UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

DEWMAS HOLDINGS, INC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

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) CONCERNING COMMERCIAL

OPERATION OF DJI PHANTOM 3 AND DJI INSPIRE 1

UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Submitted on June 16, 2015

Dewmas Holdings, Inc

86 Idora Avenue

San Francisco, CA 94117
GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing
SUMMARY

Dewmas Holdings, Inc seeks 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),

to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and

Reform Act of 2012 (FMRA). This exemption will permit Dewmas Holdings, Inc to operate an

Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and

photography of construction sites, real estate, landscape as well as perform over video certain

areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Dewmas Holdings, Inc provides its customers with expertise and knowledge in advanced

technologies and solutions to improve efficiency, productivity and effectiveness. The objective

of Dewmas Holdings, Inc aerial video and photography operations is to provide high quality

imaging for a variety of commercial, public, and residential uses, specifically targeting:

 Construction sites before and after

 Appraisals

 Real-Estate Marketing

 Motion Picture Filming

 Aerial acquisitions used for inspections of public and private structures

 Search and Rescue operations

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 3, DJI Inspire 1 UASs

Dewmas Holdings, Inc seeks an exemption to operate DJI systems for compensation or hire

within the NAS. The DJI Phantom 3 and DJI Inspire 1 are vertical takeoff and landing (VTOL)

Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or

smart phone systems.

The DJI Phantom 3 has a maximum gross weight of 1280 grams, a diagonal length of 590 mm,

and a maximum speed of approximately 16 m/s.The DJI Inspire 1 has a maximum gross weight

of 2935 grams, a diagonal length of 581 mm, and a maximum speed of approximately 22 m/s.

The DJI Phantom 3 and DJI Inspire 1 UAs are equipped with four main rotors; driven by

Lithium Polymer battery powered electric motors.

The DJI Phantom 3 and DJI Inspire 1 UAs that will be operated by Dewmas Holdings, Inc 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, Dewmas Holdings, Inc, pursuant to the provisions of the Federal Aviation
Regulations (14 C.F.R. § 11.61) and the FAA Modernization 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 and DJI Inspire 1 UASs

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 speed, weight, size, and limited operating area associated with the

unmanned aircraft and its operation, Dewmas Holdings, Inc’s operation of DJI Phantom 3 and

DJI Inspire 1 UASs meets the conditions of FMRA Section 333 and therefore, will not require an

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, Dewmas Holdings, Inc requests relief from 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 aircraft with an airworthiness certificate.

Dewmas Holdings, Inc submits that the requested relief is proper since an equivalent level of

safety will be ensured. Dewmas Holdings, Inc will use experienced personnel or technicians to

perform maintenance, alterations, or preventive maintenance on the UASs using the methods,

techniques, and practices prescribed in the operating documents (i.e. DJI Phantom 3 and DJI

Inspire 1 Instruction Manual). Furthermore, Dewmas Holdings, Inc will document and maintain

all maintenance records for the DJI Phantom 3 and DJI Inspire 1 UASs.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges

and limitations: Pilot in command, is requested by Dewmas Holdings, Inc 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 minimum flight- hour and

currency requirements, that the PIC is able to safely operate the DJI Phantom 3 and DJI Inspire 1

UASs in a manner consistent with this exemption, including evasive and emergency maneuvers

and maintaining appropriate distances from people, vessels, vehicles and structures.

Dewmas Holdings, Inc seeks relief from Section 91.7(a), entitled Civil aircraft

airworthiness, because the DJI Phantom 3 and DJI Inspire 1 UASs do not require an

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Dewmas

Holdings, Inc submits that it will ensure that the DJI Phantom 3 and DJI Inspire 1 UASs are in an

airworthy condition, prior to every flight, by determining that the UASs are in compliance with

the operating documents (i.e. DJI Phantom 3 and DJI Inspire 1 Instruction Manual), and that the

aircraft are in a condition for safe flight.

