UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

800 Federal Aviation Administration WASHINGTON, DC 20591

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: Chesapeake Drone Service

FOR AN EXE MPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14

OF THE CODE OF FED ERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a),
91.121, 91.1 51(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417 (a) & (b)

CONCERNING COMMERCIAL OPERATION OF DJI Phan tom 3 Professional

UNMANNED AIRCRAFT SYSTEM SPURSUANT TO SECTION 333 OF THE FAA

MODER NIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)

Submitted on August 13 , 2015 George S Prince

d ba/ Chesapeake Drone Service

111 Burton Air Drive Centreville, MD 21617 Gsprince16@yahoo.com

410

- 739

- 4370

SUMMARY Chesapeake Drone Service seeks exemption from the requir ements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a) (1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unma nned Aircraft System pursuant to Section

333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Chesapeake Drone Service t o operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography to be us ed primarily in

1. Farm land surveys

, crop health

, and pesticide use to reduce the amount of

chemicals need ed in order to reduce Nitrogen and P hosphorous entering the Bay

. The largest source of pollution to the Bay comes from agricultural

runoff , which contributes roughly 40 percent of the nitrogen and 50 percent o f the phosphorus

.

2. Industrial I nspection purposes

3. R eal estate

4. General photography & video services

... over certain areas of the United States.BACKGROUND

Unmanned Aircraft Systems: DJ I Phantom 3 Professional

Chesa peake Drone Service seeks an exemption to operate DJI systems for compensation or hire within the NAS. The DJI Phantom 3 Professional is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) u tilizing electronic tablet or smart

p hone systems.

The DJI Phantom 3 Professional has a maximum gross weight of approxim ately 2 pounds 11 ounces, while having a length of 16 inches width of 16 inches, he ight of 8
inches, and a maximum speed of approximatel y 29 knots. The DJI Phantom 3

Professional is equipped with four main rotors; dr iven by Lithium Polymer batte ry powered electric motors.

The DJI Phantom 3 P rofessional will be operated by a licensed pilot as required , and

will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft , as well as 14 C.F.R Part 47, Aircraft Registration , and marked in accordance with 14 C.F.R.
Part 45, Identification and Registration Marking

.

BASIS FOR PETITION

Petitioner, Chesapeake Drone Service , pursuant to the provision s of the Federal

Aviation Regulations (14 C.F.R. § 11.61) and the FAA Moder nization and Reform Act of

2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems

, hereby petitions the Administrator to commercially operate the DJI Phantom 3 Professional UAS in the National Airspace System (NAS) , and for an exemption from

the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

In consideration of the s peed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, the operation of DJI Phantom 3

Professional meets the con ditions of FMRA Section 333 and therefore, will not require

an airworthiness certificate in acc ordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, Chesapeake Drone Service requests relief fro m Sections 91.405(a), 91.407(a) (1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraf t with an airworthiness certificate.

Chesapeake Drone Service submits that the requested relief is p roper since an equivalent level of safety will be ensured. Chesapeake Drone Service will use experien ced personnel or technicians to perform maintenance, alterations, or prev entive

ma intenance on the UASs using the methods, techniques, and practices prescribed inthe ope rating documents (i.e., Monthly Maintenance Log, and DJI Pha ntom 3

Professional Instruction Manual).

Furthermore, Chesapeake Drone Service will document and maintain all maintenance

records for the DJI Phantom 3 Professional UAS

.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command , is requested by Chesapeake Drone

Service to the extent necessary to allow a Pilot in Command (PIC) ho lding a private pilot or higher level certificate, as well as an airman medical certificat e, and who has demonstrated, by meeting minimum flight

- hour and currency requirements, and who

will receive multi

- rotor training by us that the PIC is able to safely operate the DJ I

Phantom 3 Professional UAS in a manner consistent with this exemption, including

evasive and emer g ency maneuvers and maintaining appropriate distances from people,
vessels, vehicles and structures.

Chesapeake Drone Service seeks relief from Section 91.7(a), enti tled Civil aircraft

airworthiness , because the DJI Phantom 3 Professional UAS do es not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As
such, Chesapeake Drone Service submits that he will ensure that the DJI Phantom 3

Profess ional is in an airworthy condition, prior to every flight, by determining

that the UAS is in compliance with the ope rating documents (i.e., Monthly Maintenance Log, and DJI Pha ntom 3 Professional Instruction Manual), and that the aircraft is in a

conditio n for safe flight.

