November 3 , 2015 U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Wa shington, D.C. 20590

Re: Petition of Droneye LLC for Exemption from Certain Federal Aviation Regulations to Operate Unmanned Aircraft Systems Pursuant to Section 333 of the FAA Modernization and Reform Act. Dear Sir or Madam: D RONEYE LLC hereafter referred to as D RONEYE 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 (DJI Inspire 1) pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit D RONEYE to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography of construction sites, residential and commercial real estate, civil landscapes and events over certain areas of the United States. Because this petition is similar in all material respe cts to previously

- granted Section 333 petitions, D RONEYE requests expedited approval pursuant to the FAA's summary grant process.


### I. **Proposed Operations & Public Interest Benefits**
D RONEYE is a Start

- up Business located in Sussex County, NJ. Our pilots have over 100 hours of Unmanned Aircraft System (UAS) experience without incident . The objective of D RONEYE and our UAS (DJI Inspire 1) aerial operations is to provide a more affordable, High

- quality production system for a variety of commercial and Residential uses, specifically targeting
• Construction sites progress • Aerial Surveying • Real

- estate marketing • Structural Inspection• Civic landmarks • Special event coverage • Agriculture



### II. **Background** DRONEYE seeks an exemption to operate DJI Inspire 1 system for compensation or hire within the NAS. The DJI Inspire 1 already has authorized use by the FAA. The DJI Inspire 1 is vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) util izing electronic tablet or sma rt phone systems. The DJI Inspire 1 has a maximum gross weight of approximately 6.5 lbs w ith a maximum speed of approximately 16.4 fps and a maximum flying height of 400 feet. The DJI Inspire 1 is equipped with four main rotors; driven by Lithium Polymer b attery powered electric motors. The DJI Inspire 1 operated by DRONEYE 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

. 

### III. **Basis for petition** Petitioner, DRONEYE, 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 Inspire 1, 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 speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, DRONEYE operation of the DJI Inspire 1UASmeets 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, DRONEYE 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.

DRONEYE submits that the requested relief is proper since an equivalent level of safety will be ensured. DRONEYE will only use e xperienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 Instruction M anual). Furthermore, DRONEYE will document and maintain all maintenance records for the DJI Inspire 1

. Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested by DRON EYE 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 Inspire 1 UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, airports, vehicles and structures.

DRONEYE seeks relief from Se ction 91.7(a), entitled Civil aircraft airworthiness , because the DJI Inspire 1 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, DRONEYE will ensure that the DJI Inspire 1 UAS is in an airworthy condition, prior to every flight, by determining that the UAS are in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual), and that the aircraft are in a condition for safe fl ight.DRONEYE also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , as the DJI Inspire 1 UAS does not have a typical barometric altimeter onboard. However, altitude information of the DJI Inspire 1 UAS will be broad casted 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 DRONEYE operation of the DJI Inspire 1 UAS within visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121.
Additionally, DRONEYE seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for fligh t in VFR conditions . DRONEYE submits that safety will not be affected by operation of the 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 durati on of approximately 23 minutes. Battery power indicators are also able to show exactly how much battery power is left, as well as how much time is needed to return safely back to point of take

- off.
In accordance with 14 C.F.R. § 11.81, DRONEYE provides t he following information in support of its petition for exemption: **A. The name and address of the Petitioner** 

**.** Norman Harris III President DRONE LLC 42 Bunn Rd Hamburg, NJ 07419 908

- 509

-4885 Droneye1@gmail.com

**B. The Specific Sections Of 14 C.F.R. From Which DRONEYE**  **Seeks Exemption.**
**1. DRONEYE**  **Seeks Exemption F rom The Requirements Of Section**  **61.113(a) A nd**  **(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 pro perty 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. DRONEYE**  **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 ai rcraft unless it is in an airworthy condition.

**3. DRONEYE**  **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 equi pped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure.
**4. DRONEYE 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 thefirst point of intended landing and, assumin g normal cruising speed, to fly after that for at least 20 minutes.

**5. DRONEYE**  **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 parag raph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.]