Dewmas Holdings, Inc also seeks an exemption from the requirements of Section 91.121,

entitled Altimeter Settings, as the DJI Phantom 3 and DJI Inspire 1 UAs will not have a typical

barometric altimeter onboard. However, altitude information of the DJI Phantom 3 and DJI

Inspire 1 will be provided to the PIC via Global Positioning System (GPS) equipment and radio

communications telemetry data link, which downlinks from the UA to the GCS for active

monitoring of the flight path. This altitude information, combined with Dewmas Holdings, Inc’s
operation of the DJI Phantom 3 and DJI Inspire 1 within visual line of sight, at or below 500 feet

AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, Dewmas Holdings, Inc seeks an exemption from the requirements of Section

91.151(b), entitled Fuel requirements for flight in VFR conditions. Dewmas Holdings, Inc

submits that safety will not be affected by operation of the DJI Phantom 3 and DJI Inspire 1

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, Dewmas Holdings, Inc 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:

Dewmas Holdings, Inc

Attention: Nori Yoshida

86 Idora Avenue

San Francisco, CA 94117

650-918-6674

Email:nori@dewmas.com

B. The Specific Sections Of 14 C.F.R. From Which Dewmas Holdings, Inc Seeks

Exemption.

1. Dewmas Holdings, Inc Seeks Exemption From The Requirements Of Section

61.113(a) And (b).

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

subsections (a) and (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. Dewmas Holdings, Inc Seeks Exemption From 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. Dewmas Holdings, Inc Seeks Exemption From The Requirements Of Section

91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in

part:

(a) Each person operating an aircraft 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 route and

within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of

this section, the current reported altimeter setting of an appropriate

available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of the

departure airport or an appropriate altimeter setting available before

departure.

4. Dewmas Holdings, Inc Seeks Exemption From The Requirements Of Section

91.151(b).

Section 91.151, entitled Fuel requirements for 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 landing and, assuming normal cruising speed, to fly

after that for at least 20 minutes.

5. Dewmas Holdings, Inc Seeks Exemption From The Requirement Of Section

91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following:

Each owner 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 43 of this chapter[.]

6. Dewmas Holdings, Inc Seeks Exemption From The 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. Dewmas Holdings, Inc Seeks Exemption From 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 airworthiness certificate in accordance

with part 21 of this chapter.

8. Dewmas Holdings, Inc Seeks Exemption From 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) Except 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 alteration 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 program 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,

propellers, 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 the aircraft is

approved for return to service.

C. The Extent Of Relief Dewmas Holdings, Inc Seeks And The Reason Dewmas Holdings,

Inc Seeks The Relief.

1. Extent Of Relief Dewmas Holdings, Inc Seeks And The Reason Dewmas Holdings, Inc

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 necessary to allow a PIC holding a private

pilot or higher level certificate, as well as a current and valid airman medical certificate,

and who has met certain flight-hour and currency requirements, to conduct the proposed UAS

flight operations for compensation or hire.

This relief is requested 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

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

As set forth more fully below, Dewmas Holdings, Inc submits that an equivalent level of

safety will be maintained because no PIC will be allowed to operate the DJI Phantom 3 or DJI

Inspire 1 UAS unless that PIC has met certain flight-hour and

currency requirements, demonstrating that the PIC is able to safely operate any of the DJI

Phantom 3 or DJI Inspire 1 UAS in a manner consistent with the operations specifications as

described in this exemption, including evasive and emergency maneuvers, as well as maintaining

appropriate distances from people, vessels, vehicles and structures.

Further, Dewmas Holdings, Inc submits that all flights of the DJI Phantom 3 and DJI Inspire 1

UASs, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to

Dewmas Holdings, Inc’s business; and (2) will not carry passengers or property for

compensation or hire.

2. Extent Of Relief Dewmas Holdings, Inc Seeks And The Reason Dewmas Holdings, Inc

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 Dewmas Holdings, Inc to determine that the DJI Phantom 3 and DJI Inspire 1

UASs are in airworthy condition prior to every flight by ensuring that the UAS is in compliance

with the operating documents (i.e., the Dewmas Holdings, Inc Aerial Operations Manual and DJI

Phantom 3 and DJI Inspire 1 Instruction Manuals).
Dewmas Holdings, Inc seeks the requested relief because the DJI Phantom 3 and DJI Inspire 1

UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart

H. Therefore, Dewmas Holdings, Inc will ensure that the DJI Phantom 3 and DJI Inspire 1 UASs

are in airworthy condition based upon its compliance with the operating documents (i.e. DJI

Phantom 3 and DJI Inspire 1 Instruction Manual) prior to every flight, and further, determine that

the aircraft are in condition for safe flight, as stated in the conditions and limitations below.