Chesapeake Drone Service also seeks an exemption from the requirements of Section
91.121, entitled Altimeter Settings , as the DJI Phantom 3 Professional does not have a typical barometric altimeter onboard. However, altitude information of the D JI

Phantom 3 Professional will be provided to the PIC via Global Positioning System (GPS) equipment and radio comm unications telemetry data link, which downlinks from

the UA to the Transmitter for active monitoring of the flight path.

This altitude information, combined with visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, Chesapeake Drone Serv ice seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions

. Chesapeake

Drone Service submits that safety will not be affected by operation of the DJI Phantom 3 Professional during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration of approximately 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

In accordance with 14 C.F.R. § 11.81, Chesapeake Drone Service provides the following information in support of its petition for exemption:A. Name and Address of the Petitioner.

The name and address of the Petitioner and point of contact is: George S Prince

d ba/ Chesapeake Drone Service

111 Burton Air Drive Centreville, MD 21617

410

- 739

- 4370 Gsprince16@yahoo .com

B. The Specific Sections Of 14 C.F.R. From Which Chesapeake Drone Service Seeks Exemption.

1. Chesapeake Drone Service Seeks Exemption F rom The Requirements Of

Section 61.113(a) And (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command

, subsections (a) a nd (b) prescribe the following, in relevant part: (a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PIC of an aircraft. (b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if

— (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or

hire.

2. Chesapeake Drone Service Seeks Exemption F rom The Requirements Of

Section 91.7(a).

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

3. Chesapeake Drone Service Seeks Exemption F rom The Requirements Of

Section 91.121.

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

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

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

available station; or (iii) In the case of an aircraf t not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure.

4. Chesapeake Drone Service Seeks Exemption F rom The Requirements Of

Section 91.151(b).

Section 91.151, entitled Fuel requirements f or flight in VFR conditions

, subsection (b), states the following: (b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended la nding and, assuming normal cruising speed, to fly after that for at least 20 minutes.

5. Chesapeake Drone Service Seeks Exemption From The Requirement Of

Section 91.405(a).

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

— (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 4 3 of this chapter[.]

6. Chesapeake Drone Service Seeks Exemption F rom T he Requirements Of

Section 91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration , subsection (a)(1), states the following: (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

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

7. Chesapeake Drone Service Seeks Exemp tion Fr om The Requirements Of

Sections 91.409(a) (1) And 91.409(a)(2).

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

-- (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by § 43.7 of this chapter; or (2) An inspection for the issuance of an airwor thiness certificate in accordance with part 21 of this chapter.8. Chesapeake Drone Service Seeks Exemption Fr om The Requirements Of

Sections 91.417(a) And 91.417(b).

Section 91.417, entitled Maintenance records , subsections (a) and (b), state the following: (a) E xcept for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preventive maintenance, and alt eration and

records of the 100

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

The records must include

-- (i) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of completion of the work performed; and (iii) The signature, and certificate number of the person approving the

aircraft for return to service. (2) Records containing the following information: (i) The total time in service of the airframe, each engine, each propeller,

and each rotor. (ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection prog ram under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors,

pr opellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retained

and transferred with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and theaircraft is approved for return to service.

C. The Extent Of Relief Chesapeake Drone Service Seeks And The Reason

Chesa peake Drone Service Seeks The Relief.

1. Extent Of Relief Chesapeake Drone Service Seeks And The Reason Chesapeake Drone Service Seeks Relief From Section 61.113(a) And (b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and

limitations: Pilot in command , is requested to the extent n ecessary to allow a PIC holding a p rivate pilot or higher level certificate, as well as a c urrent and valid airman

medical certificate, and who has met certain flight

- hour and curren cy requirements, to

conduct the proposed UAS flight operations for compensation or hire.

This relief is requ ested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that

business or e mployment; and (2) The aircraft does not carry passengers or property for compensation or hire.

As set forth more fully below, Chesapeake Drone Service subm its that an equivalent

level of safety will be maintained because no PIC will be allowed to operate the DJI

Phantom 3 Professional UAS unless that PIC has met certain flight

- hour and currency requirements, demonstrating that the PIC is able to safely operate either the

DJI Phantom 3 Professional UAS in a manner consistent with the operations specifications as de scribed in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles

and structures.