**6**

**. DRONEYE**  **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. DRONEYE**  **Seeks Exemption Fr om The Requirements Of Sections**  **91.409(a)(1) An**  **d 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 ha d

-- (1) An annual inspection in accordance with part 43 of this chapter and has bee n approved for return to service by a person authorized by § 43.7 of this chapter; or (2) An inspection for the issuance of an airworth iness certificate in accordance with part 21 of this chapter.
**8. DRONEYE Seeks Exemption from the Requirements of Sections 91.417(a) A nd**  **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 item s 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 own er 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 DRONEYE Seeks A nd The Reason DRONEYE Seeks The**  **Relief. 1. Extent Of Relief DRONEYE Seeks A** **nd The Reason DRONEYE Seeks Relief From Section 61.1**  **13(a) A nd (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 val id 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, DRONEYE submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the DJI Inspire 1 UAS unless that PIC has met certain flight

- hour and currency requi rements, demonstrating that the PIC is able to safely operate either the 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 appropria te distances from people, vessels, vehicles and structures.
Further, DRONEYE submits that all flights of the DJI Inspire 1 UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to DRONEYE’s business; and (2) will not carry passengers or property for compensation or hire.

**2. Extent Of Relief DRONEYE**  **Seeks A nd The Reason**  **DRONEYE 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 The DRONEYE to determine th at the DJI Inspire 1 UAS are in airworthy condition prior to every flight by ensuring that th e UAS is in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 Instruction Manu al).

DRONEYE seeks the requested relief because the DJI Inspire 1 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, DRONEYE will ensure that the DJI Inspire 1 UAS are in airworthy condition based u pon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 ) 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 DRONEYE**  **Seeks A nd The Reason**  **DRONEYE Seeks Relief**  **From Section 91.121.**Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the DJI Inspire 1 UAS, which utilize a barometric pressure sen sor, 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 ai r traffic control (ATC) in feet above ground level (AGL), DRONEYE seeks t he requested relief because the 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, reli ef 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 w ill be maintained since the DJI Inspire 1 UAS are equipped with a barometric pressure sensor and GPS equipm ent, which automatically ensures that a ground level pressure setting will be es tablished 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 DRONEYE**  **Seeks A nd The Reason**  **DRONEYE 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 Inspire 1 UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 23 minutes. The DRONEYE seeks the requested relief becau se without an exemption from Section 91.151(b), the flight time duration of the battery powered DJI Inspire 1 UAS will severely constrain the practicality of any aerial video or still photo flight operations that DRONEYE proposes to conduct pursuant to this Petition.
Significantly, as set forth below, the technical specifications of the DJI Inspire 1 UAS, the DJI Inspire 1 operating documents, and DRONEYE’s proposed operating limitations, ensure that DRONEYE will safely operate the battery powered DJI Inspire 1 UAS duringdaylight hours in visual meteoro logical conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total duration of 23 minutes.

**5. Extent Of Relief DRONEYE**  **Seeks A nd The Reason**  **DRONEYE Seeks Relief**  **From Sections 91.405( a), 91.407(a)(1), 91.409(a)(1) & (a)(2),**  **An d 91.417(a) & (b).**  Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), an d 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, DRONEYE requests relief from these Sections because t he DJI Inspire 1 UAS do not require air worthiness certificates. As set forth more fully below, the DJI Inspire 1 UAS meet the con ditions of FMRA Section 333 for operation without an airworthiness certificate. Accordin gly, DRONEYE will use trained technicia ns to perform maintenance, alterations, o r preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, DRONEYE will document and maintain all maintenance records for the DJI Inspire 1 UAS.

**D. The Reasons Why**

**Granting DRONEYE Request Would Be In The Public Interest;**  Granting the present Petition will further the public interest by allowing DRONEYE to safel y, efficiently, and economically perform aerial video and photography of construction sites, real estate, events and civic landscape over certain areas of the United States. Additionally, use of the DJI Inspire 1 UAS will decrease congestion of the NAS, re duce pollution, and provide significant benefits to the economy. Notably, the benefits of DRONEYE proposed operation of the DJI Inspire 1 UAS will be realized without implicating any privacy issues.
**1. The Public Will Benefit From Decreased Congestion Of The NA** **S.** The 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 aerialacquisi tions, an exemption allowing the use of a 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 t he number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The DJI Inspire 1 UAS does not require 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 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 A nd Eff** **iciency Of The DJI Inspire 1**  **UA S.**  Conducting aerial acquisitions with the DJI Inspire 1 UAS, 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 Inspire 1 UAS produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine a ircraft that are typically utilized for aerial video and photography, while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The DJI Inspire 1 UAS, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollu tion, as the UAS are propelled by battery powered electric motors, rather than an internal combustion engine.
By using the DJI Inspire 1 UAS to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is u sually 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 Inspire 1 UAS (weighing approximately 6.5 pounds at their maximum gross weight with diagonal dimension of 17 .2 inches, and with no fuel on board), has less physical potential for collateral damage to life and property on the ground, and in the air,compared to the manned aircraft that typically conduct s imilar 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 A erial Video and Photography**  **Operations with**  **the DJI**  **Inspire 1 UA** **S Will Benefit The**  **Economy**