3. Extent Of Relief Dewmas Holdings, Inc Seeks And The Reason Dewmas Holdings, Inc

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 and DJI Inspire 1 UASs, which utilize a barometric pressure

sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude

information from the UA to the PIC at the ground control station (GCS). Since the FAA requires

that any altitude information concerning UAS operations be reported to air traffic control (ATC)

in feet above ground level (AGL), Dewmas Holdings, Inc seeks the requested relief because the

DJI Phantom 3 and DJI Inspire 1 UA’s altimeter may be set on the ground to zero feet AGL,

rather than the local barometric pressure or field altitude, 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 equivalent level of safety will be maintained since the DJI

Phantom 3 and DJI Inspire 1 UAs are equipped with a barometric pressure sensor and GPS

equipment, which automatically ensures that a ground level pressure setting will be established

prior to each flight, and provides the PIC with altitude information of the UA on the heads-up

display of the GCS.

4. Extent Of Relief Dewmas Holdings, Inc Seeks And The Reason Dewmas Holdings, Inc

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 and DJI

Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC), under visual

flight rules (VFR), 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. Dewmas Holdings, Inc

seeks the requested relief because without an exemption from Section 91.151(b), the flight time

duration of the battery powered DJI Phantom 3 and DJI Inspire 1 UAs will severely constrain the

practicality of any aerial video or still photo flight operations that Dewmas Holdings, Inc

proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the DJI Phantom 3 and DJI

Inspire 1 UASs, the DJI Phantom 3 and DJI Inspire 1 operating documents, and Dewmas

Holdings, Inc’s proposed operating limitations, ensure that Dewmas Holdings, Inc will safely

operate the battery powered DJI Phantom 3 and DJI Inspire 1 UAs during daylight hours in

visual meteorological 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 Dewmas Holdings, Inc Seeks And The Reason Dewmas Holdings, Inc

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 apply to

aircraft with an airworthiness certificate, Dewmas Holdings, Inc requests relief from these

Sections because the DJI Phantom 3 and DJI Inspire 1 UASs do not require airworthiness

certificates. As set forth more fully below, the DJI Phantom 3 and DJI Inspire 1 UASs meet the

conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly,

Dewmas Holdings, Inc will use trained technicians to perform maintenance, alterations, or

preventive maintenance on the UASs using the methods, techniques, and practices prescribed in

the UAS operating documents (i.e., the Dewmas Holdings, Inc Aerial Operations Manual and

DJI Phantom 3 and DJI Inspire 1 Instruction Manual). Furthermore, Dewmas Holdings, Inc will

document and maintain all maintenance records for the DJI Phantom 3 and DJI Inspire 1 UASs.

D. The Reasons Why Granting Dewmas Holdings, Inc 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 allowing Dewmas Holdings, Inc

to safely, efficiently, and economically perform aerial video and photography of construction

sites, real estate, and landscape over certain areas of the United States. Additionally, use of the

DJI Phantom 3 and DJI Inspire 1 UASs will decrease congestion of the NAS, reduce pollution,

and provide significant benefits to the economy. Notably, the benefits of Dewmas Holdings,

Inc’s proposed operation of the DJI Phantom 3 and DJI Inspire 1 UASs will be realized without

implicating any privacy issues.

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

The DJI Phantom 3 and DJI Inspire 1 UAs are battery powered and serve as a safe, efficient, and

economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By

reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption

allowing the use of a DJI Phantom 3 or DJI Inspire 1 UAS would reduce the amount 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 departing aircraft will be reduced. The DJI Phantom 3 and

DJI Inspire 1 UAs do not require an airport to takeoff or land. Likewise, a reduction of manned

aircraft conducting aerial video and photography missions would result in fewer aircraft that

must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing

phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The DJI

Phantom 3, DJI Inspire 1 UASs.