Further, Chesapeake Drone Service submits that all flights of the DJI Phantom 3

Professional UAS, cond ucted by the PIC pursuant to the grant of this Petition: (1)

will be incidental to Chesapeake Drone Service ’s business; and ( 2) will not carry

passengers or property for compensation or hire.

2. Extent Of Relief Chesapeake Drone Service Seeks And The Reason Chesapeake Drone Service Seeks Relief From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to the extent required to allow Chesapeake Drone Service to d etermine that the DJI

Phantom 3 Professional and is in airworthy condition prior to eve ry flight by ensuring that the UAS is in compliance with the operating documents (i.e., the Monthly Maintenance Log, and DJI Phantom 3 Professional Instruction Manual). Chesapeake Drone Service seeks the requested relief because the DJI Ph antom 3

Professional do es not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Chesapeake Drone Serv ice wil l ensure that the

DJI Ph antom 3 Professional is in air worthy condition based upon its compliance with theoperating documents (i.e., M onthly Maintenance Log, and DJI Phantom 3 Professional

user Manual ) prior to every flight, and further, determine that the aircraft is in condition

fo r safe flight, as stated in the conditions and limitations below.

3. Extent Of Relief Chesapeake Drone Service Seeks And The Reason Chesapeake Drone Service Seeks Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the DJI Phantom 3 Professional , which utilize a barometric pressure sensor, GPS equipm ent, and a radio communications telemetry data link to downlink

altitude information from the UA to the PIC on the Ipad or Iphone

Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), Chesapeake

Drone Service seeks the requested relief because the DJI Phantom 3 Professional altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitu de, before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply with the applicable conditions and limitations stated below. As more fully set forth herein, an equi valent level of safety will

be maintained since the DJI Phantom 3 Professional is equipped with a barometric pressure sensor and GPS equipment, w hich automatically ensures that a ground level pressure setting will be established prior t o each flight, and p rovides the PIC with

altitude information of the UA on the heads

- up display

.

4. Extent Of Relief Chesapeake Drone Service Seeks And The Reason Chesapeake Drone Service Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to allow flights of the battery powered DJI

Phantom 3 Professional during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 1 3.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at

least 4.5 minutes.

Chesapeake Drone Service seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered DJI Phantom 3 Professional will severely constra in the practicality of any aerial video or still photo flight operations that Chesapeake Drone Service proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the techni cal specifications of the DJI Phantom 3

Professional operating documents, and Chesapeake Drone Service proposed ope rating
limitations, ensure that Chesapeake Drone Service will safely operate the batterypowered DJI Phantom 3 Professional during daylight hours in visual met eorological

conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

5. Extent Of Relief Chesapeake Drone Service Seeks And The Reason Chesapeake Dr one Service Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only a pply to aircraft with an airworthiness certificate, Chesapeake Drone Service requests relief from these Sections because the DJI Phantom 3 Professional does not require airworthiness certificates. As set forth more fully below, the DJI Phantom 3

Professional meets the con ditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, Chesapeake Drone Service will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and pr actices prescribed in the UAS operating documents (i.e., the Chesapeake Drone Service Aerial Operati ons Manual, Monthly

Maintenance Log, and DJI Phantom 3 Professional Instruction Manual).

Furthermore, Chesapeake Drone Service will document and maintain all maintenance

rec ords for the DJI Phantom 3 Professional UAS.

D. The Reasons Why Granting Chesapeake Drone Service Request Would Be In

The Public Interest; That Is, How It Would Benefit The Public As A Whole.

Granting the present Petition will further the public interest by allow ing Chesapeake

Drone Service to safely, efficiently, and economically perform aerial video and photography of farm land, chicken houses with sediment ponds , real estate, and landscape

, over certain areas of the United States.

Additionally, use of the DJI Phantom 3 Professional and will decrease congestion of the NAS, reduce pollution, and prov ide significant benefits to the economy. Notably, the

benefits of Chesapeake Drone Service ’s proposed operation of the DJI

Phantom 3 Professional and will be r ealized without implicating any privacy is sues.

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

The DJI Phantom 3 Professional is battery powered an d serve s as a safe, efficient, and

economical alternative to th e manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amou nt of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJI Phantom 3 Professional UASwould reduce the a mount of manned aircraft in the NAS, reduce noise and air pollution,

as well as increase the safety of life and property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departin g aircraft will be reduced.

