all	variants)	or Panasonic	GH4	cameras	(all	variants).

In	 addition, all UAS operated	 by	 Liftoff will	 be fitted	 with Global	 Position	 System ( GPS ) safety	features	that will	limit	their	ability to	fly	above	400	fee t, not	allow	them

to exceed	2 0	knots	speed, not	allow	operations	within	5	miles	of	an	active	airfield,

and allow	 the	 UAS	 to	 return	 to	 a	 predetermined	 location	 in	 the	 event	 that

communication	with	 the PIC is	lost. In	addition,	neither	 the	Phantom	3,	Tarot 680 nor	S800	will	operate	beyond	the	PIC	line	of	sight	or	without	a	spotter	(also	referred to	as	“safety	observer”).

Liftoff will	use	manufacturers	service	centers	 to	perform	maintenance,	alterations, or	 preventive	 maintenance	 on	 the	 UAS	 using	 only	 the	 me thods	 and	 practices

outlined	 in	 the manufacturer operating manuals

. Liftoff will	 document	 all

maintenance	 conducted	 on	 the	 Phantom	 3 ,	 Tarot	 680 and	 S800	 and	will	maintain3 those	 records	 in	 perpetuity. Liftoff will	 also	 implement	 a	 stringent	 operators

manu al	to	cover	all	aspects	of	UAS	operation s

. Liftoff will	designate	an	“authorized person”	 to	oversee	 the	administration	of	 the operator’s manual,	and	sign	off	on	all records	associated	with	the	UAS	being	flown.

Petition Details

In	 consideration	 of	 the	 sp eed,	 size,	 weight	 and	 limited	 operating	 area	 associated with	 the	UAS	and	 their	 operation, Liftoff ’s	 operation	 of	 the	Phantom	3 ,	Tarot	680

and	 S800	 meets	 the	 conditions	 of	 FMRA	 Section	 333	 and	 therefore	 would	 not require	airworthiness	certificates	as	outli ned	in	14	CFR	§	21.

Furthermore, Liftoff requests	r eli ef	from	certain	requirements	outlined	below :

! 14	CFR	§	61.23(a)	&	(c)

Liftoff requests	 relief	 from certain	 requirements	 of this	section	because	 the

UAS operations	will	be	accomplished	by	a	PIC	holding a	 third

- class	medical

certificate

.

! 14	CFR	§	61.101(e)(4)	and	(5)

Liftoff requests	 relief	 from certain	 requirements	 of this	 section	 because it’s UAS	have	more	 than	one	motor	but	are	unmanned,	do	not	carry	occupants, and	do	not	have	retractable	landing	gea r.		 In	addition,	Liftoff	requests	relief from	 this	 section	 because	 it	 is	 seeking	 to	 conduct its operations	 for compensation.

! 14	CFR	§ 61.113(a)

Liftoff requests	relief	from	certain	requirements	of	this	section	to	the	extent necessary	to	allow	a PIC holding a	private	pilot	or	higher	level	certificate,	as

well	 as a	 third

- class	 medical	 certificate ,	 and	 who	 has	 demonstrated,	 by meeting	minimum	flight	hour	and	currency	requirements,	that	the	PIC	is	able to	 safely	 operate	 the	 Phantom	 3 ,	 Tarot	 680 and	 S800	 UAS	 in a	 manner consistent	with	this	exemption,	including	evasive	and	emergency	maneuvers and	 maintaining	 appropriate	 distances	 from	 people,	 vessels,	 vehicle	 and

structures.

! 14	CFR	§ 61.315(a)

Liftoff requests	 relief	 from certain	 requirements	 of this	 section	 beca use	 it wishes	to	conduct	its	flight	operations	for	hire	and	to	be	compensated	by	its

customers.