Conducting aerial acquisitions with the DJI Phantom 3 and DJI Inspire 1 UASs, instead of

manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise

pollution generated during traditional aerial video and still photography flight operations. By

using battery power and electric motors, the DJI Phantom 3 and DJI Inspire 1 UASs produce no
air pollution, and is the most viable environmentally conscious alternative to the cabin class, six

cylinder internal combustion engine aircraft that are typically utilized for aerial video and

photography, while burning approximately 20-30 gallons per hour of leaded aviation fuel. The

DJI Phantom 3 and DJI Inspire 1 UAs, while reducing the carbon footprint of aerial acquisitions,

also eliminates noise pollution, as the UAs are propelled by battery powered electric motors,

rather than an internal combustion engine.

By using the DJI Phantom 3 and DJI Inspire 1 UASs to perform aerial acquisitions, the

substantial risk to life and property in the air and on the ground, which is usually associated with

traditional manned aircraft flight operations, will be substantially reduced or completely

eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI

Phantom 3 and DJI Inspire 1 UAs (weighing approximately 2 pounds 13 ounces and 6 pounds

7.5 ounces respectively, at their maximum gross weights with approximate lengths of 13 inches

and 17.3 inches respectively, approximate widths of 18 inches and 17.7 inches respectively, and

with no fuel on board), has less physical potential for collateral damage to life and property on

the ground, and in the air, compared to the manned aircraft that typically conduct similar

operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a

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

3. Performing Aerial Video and Photography Operations With The DJI

Phantom 3 and DJI Inspire 1 UASs Will Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 3 and DJI Inspire 1 UASs are also an

economical alternative to using manned aircraft to conduct similar aerial operations. As such,

operation of the DJI Phantom 3 and DJI Inspire 1 UASs will allow United States based

companies, like Dewmas Holdings, Inc, to remain competitive and contribute 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. owned and

operated companies must adopt new and alternative technology in order to remain competitive.

Operating the battery powered DJI Phantom 3 and DJI Inspire 1 UASs is one such technology

that not only allows companies greater operational flexibility compared to manned aircraft, but

provides such flexibility without the high operational cost of a traditional manned aircraft.

By operating the DJI Phantom 3 and DJI Inspire 1 UASs, companies such as Dewmas Holdings,

Inc, can remain competitive and profitable, and therefore, provide greater job stability to

employees and contractors, which will ultimately contribute to growth of the U.S. economy.

Improved financial performance of U.S. companies, through commercial use of the DJI Phantom

3 and DJI Inspire 1 UASs, 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.

4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for decades,

Dewmas Holdings, Inc’s proposed operation of the DJI Phantom 3 and

DJI Inspire 1 UASs will not implicate any privacy issues. Specifically, the DJI Phantom 3 and

DJI Inspire 1 UASs will be operated only in compliance with operating documents (i.e., the

Dewmas Holdings, Inc Aerial Operations Manual and DJI Phantom 3 and DJI Inspire 1
Instruction Manual) which requires property owner involvement as well as local law

enforcement notification, and in accordance with the Federal Aviation Regulations, including the

minimum 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 Which Dewmas Holdings, Inc Seeks Exemption.

1. Reasons Why the DJI Phantom 3 and DJI Inspire 1 UAs Meet The Conditions Of The

FAA Modernization 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, Dewmas Holdings, Inc’s operation of the DJI Phantom 3

and DJI Inspire 1 UASs meet 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 unmanned 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 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, Dewmas Holdings, Inc submits that the DJI Phantom 3 and DJI

Inspire 1 UASs can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated

by: (a) the characteristics of the DJI Phantom 3 and DJI Inspire 1 UASs; (b) the pilot

certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The DJI Phantom 3 and DJI Inspire 1

UASs Demonstrate Its Safe Characteristics.

The DJI Phantom 3 and DJI Inspire 1 UASs do 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 and DJI Inspire 1 UASs.

The technical specifications of the DJI Phantom 3 and DJI Inspire 1 UASs are set forth by the

DJI Phantom 3 and DJI Inspire 1 Specifications and Data Sheet, attached hereto as Exhibit A and

B, respectively.

ii. The DJI Phantom 3 and DJI Inspire 1 UASs Autonomous

Flight And Navigation Modes Enable The UASs To Remain Within

A Defined Operational Area.