The DJI Phantom 3 Professional doe s not r equire an airport to takeoff or land. Likewise,

a reduction of manned aircraft conducti ng aerial video and photography missions would

result in fewer aircraft that must be handle d by air traffic cont rol during the ground, takeoff, departure, arrival , and landing phases of flight operations.

2. The Public Will Benefit From The S afety And Efficiency Of The DJI Phantom 3

Professional.

Conducting aerial acquisitions with the DJI Phantom 3 Professional instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated duri ng traditional aerial video and still photography flight operations.

By using battery pow er and electric motors, the DJI Phantom 3 Professional produce s

no air pollution, and is the most viable environmentally conscious alternative to the

cab in class, six cylinder internal combustion engine aircraft that are typically utilized fo r aerial video and photography, while burning approximately 20

- 30 gallons per hour of

leaded av iation fuel.

The DJI Phantom 3 Professional , while r educing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as t he UAs is propelled by battery powered electric motors, rather than an internal combustion engine.

By using th e DJI Phantom 3 Professional to perform aerial acquisitions, the substantial risk to life and propert y in the air and on the ground, which is usually associated with

traditional manned airc raft flight operations, will be substantially reduced or completely

eliminated.

Asi de from the lack of flight crew members located onboard the aircraft, the DJI Phantom 3 Professional (weighing approximately 2 pounds 11 ounces respectively, at

it’s maximum gross weights with lengths of 16 inche s and 17.3 inches respective ly, and

w ith 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

condu ct similar operati ons (weighing approximately 6,000 pounds with a wing span of

approx imately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations With The DJI

Phantom 3 Pr ofessional and Will Benefit The Economy.

In addition to being safe and efficient, the D JI Phantom 3 Professional is also an

economical alternative to u sing manned aircraft to conduct similar aerial operations. Assuch, operation of the DJI Phantom 3 Professional will allow United States based

companies, like mine , to re main competitive and c ontribute to growth of the U.S.

economy.

Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA” ) regulatory actions phasing out leaded aviation fuels, U.S. ow ned and operated companies must adopt new and altern ative technology in order to re main competitive. Operating the battery powered DJI Phantom 3 Professional and is one

such technology that not only allows companies greater oper ational flexibility compared

to manned aircraft, but provides such flexibility w ithout the high operational cost of a

traditional manned aircraft.

By operating the DJI Phantom 3 Professional , small companies can remain competitive and profitable, and theref ore, provide greater job stability to employees and contractors,

whic h will ul timately contribute to growth of the U.S. economy.

Improved financial perform ance of U.S. companies, through commercial use of the DJI Phantom 3 Professional and DJI Inspire 1 UA Ss, provides a stable workforce that increases consumer spending; improve s loc al, 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.

4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for
decades, Chesapeake Drone Service ’s proposed operation of the DJI Phantom 3 Professional will not implicate any privacy issues. Specifically, the DJI Phantom 3 Professional and will be operated only in compliance with operating

documen ts (i.e., the Monthly Maintenance Log, and DJI

Phantom 3 Professional ins truction Manual) which requires property owner involvement

as well as local law enforcement notif ication, and in accordance with the Federal Aviation Regulat ions, including the mini mum altitude requirements of 14 C.F.R. §

91.119.

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Whi ch Chesapeake Drone Service Seeks Exemption.

1. Reasons Why The DJI Phantom 3 Professional Meet s The Conditions Of The

FAA Moder nization and Reform Act of 2012 (FMRA) Section 333.

In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, Chesapeake Drone Service ’s operation of

the DJI Phantom 3 Professional meet s the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.Section 333 provides authority for a UAS to operate without airworthiness

certification and sets forth requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security. Specifically , FMRA Section 333 states the following, in part:

(a) In General.

-- Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unman ned aircraft systems may operate safely in the national airspace system before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act.

(b) Assessment of Unmanned Aircraft Systems.

-- In m aking 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, a nd 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 certificat

ion 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 a ircraft 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, Chesa peake Drone Service submits that the DJI Phantom 3 Professional can operate saf ely in the NAS pursuant to FMR A Section 333, as demonstrated by: (a) the chara cteristics of the DJI Phantom 3 Professional (b) the pilot

certifi cation requirement; and (c) the specific operating limitations.

a. The Specifications Of The DJI Phantom 3 Professional Demonstrate Its Safe

Characteristics.