! 14	CFR	§ 91.7(a)

Liftoff requests relief from certain	 requirements	 of this	section	because	 the

Phantom	3 ,	Tarot	680 and	S800	do	not	require	an	airworthiness	cer tificate	in

accordance	with 14	CFR	§	21. Liftoff certifies	that	it	will	ensure	the	Phantom

3 ,	 Tarot	 680 and	 S800	 are	 in	 airworthy	 condition	 prior	 to	 every	 flight	 by determining	 that	 the	 systems	 are	 operating	 in	 accordance	 with	 the manufacturer	operating	d ocuments,	and	are	in	safe	conditions	for	flight.4 ! 14	CFR	§ 91.119(c) Liftoff	 requests	 relief	 from	certain	 requirements	 of	 this	section because	 the

UAS will	not	be	operated	more	than	4 00	feet	off	the	ground	and	will	maintain a	safe	distance	from	people	and objects,	as	well	as	utilize	the	safety	systems mentions	in	the	previous	paragraphs.

! 14	CFR	§ 91.121 Liftoff	 requests	 relief	 from	certain	 requirements	 of	 this	section because	 the UAS	will	 not	 be	equipped	with	 the	 typical	 barometric	altimeters	 present	in

ma nned	 aircraft. Altitude on	 the	 UAS	 will	 be	 provided	 to	 the	 PIC	 via	 GPS equipment	and	radio	communications	with	the	GCS.		In	addition, neither	the Phantom	3,	Tarot	680	nor	S800	will	operate beyond	 the	PIC	line	of	sight	or without	a	spotter (also	referred	t o	as	“safety	observer”)

.

! 14	CFR	§ 91.151(a)(1) Liftoff	 requests	 relief	 from	 certain	 requirements	 of	 this	 section because safety	 will	 not	 be	 affected	 by	 operation	 of	 a	 UAS	 during daylight hours	 in visual	 meteorological	 conditions	 under	 visual	 flight	 rules	 w ith	 enough battery	 power	 to	 fly	 for	 a	 total	 duration	 of	 approximately	 20	 minutes. Battery	power	indicators	will	be	present	on	all	UAS	and	GCS,	and	the	PIC	will not	allow	any	system	to	operate	beyond	the	point	of	safe	return.

! 14	CFR	§ 91.405(a)

Liftoff	 re quests	 relief	 from	certain	 requirements	 of	 this	section because	 the UAS	 will	 be	 maintained	 in	 accordance	 with	 the	 manufacturer	 operating documents	and	will	only	be	repaired/overhauled	by	 the	original	equipment

manufacturer.	 	The	UAS	will	 not	 be	 flown	if	 ob vious	 flaws	 or	 known	issues exist	with	the	equipment. Furthermore,	UAS	will	be	visually	inspected	by	the PIC	prior	to	each	flight	and,	additionally,	after	each	flight	has	concluded.

! 14	CFR	§ 91.407(a)(1) Liftoff	 requests	 relief	 from	certain	 requirements	 o f	 this	section	because	 the UAS	 will	 be	 maintained	 in	 accordance	 with	 the	 manufacturer	 operating documents	and	will	only	be	repaired/overhauled	by	 the	original	equipment

manufacturer.	 	The	UAS	will	 not	 be	 flown	if	 obvious	 flaws	 or	 known	issues

exist	with	th e	equipment. Furthermore,	UAS	will	be	visually	inspected	by	the PIC	prior	to	each	flight	and,	additionally,	after	each	flight	has	concluded.

! 14	CFR	§	91.409(a)(1)	and	(2) Liftoff	 requests	 relief	 from	certain	 requirements	 of	 this	section	because	 the

UAS	 wi ll	 be	 maintained	 in	 accordance	 with	 the	 manufacturer	 operating documents	and	will	only	be	repaired/overhauled	by	 the	original	equipment

manufacturer.	 	The	UAS	will	 not	 be	 flown	if	 obvious	 flaws	 or	 known	issues exist	with	the	equipment. Furthermore,	UAS	wi ll	be	visually	inspected	by	the PIC	prior	to	each	flight	and,	additionally,	after	each	flight	has	concluded.