The DJI Phantom 3 and DJI Inspire 1 UASs may be operated in both manual and fully

autonomous flight modes. A complete description of the flight and navigational modes of the DJI

Phantom 3 and DJI Inspire 1 UASs is provided in the DJI Phantom 3 and DJI Inspire 1 User

Manuals, attached hereto as Exhibit C and D, respectively.

iii. The DJI Phantom 3 and DJI Inspire 1 UASs Are Designed

For Automatic Return To Home Point Or Hover In The Event Of

Loss Of The Control Link Or Navigation.

When the Control Link is lost, the DJI Phantom 3 and DJI Inspire 1 UAs will remain stationary,

in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 3 and DJI Inspire 1 UAs do

not reacquire 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 Failsafe Functions of the DJI Phantom 3 and DJI Inspire 1 UASs

is provided in the DJI Phantom 3 and DJI Inspire 1 User Manuals, attached hereto as Exhibit C

and D, respectively.

iv. The DJI Phantom 3 and DJI Inspire 1 GCS And Its Operation.

A complete description of the operation and specifications of the DJI Phantom 3 and DJI Inspire

1 GCS and flight control software is provided in the DJI Phantom 3 and DJI Inspire 1 User

Manuals, attached hereto as Exhibit C and D, respectively.

b. Flight Operations of DJI Phantom 3 and DJI Inspire 1 UASs Are Limited To The Line

Of Sight Of A Certificated Pilot in Command With A Safety Observer.
Dewmas Holdings, Inc will only utilize certificated pilots who possess a current and valid airman

medical certificate to act as a pilot in command (PIC) of the DJI Phantom 3 and DJI Inspire 1

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

c. Flights Of DJI Phantom 3 and DJI Inspire 1 UASs Will Be Conducted Pursuant To

Specific Operating Limitations.

In seeking this exemption, Dewmas Holdings, Inc proposes to commercially operate DJI

Phantom 3 and DJI Inspire 1 UASs for the special purpose of conducting aerial video and

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

limitations:

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

described in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum

gross weight: DJI Phantom 3 and DJI Inspire1 Unmanned Aircraft Systems. Proposed operations

of any other aircraft will require a new petition or a petition to amend this grant.

2. UAS operations under this exemption will be limited to conducting operations for the purpose

of aerial video and photography.

3. The UAs may not be flown at an indicated airspeed exceeding 20 knots.

4. The UA must be operated at an altitude of no more than 500 feet above ground level (AGL),

as indicated by the procedures specified in the operating documents unless a special request is

made and approved by ATC. All altitudes 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 unaided by any device other than corrective

lenses, as specified on the PIC’s FAA-issued airman medical certificate.

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted.

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS

requirement as long as the PIC 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 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 must not perform any other duties beyond assisting the PIC with seeing

and avoiding other air traffic and other ground based obstacles/obstructions and

is not permitted to operate the camera or other instruments.

9. The operating documents and the grant of exemption must be accessible during

UAS operations and made available to the Administrator upon request. If a discrepancy exists

between the conditions and limitations contained in the grant of exemption and the procedures
outlined in the operating documents, the conditions and limitations contained in the grant of

exemption take precedence and must be followed. 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 amendment to its grant

of exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if questions arise

regarding updates or revisions to the operating documents.

10. Prior to 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. The Ground Control Station must be included in the

preflight inspection. All maintenance and alterations must be properly documented in the aircraft

records.

11. Any UAS that has 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 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 operating

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 requirements,

in accordance with the operating documents. Maintenance, inspection, alterations, and status of

replacement/overhaul component parts must be noted in the aircraft records, including total time

in service, description of work accomplished, and the signature of the authorized person

returning the UAS to service.

15. Each UASs operated under this exemption must comply with all manufacturer Safety

Bulletins.

16. The authorized person must make an entry in the aircraft record of the corrective action taken

against discrepancies discovered between inspections.

17. 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 operator’s

qualification criteria and demonstrates the ability to safely operate the UAS in a manner

consistent with how the UAS will be operated under the exemption, including evasive and

emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and

structures. PIC qualification flight 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 operations may only be conducted during dedicated training

sessions. During training, proficiency, and experience-building flights, all persons not essential

for flight operations are considered nonparticipants, and the PIC must operate the UA with

appropriate distance from nonparticipants in accordance with 14 C.F.R. §91.119.