The DJI Phantom 3 Professional does 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.i. Technical Specifications Of The DJI Phantom 3 Professional UAS

.

The technical specifications of the DJI Phantom 3 Professional are set forth by the DJI

Phantom 3 Professional Specifications and Data Sheet, attached

. ii. The DJI Phantom 3 Professional Does Not Allow Autonomous Flight The DJI Phantom 3 Professional may currently only be operated in manual flight mode from the factory w hich improves the area of safe operation

. A complet e description of

the fli ght and navigational modes of the DJI Phantom 3 Professional is provided at pages 25

- 35 of the DJI Phantom 3 Profession al User Manual

, attached

.

iii. The DJI Phantom 3 Professional is Are Designed For Automatic Retur n To

Home Po int Or Hover In The Event Of Loss Of The Control Link Or Navigation.

When the Control Link is lost, the DJI Phantom 3 Professional will remain stationary, in flight, for 3 seconds or more. If, after 3 secon ds, the DJI Phantom 3 Professional does
not reacq uire control link data from the GCS, the UAs will assume that the Control Link

is lost and the UAs 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 Failsaf e Functions of the DJI Phantom 3 Professional UAS are set forth at pages 27 through 29 of the DJI Phantom 3 Professional User
Manuals, attached hereto as Exhibit C

.

iv. The DJI Phantom 3 Professional and Its Operation.

A complete description of the operation and specifications of the DJI Phantom 3 Professional flight control s oftware is provided at pages 32 through 43 of the DJI

Phantom 3 Professional User Manual. A DJI Phantom 3 Professional User Man ual is

att ached

.

b. Flight Operations Of DJI Phantom 3 Professional Is Limited To The Line Of

S ight Of A Certificated Pilot in Command With A Safety Observer.

Chesapeake Drone Service will only utilize certificated pilots who possess a c urrent and

valid airman medical certificate to act as a pilot in command (PIC) of the DJI Phantom 3

Professional . Additionally, a safety observer will assist all pilots during flight time.

c. Flights Of DJI Phantom 3 Professional Will Be Conducted Purs uant To Specific Operating Limitations.

In seeking this exemption, Chesapeake Drone Service proposes to commercially operate DJIPhantom 3 Professional for th e special purpose of conducting aerial video and

photography over certain areas of United States, pursuant to the following specific operating limitations:

1. Operations authorized by this grant of e xemption will be limited to the following aircraft described in the opera ting documents, rotorcraft UASs weighing less than 55 pounds maxi mum gross weight: DJI Ph antom 3 Professional Unma nned 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 aeri al 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 500 feet above ground level (AGL), as indicated by the proced ures specified in the operating docume nts unless a special request is made and approved by ATC. All altitudes reported 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 unaide d 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 always 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 mu st 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 must not perform any other duties beyon d 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

UA S 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 con tained in the grant of exemption take precedence and must be followed. Otherwise, the operator must follow the procedures asoutlined 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

determi nes 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) may be contacted if questions arise regardin g updates or revisions to the operating

documents.

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 operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. All maintenance and alterations must be properl y documented in the 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 con ducts the functional test flight must make an entry in the aircraft 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 op erating documents.

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

14. The operator must carry out its maintenance, inspections, and record keeping require ments, 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 si gnature 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 take n against discrepancies discovered between inspections.

17. The 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

opera tor’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 hours 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 ope rations may only be conducted during dedicated trai ning sessions. During training, proficiency, and experience

- building flights, all p ersons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriat e 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 den oted 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 airpor t management must be made available to the Administrator upon 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 los es 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 obs tacles or emergencies in accordance with the operating documents.

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 poin t and land the UA with 25% battery power remaining.

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificateof Waiver or Authorization (COA) prior to conducting any operations under

the grant of exemption. This COA will also requi re 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 o perations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requirements.

26. 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 i n accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable.

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

28. 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 upon request.