! 14	CFR	§	91.417(a)	and	(b) Liftoff	 requests	 relief	 from	certain	 requirements	 of	 this	section because	 the UAS	 referenced	 in	 this	 application	 for	 exe mption will	 be	 inspected	 an d maintained	 in	 accordance	 with	 the	 manufacturer	 operator	 manuals

. Furthermore, Liftoff certifies	 that	 it	 will	 document	 all	 maintenance5 conducted	 on	 the	 Phantom	 3 ,	 Tarot	 680 and	 S800	 and	 will	 maintain	 those records	in	perpetuity

.

In	 accordance with	 14	 CFR	 §	 11.81, Liftoff	 Aerials	 LLC provide s the	 following information	in	support	of	its	exemption	request:

1. Contact	Information:

Cory	Fechner Owner,	President

Liftoff	Aerials	LLC

600	N	Lilac	Drive

Suite	209 Minneapolis,	MN	55422 ( 612)	987

- 4568
info@liftoffaerials.com

2. Public	Interest

Approval	 of	 this	 request	 for	 exemption	 will	 further	 the	 public	 interest	 by allowing Liftoff	Aerials	LLC to	safely,	efficiently	and	economically perform	aerial video	 and	 photography	 for	 local	 businesses	 who	 would	 otherwise	 not	 benefit from	 the	 technological	 advantages	 that	 larger,	 nationwide	 companies,	 hold. Furthermore, Liftoff	Aerials	LLC is	a	small	business that desires	to	perform	well and	 supp ort	 its	 community.	 	 Granting	 this	 exemption	 will	 allow Liftoff	 Aerials

LLC to	expand	its	local	economic	footprint	and	provide	greater	opportunities	to

the	local	workforce.

In	addition,	granting	of	this	exemption	request	will	reduce	pollution	that	would

ot herwise	 be	 produced	 by	 air

- breathing	 manned	 aircraft performing	 the	 same type	of	work .		As	the	Phantom	3 ,	Tarot	680 and	S800	are	battery	powered,	they would	 eliminate	 all	 carbon	 emissions	 that	 would	 otherwise	 be	 produced	 by manned	operations.		The	Phantom 3 ,	Tarot	680 and	S800	are	also	smaller than their	 manned	 alternatives, which	 means	 not	 needing	 vast	 airports	 for operations/maintenance,	and	decreased	noise	pollution.

3. Safety

In	consideration	of	the	size,	weight,	speed,	and	limited	operating	area	associa ted with	 the	 UAS	 and	 their	 operation, Liftoff ’s	 operation	 of	 the	 Phantom	 3 ,	 Tarot

680 and	 S800	 meet	 the	 conditions	 of	 FMRA	 Section	 333,	 and	 will	 not	 require

airworthiness	certificates	in	accordance	with	14	CFR § 21.		Section	333	provide authority	 for	UAS to	 operate	without	airworthiness	 certification	and	 sets	 forth requirements	for	consideration	whether	a	UAS	will	crate	a	hazard	to	users	of	the NAS	or	the	public,	or	otherwise	pose	a	threat	to	national	security.6 Liftoff certifies	that	the	Phantom	3 ,	Tarot 680 and	S800	can	operate	safely	in	the NAS	 as	 demonstrated	 by	 their	 system	 characteristics,	 the	 pilot	 certification requirement,	and	specific	operation	limitations	outlined	in	this	request.

T he	Phantom	3 ,	Tarot	680 and	S800	can	be	operated	in	manned	or	au tonomous (hover)	 mode.	 	 Further	 explanations	 of	 these	 capabilities	 are	 included	 in Enclosure	(1) .		Furthermore:

o All UAS	 will	 be	 equipped	 with	 the	 ability	 to	 automatically	 land	 at	 a

pre

- determined	site	in	the	event	communication	is	lost	with	the	GCS.

o The Phantom	 3 ,	 Tarot	 680 and	 S800	 will	 only	 be	 operated	 in accordance	 with	 the	 manufacturer	 operating	 manuals.	 	 No	 activities

outside	those	manuals	will	be	allowed.