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. §

1.1. All operations must be conducted under visual meteorological conditions

(VMC). If flight at night is required, a special request will be made at the FAA office closest to

proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized.

20. The UA may not operate within 5 nautical miles of an airport reference point as denoted on a

current FAA-published aeronautical chart unless a letter of agreement with that airport’s

management is obtained, and the operation is conducted in accordance with a NOTAM as

required by the operator’s COA. The letter of agreement with the airport management must be

made available to the Administrator 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 loses communications or loses its GPS signal, it must return to a predetermined

location within the planned operating area and land or be recovered in accordance with the

operating documents.

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

accordance with the operating 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 point

and land the UA with 25% battery power remaining.

25. The operator 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.

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

in 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) or 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 device or vehicle.

31. Flight operations must be conducted at least 500 feet from all nonparticipating persons

(persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and

structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the

UA and/or debris in the event of an accident. The operator must ensure that nonparticipating

persons remain under such protection. If a situation arises where nonparticipating persons leave

such protection and are within 500 feet of the UA, flight 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, SO, operator trainees or essential persons do not present an

undue hazard to those persons per § 91.119(a).

32. All operations shall be conducted over private or controlled-access property with permission

from the land owner/controller or authorized representative. Permission from land

owner/controller or authorized representative will be obtained for each flight to be conducted.

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

Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site:

www.ntsb.gov.

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a)

And (b) Would Not Adversely Affect Safety.

Dewmas Holdings, Inc submits that the equivalent level of safety established by Section
61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI

Phantom 3 and DJI Inspire 1 UASs unless that PIC has demonstrated, by meeting minimum

flight-hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 3

or DJI Inspire 1 UAS in a manner consistent with the exemption, including evasive and

emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and

structures.

Considering Dewmas Holdings, Inc’s proposed area of operations, and the operating limitations

set forth-above; the parallel nature of private pilot aeronautical knowledge requirements to those

of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills

necessary to safely operate the DJI Phantom 3 or DJI Inspire 1 UAS, Dewmas Holdings, Inc

submits that the additional manned airmanship experience of a commercially certificated pilot

would not correlate to the airmanship skills necessary for Dewmas Holdings, Inc’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 respects, to those presented herein (e.g. Exemption Nos.

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150,

11153, 11156, 11158, 11159, 11160, 11161).

Dewmas Holdings, Inc will not allow any PIC to operate the DJI Phantom 3, DJI

and Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight-hour

requirements or the DJI Phantom 3 or DJI Inspire 1 UAS training and currency requirements,

that the PIC is able to safely operate the DJI Phantom 3 or DJI Inspire 1 UAS in a manner

consistent with this exemption, including evasive and emergency maneuvers and maintaining

appropriate 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 a minimum of 5 hours of those

hours as a UAS pilot operating the same make and model of UAS to be used for operations under

the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and

landings 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 safety

during Dewmas Holdings, Inc’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

including 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 operations 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 regulations 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 experiencebuilding flights the PIC is required to operate the UA with appropriate distances in accordance

with 14 C.F.R 91.119.

Exemption No. 11138 at page 15.

Accordingly, Dewmas Holdings, Inc will ensure safe operations by not allowing any PIC to

operate the DJI Phantom 3 or DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting

minimum flight-hour and currency requirements, that the PIC is able to safely operate the DJI

Phantom 3 or DJI Inspire 1 UAS in a manner consistent with the exemption, including evasive

and emergency maneuvers and maintaining appropriate 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 because prior to

every flight, Dewmas Holdings, Inc will ensure that the DJI Phantom 3

and DJI Inspire 1 UAS is in an airworthy condition based upon the UAS’s compliance with its

operating documents and as stated in the conditions 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, 11138, 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 and DJI Inspire 1 UAs will be provided to the PIC via

GPS equipment and a radio communications telemetry data link, which downlinks from the UA

to the GCS for active monitoring of the flight path and altitude. This altitude information,

combined with Dewmas Holdings, Inc’s operation of the DJI Phantom 3 and DJI Inspire 1 UAs

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 equipment 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, in all material respects, to those presented herein (e.g. Exemption Nos.