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

30. The UAS may not be operated by the PIC from any moving d evice or vehicle.

31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than the PIC, SO, operator trai nees or essential persons),
vessels, vehicles, and structures unless:

a. Barriers or structures are pr esent that sufficiently protect nonparticipating persons

from the UA a nd/or debris in the event of an accident. The operator must ensure that nonparticipa ting persons remain under such protection. If a situation arises where nonparticipating persons leav e 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, veh icles or structures has granted permission and the

PIC has made a s afety assessment of the risk of operating closer to those objects and

dete rmined that it does not present an undue hazard, and; c. Operations nearer to the PIC, SO, operato r trainees or essential persons do not present an undue haz ard to those persons per § 91.119(a).32. All operations shall be conducted over privat e or controlled

- access property with

permission from the land owner/controller or authorized representative.

Permission from land owner/controller or au thorized represen tative will be obtained 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 must be reported to the FAA's UAS Integra tion 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

.

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And ( b) Would Not Adversely Affect Safety.

Chesapeake Drone Service submits that the equivalent level o f safety established by

Section 61.113(a) and (b) will be maintained because no PIC wil l be allowed to operate

the DJI Phantom 3 Professional unless that PIC has demon strated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 Professional or DJI Inspire 1 UAS in a manner consistent

with the exemption, including evasive and emergency maneuv ers and maintaini ng appropriate distances from people, vessels, vehicles and structures.

Considering Chesapeake Drone Service ’s proposed area o f operations, and the operating limitations set forth

- above; the parallel nature of priva te pilot aeronautical knowledge requirements to t hose of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI Phantom 3

Professional UAS, Chesapeake Drone Service submits that the addition al manned airmanship experience of a commercially certificate d pilot would not correlate to the airmanship skills necessary for Chesapeake Drone Service ’s specific proposed flight operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respe cts, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 110 67, 11080, 11109, 11110,
11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

Chesapeake Drone Service will not allow any PIC to operate the DJI Phantom 3

Pr ofessional unless that PIC has demonstrated, by meeting minimum flight

- hour requirements or the DJI Phantom 3 Professional UAS training and currency requirements, that the PIC is able to s afely operate the DJI Phantom 3 Professional

UAS in a manner consist ent with this exemption, including evasive and emergency maneuvers and maintaining app ropriate distances from people, vessels, vehicles and

structures.

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b ), 25 hours of total time as a UAS rotorcraft pilot (with aminimum of 5 hours of those hours as a UAS pilot opera ting the same make and model

of UAS to be used for operations under the exemption). In addition to the hour requirements, the PIC must accompl ish 3 takeoffs and la ndings in the preceding 90 days (for currency purposes).

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of sa fety during Chesapeake Drone Service ’s proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows: In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot incl uding at least 10 hours logged as a UAS pilot with a multi

- rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for o perations under the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi

- rotor time and the 10 hours may be

included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight

- hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the petitioner’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulati ons would satisfy this requirement. Training, proficiency, and experience

- building flights can also be conducted under the grant of exemption to accomplish the required flight time. During training, proficiency, and experience

- building flights the PIC is r equired to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15.

Accordingly, Chesapeake Drone Service will ensure safe ope rations by n ot allowing any

PIC to operate the DJI Phantom 3 Professional unle ss that PIC has demonstrated, by meeting minimum flight

- hour and curr ency requirements, that the PIC is able to safely operate the DJI Phantom 3 Professional UAS in a manner consistent with the exemption, including evas ive and emergency maneuvers and maintaining ap propriate distances from people, vessels, vehicles and structures.

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.7(a) will be maintained

bec ause prior to every flight, Chesapeake Drone Serv ice wil l ensure that the DJI

Phantom 3 Professional UAS is in an airworthy condition based upon the UAS’ scompliance with its operating documents and as stated in the condition s and limitations

herein.

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109,
11110, 11112, 11136, 1113 8, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained

because the altitude information of the DJI Phantom 3 Professional will be provided to the PIC via GPS equip ment and a radio communications telemetry data link, which

downlinks from the UA to the GCS for act ive monitoring of the flight path and altitude.

This altitude information, combined with Chesapeake Drone Service ’ s operation of the

DJI Phantom 3 Professional within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information will be generated by GPS e quipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically established by the UASs at ground level.

The FAA has previously granted relief from Section 91.121 specific to UAS, in
circumstances similar, i n all material respects, to those p resented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 110 80, 11109, 11112,
11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJI Phantom 3 Professional (2) t he limitations on the proposed flight operations; and (3) the location of the proposed fl ight operations.

Accordingly, Chesapeake Drone Service will ensure that he will safely operate th e battery powered DJI Phantom 3 Professional during dayligh t hours in VFR condi tions,

with enough battery power to fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5

minutes.