o The	UAS	will	only	be	operated	within	the	PIC	line	of	sight

o A safety	 observer will	 always	 be	 pre sent	 when	 the	 UAS	 are	 in operation

Additional Self

- Imposed	Limitations

In	 requesting	 this	 exemption, Liftoff is	 seeking	 authorization	 to	 operate	 the

Phantom	 3 ,	 Tarot	 680 and	 S800	 unmanned	 aerial	 systems	 for	 the	 purpose	 of conducting a erial	video	and	phot ography	pursuant	to	the	following	limitations:

1. Operations	 authorized	 by	 this	 grant	 of	 exemption	 will	 be	 limited	 to	 the

Phantom	3 ,	Tarot	680 and	S800	UAS	described	in	the	operating	documents, weighing	 less	 than	 55	 pounds	 maximum	 gross	 weight.	 	 Operations	 o f	 any other	UAS	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	photography	and	video.

3. The	UAS	may	not	be	flown	at	speeds	exceeding	20	kn ots.

4. The	 UAS	 will	 be	 operated	 at	 an	 altitude	 of	 no	 more	 than	 400	 feet	 above ground	 level	 (AGL)	 unless	 a	 special	 request	 is	 made	 and	 approved	 by	 Air Traffic	Control	(ATC).		All	altitudes	reported	to	ATC	will	be	in	AGL.

5. The	UAS	will	operate	within	the	PIC’s visual	line	of	sight	at	all	times.		The	PIC will	 only	 use	 human	 vision,	and	will	 not	 be	aided	 by	any	 device	 other	 than corrective	lenses,	as	specified	in	their	medical	certificate.

6. First	person	view	(FPV)	by	the	PIC	or	spotter	is	not	permitted

7. All	 operatio ns	 must	 utilize	 a	 safety	 observer	 (SO).	 The	 SO	 may	 be	 used	 to satisfy	 the	 VLOS	 requirement	 as	 long	 as	 the	 PIC	 always	 maintains	 VLOS capability.	The	SO	and	PIC	must	be	able	to	communicate	verbally	at	all	times. Electronic	messaging	or	texting	is	not	permitt ed	during	flight	operations.	The PIC	 must	 be	 designated	 before	 the	 flight	 and	 cannot	 transfer	 his	 or	 her designation	for	the	duration	of	the	flight.	The	PIC	must	ensure	that	the	SO	can perform	the	functions	prescribed	in	the	operating	documents.

8. The	 SO	 mu st	 not	 perform	 any	 other	 duties	 beyond	 assisting	 the	 PIC	 with seeing	 and	 avoiding	 other	 air	 traffic	 and	 other	 ground	 based7 obstacles/obstructions	and	is	not	permitted	 to	operate	 the	camera	or	other

instruments.

9. If	granted	under	 this	application,	 the	opera ting	documents	and	 the	grant	of exemption	must	be	accessible	during	UAS	operations	and	made	available	 to

the	Administrator (or	 their	delegate,	including	local	law	enforcement) upon request.	 If	 a	 discrepancy	 exists	 between	 the	 conditions	 and	 limitations

con tained	 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.	 Otherwise,	 the	 operator must	 follow	 the	 procedures	 as	 outlined in	 its	 operating	 documents.	 The operator	may	update	 or	 revise	its	 operating	documents.	 It	is	 the	 operator’s responsibility	 to	 track	 such	 revisions	 and	 present	 updated	 and	 revised documents	 to	 the	 Administrator	 upon	 request.	 The	 operator	 must	 also

present updated	 and	 revised	 documents	 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 amend ment	 to	 its	 grant	 of exemption.

10. Prior	 to	 each	 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	op erating	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	th e	aircraft	records.

11. Any	UAS	 that	has	undergone	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	t est	flight	must	make	an	entry	in	the	aircraft	records.