11062, 11063, 11064, 11065, 11066, 11067, 11080, 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 and

DJI Inspire 1 UASs; (2) the limitations on the proposed flight operations; and (3) the location of

the proposed flight operations. Accordingly, Dewmas Holdings, Inc will ensure that it will safely

operate the battery powered DJI Phantom 3 and DJI Inspire 1 UAs during daylight hours in VFR

conditions, 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 specifications of the DJI Phantom 3 and DJI

Inspire 1 UASs; the limitations on the proposed flight operations; and the location of the

proposed operations, will ensure 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 and DJI Inspire 1 UASs

provide audible and visual warnings to the PIC at the GCS when the UAs experiences low

battery voltage, the first warning occurring at approximately 33% remaining battery power, and

again at approximately 10% remaining battery power. At the critically low battery level, the DJI

Phantom 3 and DJI Inspire 1 UASs 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 characteristics 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 FAA has previously granted relief from

Section 91.151 specific to UAS, in circumstances similar, 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, 11136, 11138, 11150, 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, Dewmas Holdings, Inc submits that the equivalent level of safety with

regard to the regulatory maintenance and alteration 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 Dewmas

Holdings, Inc will use trained technicians to perform maintenance, alterations, or preventive

maintenance on the UASs using the methods, techniques, and practices prescribed in the

operating documents (i.e., the Dewmas Holdings, Inc Aerial Operations Manual, and DJI

Phantom 3 and DJI Inspire 1 Instruction Manual). Furthermore, Dewmas Holdings, Inc will

document and maintain all maintenance records for the DJI Phantom 3 and DJI Inspire 1 UASs.
Since the DJI Phantom 3 and DJI Inspire 1 UASs will be inspected as prescribed by the

operating documents, Dewmas Holdings, Inc 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

and DJI Inspire 1 User Manuals are attached hereto as Exhibit C and D.

Likewise, the exemption sought will not adversely affect safety because Dewmas Holdings, Inc

will use trained technicians to perform maintenance, alterations or preventive maintenance on the

UAS using the methods, techniques, and practices prescribed by the operating documents.

Furthermore, the exemption sought would maintain an equivalent level of safety

established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI

Phantom 3 and DJI Inspire 1 UASs will be performed by trained technicians. Maintenance will

be documented and maintained utilizing a 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 Dewmas Holdings, Inc’s proposed operating limitations, the operating

documents, and the technical aspects of the DJI Phantom 3 and DJI Inspire 1 UASs, Dewmas

Holdings, Inc 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 granted relief 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, 11138, 11150, 11153, 11156, 11157, 11158, 11159,

11160, 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, Dewmas Holdings, Inc requests that

the FAA prescribe special conditions for the intended operation of the DJI Phantom 3 and DJI

Inspire 1 UASs, 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, Subpart 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 photography 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 conditions pursuant to 14 C.F.R.

§ 21.16, for operation of the DJI Phantom 3 and DJI Inspire 1 UASs, 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 the 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, or propeller because 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

safety 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 Leading Edge’s intended operation of the DJI Phantom 3 and DJI

Inspire 1 UASs, 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, 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).

F. A Summary That Can Be Published In The Federal Register, stating: The Rules

From Which Dewmas Holdings, Inc Seeks Exemption:

Dewmas Holdings, Inc 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 Dewmas Holdings, Inc

Seeks:

This exemption will permit Dewmas Holdings, Inc to commercially operate an

Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and

photography over certain areas of the United States.

G. Any Additional Information, Views, Or Arguments Available To Support Dewmas

Holdings, Inc’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, Dewmas Holdings, Inc’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 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.

APPENDIX – A

DJI PHANTOM 3 TECHNICAL SPECIFICATIONS

http://www.dji.com/product/phantom-3/spec

APPENDIX – B

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

http://www.dji.com/product/inspire-1/spec

APPENDIX – C

DJI Phantom 3 Manufacturer’s User Manual

http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.2_en.pdf

APPENDIX – D

DJI Inspire 1 Manufacturer’s User Manual

http://download.djiinnovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.2_en.pdf