Here, as in Exemption No. 11109, the technical specificatio ns of the DJI Phantom3 Professional ; the limitations on the proposed flight operations; and the location of the

proposed operations, will ensur e an equivalent level of safety established by 14 C.F.R. Section 91.151(b).

Furthermore, safety will be ensured as the DJI Phantom 3 Professional prov ides visual warnings to the PIC when the UAs experiences low bat tery voltage, the first warning occurring at approximately 33% remaining battery po wer, and again at approximately 10% remaining battery power. At the critically low batter y level, DJI Phantom 3

Professional will descend and land automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical charac teristics and operating limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FA A has previously g ranted

relief from Section 91.151 specific to UAS, in circumstances simila r, in all material
respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042,
11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 111 36, 11138,

11 150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

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

In seeking this exemption, Chesapeake Drone Service submi ts that the equivalent level

of safety with regard to the regulatory maintenance and alte ration requirements

established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)( 2), and 91.417(a) & (b) will be met because Chesapeake Drone Service will u se trained tech nicians to perform maintenance, alterations, or preventive maintenance on the UASs usi ng the methods, techniques, and best practices prescribed in the operating documents (i.e.,

the , Monthly Maintenance Log, and DJI Phantom 3 Professional In struction Manual).

Furthermore, Chesapeake Drone Service will document and maintain all maintenance

records for the DJI Phantom 3 Professional

.

Since the DJI Phantom 3 Professional and will be inspected as prescribed by the operating documents, Chesapeake Drone Service will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy

of the DJI Phantom 3 Professional User Manual is attached

.

Likewise, the exemption sought will not adversely affect safety because Chesapeake

Drone Service will use trained technicians to perform mainten ance, alterations or preventive maintenance on the UAS using the methods, techniques, a nd practices prescribed by the operating documents.

Furthermore, the exemption sought would maintain an equivalent level of safetyestablished by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of

the DJI Phantom 3 Professional and will b e performed by trained technicians.

Maintenance will be documented and m aintained utilizing the monthly maintenance log. Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the technical characteristics and operating limitations of

the UAS are considered.

In consideration of Chesapeake Drone Service ’s proposed opera ting limitations, the operating documents, and the technical aspects of the DJI Phantom 3 Profes sional, Chesapeake Drone Service submits that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b).

The FAA has previously gra nted relief specific to UAS in circumstances similar, in all material respects, to those p resented herein (e.g. Exemption Nos. 11062, 11063,
11064, 11065, 11066, 11067, 110 80, 11109, 11110, 11112, 11136, 11138, 11150,
11153, 11156, 11157, 11158, 11159, 111 60, 11161).

7. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Chesapeake Drone

Service requests that the FAA pr escribe special conditions for the intended operation of

the DJI Phantom 3 Professional UAS , which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subp art H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAs for the limited purpose of conducting aerial video and p hotography over certain areas of the United States for compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose

a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification in accordance with any requirements that must be established for the safe operation of the UAS in the NAS.

Likewise, the Administrator may prescribe special co nditions pursuant to 14

C.F.R. § 21.16, for operation of the DJI Phantom 3 Professional UAS, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features of th e aircraft.

Section 21.16, entitled Special Conditions, states the following: If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, orpropeller beca use of a novel or unusual design feature of the aircraft, aircraft

engine or propeller, he prescribes special conditions and amendments thereto for the product.

The special conditions are issued in accordance with Part 11 of this chapter and contain such s afety standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent to

that established in the regulations. See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for the intended operation of the DJI Phantom 3 Professional UAS, which con tain such safety standards that the Administrator finds necessary to establish a lev el of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

A Summary That Can Be Published in the Federal Register, stating: The

Rules From Which Chesapeake Dr one Service Seeks Exemption: Chesapeake Drone Service seeks exemption from the requirements of 14 C.F.R

Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

A Brief Description Of The Nature Of The Exemption Chesapeake Drone Service

Seeks: This exemption will permit Chesapeake Drone Service to c ommercially operate an

Unmanned Aircraft System (UAS) for the purpose of conducting aerial v ideo and photography over certain areas of the United States.