12. Pre

- flight	 inspections	 must	 occur	 prior	 to	 every	 flight.	 	 The	 pre

- flight inspection	 must	 account	 for	 all	 potential	 discrepancies,	 e.g.	 inoperable components,	 items,	 or	 equipment,	 not	 already	 covered	 i n	 the	 relevant sections	of	the	operating	documents.

13. Liftoff must	 follow	 the	 UAS	 manufacturer’s	 aircraft/component, maintenance,	overhaul,	replacement,	inspection,	and	life	limit	requirements.

14. Liftoff must	 carry	 out	 its	 maintenance,	 inspections,	 and	 recor d	 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	accompl ished,	and	the	signature	of	the	person	returning

the	UAS	to	service.

15. Each	UAS	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.8 17. The	PIC	must	possess	at	least	a	private	pilot	certificate	and	at	least	a	current

third

- class	medical	certificate.		These	documents	will	be	present	with	the	PIC during	all	UAS	flights.

18. Liftoff will	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	 maneuv ers	 and	 maintaining appropriate	 distances	 from	 persons,	 vessels,	 vehicles	 and	 structures.	 PIC qualification	flight	hours	will	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 requested under	 the	 terms	 of	 the	 exemption,	 if	 granted.	 However,	 training operations	will	only	be	conducted	during	dedicated	training	sessions.	During training,	 proficiency,	 and	 experience

- building	 flights,	 all	 persons	 not essential	for	flight	operations	will	be	co nsidered	nonparticipants,	and	the	PIC must	 operate	 the	 UA S with	 appropriate	 distance	 from	 nonparticipants	 in accordance	with	14	C.F.R.	§	91.119.

19. UAS	operations	will	not	be	conducted	during	night,	as	defined	in	14	C.F.R.	§ 1.1.	All	operations	will	be	condu cted	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	requested	or	authorized.

20. T he	UAS	will	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	wit h	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.

21. The	UAS	will	not	be	operated	less	than	500	feet	below	or	less	than	2,000	feet horizontally	from	a	cl oud	or	when	visibility	is	less	than	3	statute	miles	from

the	PIC.

22. If the	UAS	loses	communications	or	loses	its	GPS	signal,	it	will	return	to	a	pre

determined	 location	 within	 the	 planned	 operating	 area	 to	 land	 and	 will	 be

recovered	in	accordance	with Lifto ff ’s	operating	documents.

23. The	 PIC	 must	 abort	 the	 flight	 in	 the	 event	 of	 unpredicted	 obstacles	 or emergencies	in	accordance	with	the	operating	documents.

24. The	PIC	will	be	prohibited	 from	beginning	a	 flight	unless	(considering	wind

and	 forecast	 weather	 cond itions)	 there	 is	 enough	 power	 to	 fly	 at	 normal cruising	 speed	 to	 the	 intended	 landing	 point	 and	 land	 the	 UAS	 with	 25% battery	power	remaining.

25. Liftoff must	 obtain	 an	 Air	 Traffic	 Organization	 (ATO)	 issued	 Certificate	 of Waiver	or	Authorization	(COA)	prior to	conducting	any	operations	under	the grant	 of	 exemption.	 This	 COA	 will	 also	 require	 the	 operator	 to	 request	 a Notice	to	Airman	(NOTAM)	not	more	than	72	hours	in	advance,	but	not	less than	 48	 hours	 prior	 to	 the	 operation.	 All	 operations	 shall	 be	 conducted in accordance	 with	 airspace	 requirements	 in	 the	 ATO	 issued	 COA	 including class	of	airspace,	altitude	level	and	potential	transponder	requirements.9 26. All	 UAS	 operated	 with	 the	 exemption	 will	 be	 identified	 by	 serial	 number, registered	 in	 accordance	 with	 14	 C FR	 Part	 47	 and	 have	 identification marking	in	accordance	with	14	CFR	Part	45.

27. Before	 conducting	 operations, Liftoff will	 ensure	 the	 radio	 frequency spectrum	used	 for	operation	and	control	of	the	UA	comply	with	the	Federal Communications	 Commission	 (FCC)	 or other	 appropriate	 government oversight	agency	requirements.

28. The	documents	required	under14	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	upon	request.

29. The	UAS	will	remain	clear	and	yield	the	right	of	way	to	all	manned	aviation operations	and	activities	at	all	times.

30. The	UAS will not	be	operated	by	the	PIC	from	any	moving	device	or	vehic le.

31. Flight	operations	will	be	conducted	at	least	500	feet	from	all	nonparticipating persons	 (persons	 other	 than	 the	 PIC,	 safety	 observer,	 operator	 trainees	 or essential	persons),	vessels,	vehicles,	and	structures	unless:

a. Barriers	 or	 structures	 are	 present that	 sufficiently	 protect nonparticipating	persons	 from	 the	UAS	and/or	debris	in	 the	event	of an	 accident.	 The	 operator	 will	 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	operations	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 operating	 closer	 to	 those	 objects	 and	 determined	 that	 it	 does	 not present	an	undue	hazard,	and;

c. Operations	 nearer	 to	 the	 PIC,	 safety	 observer,	 operator	 trainees	 or essential	 persons	 do	 not	 present	 an	 undue hazard	 to	 those	 persons per	§	91.119(a).

32. All	 operations	will	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

representa tive	will	be	obtained	in	writing	for	each	flight	to	be	conducted.

33. Any	 incident,	 accident,	 or	 flight	 operation	 that	 transgresses	 the	 lateral	 or vertical	boundaries	of	the	operational	area	as	defined	by	the	applicable	COA

will be	 reported	 to	 the	 FAA's	 UAS	 In tegration	 Office	 (AFS

- 80)	 within	 24

hours.	 Accidents will be	 reported	 to	 the	 National	 Transportation	 Safety Board	 (NTSB)	 per	 instructions	 contained	 on	 the	 NTSB	 Web	 site: www.ntsb.gov.10 Conclusion

As	described	in	 this	request	 for	exemption, Liftoff	Ae rials	LLC seeks	an	exemption from	14	CFR	§	61.23(a)	and	(c),	61.101(e)(4)	and	(5),	61.113(a),	61.315(a),	91.7(a), 91.119(c),	91.121,	91.151(a)(1),	91.405(a),	91.407(a)(1),	91.409(a)(1)	and	(2),	and 91.417(a)	 and	 (b) pursuant	 to	 14	 CFR	 Part	 11.16	 and	 Sectio n	 333	 of	 the	 FMRA, which	will	permit	the	safe	operation	of	the	DJI	Phantom	3 ,	Tarot	680 and DJI S800

EVO UAS	 commercially	 for	 the	 purposes	 of	 conducting	 aerial	 photography	 and

video.

By	granting	this	Petition,	the	FAA	Administrator	will	be	fulfilling	the Congressional mandate	 of	 the	 FAA	Modernization	and	Reform	Act	 of	 2012,	while	also	advancing the	interests	of	 the	public,	by	allowing Liftoff	Aerials	LLC to	safely,	efficiently,	and economically	 operate	 the	 DJI	 Phantom	 3 ,	 Tarot	 680 and DJI S800 EVO UAS

comm ercially	 within	 the	 NAS. Previous	 examples	 of	 exemptions	 granted	 to companies	seeking	similar	authorizations	are	included	in References	(1),	(2), and (3).

Therefore ,	 in	 accordance	 with	 the	 Federal	 Aviation	 Regulations	 and	 the	 FAA

Modernization	and	Reform Act	of	2012,	Section	333, Liftoff	Aerials	LLC respectfully requests	 that	 the	 Administrator	 grant	 this	 Petition	 for	 an	 exemption	 and	 permit

Liftoff	Aerials	LLC to	operate	 the	DJI	Phantom	3 ,	Tarot	680 and DJI S800 EVO UAS commercially	 for	 the	 purpose	 of	 con ducting	 aerial	 photography	 and	 video	 and photography	over	certain	areas	of	the	United	States.

Respectfully

,

Cory	Fechner Owner,	President

Liftoff	Aerials	LLC