Any Additional Information, Views, Or Arguments Available To Support Chesapeake Drone Service ’s Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. As such, Chesapeake Drone Service ’s request for exemption may be granted pursuant to the authority of FMRA Section 333

and 14 C.F.R. Part 11, as set forth above. FMRA Section 333 sets forth the requirement s for consider ing whether a UAS will create a hazard to users of the NAS or the public , or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification.

As discussed in detail above, a lice nsed pilot will operate the DJI Phantom 3 Professional safely in the NA S, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.CONCLUSION

As set forth herein, Chesapeake Drone Service seeks an exemption pur suant 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 3 Professional UAS commercially, without an airworthiness certific ate, for the limited purpose of conduct ing aerial video and photography over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfi lling the Congressional mandate of the FAA
Modernization and Reform Act of 2012, while also advancing the interests of t he public, by allowing a licensed pilot to safely, efficientl y, and economically operate the DJI Phantom 3 Professional commercially within the NAS.

WHEREFORE , in accordance with the Federal Aviation Regulations and the

FAA Modernization and Reform Act of 2012, Section 333, Chesapeake Drone Service respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.1 51(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Chesapeake Drone Service to operate the DJI Phantom 3 Professional and commercially for the purpose of conducting aerial video and photography over certain

areas of the United States.

Dated: August 1 , 2015 Respectfully submitted, George S Prince

d ba/ Chesapeake Drone Service

111 Burton A ir D rive Centreville, MD 21617

410

- 739

- 4370

g sprince1 6@yahoo.com

Appendices:

A

– DJI Phantom 3 Professional Specifications Data Sheet

APPENDIX

– A

DJI Phantom 3 Professional TECHNICAL SPECIFICATIONS

Chesapeake Drone Service only utilizes safe and reliable UASs. DJI is an industry

leader in small UAS production. DJI UASs are loaded with ground brea king software enabling the user to set parameters which will not allow flight into controlle d airspace.

Parameters can also be set to limit flight to no higher than a predetermin ed an d set

altitude as well as limit flight to a predetermined and set distance. In addition, DJI software provides real

- time altitude and location information to the PIC via the linked monitor (smart p hone/tablet devices)1.1 DJI Phantom 3 Professional

1 .1.1 Aircraft 1.1.1.1 Supported Battery

– DJI 5200mAH LiPo Battery 1.1.1.2 Weight (Battery & Propellers Included)

– 2lbs 11.810oz (1242g) 1.1.1.3 Hover Accuracy (Ready to Fly)

– Vertical: .8m; Horizontal: 2.5m 1.1.1.4 Max Yaw Angular Velocity

- 200 0 /s 1.1.1.5 Max Tilt Angel

- 35 0
1.1.1.6 Max Ascent Speed

– 6m/s 1.1.1.7 Max Descent Speed

– 2m/s 1.1.1.8 Max Flight Speed

– 15m/s (NOT RECOMMENDED)

1.1.2 Gimbal 1.1.2.1 Working Current

– Static: 750mA; Dynamic: 900mA 1.1.2.2 Control Accuracy

- ±0.03 0

1.1. 2.3 Controllable Range

– Pitch:

- 90 0

- 0 0
1.1.2.4 Maximum Angular Speed

– Pitch: 90 0 /s

1.1.3 Camera 1.1.3.1 Operating Temperature Range

- 32 0 F

- 104 0 F (0 0 C

- 40 0 C)

1.1.3.2 Sensor Size

– 1/2.3”

1.1.3.3 Effective Pixels

– 14M

1.1.3.4 Resolution

– 4384x3288

4 .1.3.5 HD Video Recording

– 1080p30 & 720p 4.1.3.6 Recording Field of View

- 110 0 /85 0

1.1.4 Transmitter 1.1.4.1 Operating Frequency

– 5.728GHz

– 5.85GHz 1.1.4.2 Communication Distance (unobstructed)

– FCC Compliance: 800m 1.1.4.3 Receiver Sensitivity (1%PE R)

- - 93dBm

1.1.4.4 Transmitter Power

– FCC Compliance: 100mW 1.1.4.5 Working Voltage

– 120mA@3.7V 1.1.5 Range Extender 1.1.5.1 Operating Frequency

– 2412

- 2462MHz 1.1.5.2 Communication Distance (unobstructed)

– 500

- 700m

1.1.5.3 Transmitter Power

– 20dBm

1. 1.5.4 Power Consumption

– 2W

Reserved N Number

- N294 2