**.** In addition to being safe and efficient, the DJI Inspire 1 UAS are also an economical alternative to using manned aircraft to conduct similar aerial op erations. As such, operation of the DJI Inspire 1 UAS will allow United States based companies, like DRONEYE , 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 op era ted companies must adopt new and alternative technology in order to remain competitive. Op erating the battery powered DJI Inspire 1 UAS is one such technology that not only allows companies greater operational fl exibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft. By operating the DJI Inspire 1 UAS, companies such as DRONEYE, 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 Inspire 1 UAS, provides a stable workforce that increases consumer spending; improves local,
s tate, 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 A re No Privacy**  **Issues.** Similar to the manned aerial acquisition flight operations that have been conducted for decades, DRONEYE’s proposed operation of the DJI Inspire 1 UAS will not implicate any privacy issues. Specifically, the DJI Inspire 1 UAS will be operated only in compliance with operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual) which requires property owner involvement as well as local lawenforcement notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.

**E. T he Reasons Why** 

**Granting The Exemption Would Not A dv** **ersely A**  **ffect Safety, Or How The Exemption Would Provide A**  **Lev el Of Safety** 

**A t Least Equal To That**  **Provided By**

**The Rule From Which DRONEYE Seeks Exemption.**

**1. Reasons Why**

**The DJI Inspire 1 UA S Meet The Con**  **ditions Of The FAA Modernization and Reform A** **ct of 2012 (FMRA ) Section 333.**  In consideration of the size, weight, speed, and limited ope rating area associated with the unmanned aircraft and its operation , DRONEYE ’s operation of the DJI Inspire 1 UAS meet the conditions of FMRA Section 333, and wi ll 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 airwo rthiness certification and sets forth requirem ents for considering whether a UAS will create a ha zard to users of the NAS or the public, or otherwise pose a threat to national security. Specifical ly, 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 sy stems 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, orairworthiness 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 requiremen ts for the safe operation of such aircraft systems in the national airspace system.

In seeking this exemption, DRONEYE submits that the DJI Inspire 1 UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the (b) characteristi cs of the DJI Inspire 1 UAS; (b) the pilot certification requirement; and (c) the specific operating limitations. **a. The Specifications Of The DJI Inspire 1 UA S Demonstrate Its Safe**  **Characteristics.** The DJI Inspire 1 UAS 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 Inspire 1**  **UA S.**  The tec hnical specifications of the DJI Inspire 1 UAS are set forth by the DJI Inspire 1 User Manual ( attached )

.

**ii. The DJI Inspire 1**  **UAS Global Positioning Modes Enable The UA** **S To Remain**  **Within A**

**Defined Operational A rea.**  The DJI Inspire 1 UAS may be operated i n both manual and global positioning flight modes. A complete description of the flight and navigational modes of the DJI Inspire 1 UAS is provided in the DJI Inspire 1 User Manual ( attached )

.

**iii. The DJI Inspire 1**  **UA S A** **re Designed For A utomatic Return To**  **Home Point**  **Or Hover In The Event Of Loss Of The Control Link Or Navigation.** Wh en the Control Link is lost, the DJI Inspire 1 UAS will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Inspire 1 UAS does not reacquire contro l link data from the GCS, the UAS will assume that the Control Link is lost and the willreturn 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 Inspire 1 UAS are set forth in the DJI Inspire 1 Manual (attached)

. **iv. The DJI Inspire 1**  **GCS A nd Its Operation.**  A complete description of the operation and specifications of t he DJI Inspire 1 GCS and flight control software is provided in the DJI Inspire 1 User Manual.
**b. Flight Operations Of DJI Inspire 1**  **UA S Is Limited To The Line Of Sight Of A**  **Certificated Pilot in Command With A Safety Observer.**  DRONEYE staff will be the on ly persons to act as a pilot in command (PIC) of the DJI Inspire 1 UAS. Additionally , a safety observer will assist with every flight

. **c. Flights Of DJI Inspire 1**  **UA S Will Be Conducted Pursuant To Specific Operating**  **Limitations.** In se eking this exemption, DRONEYE propo ses to commercially operate DJI Inspire 1 UAS for the special purpose of conducting aerial video and photography over certain areas of United States, pursuant to the following specific operating limitations. 1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UAS weighing less than 55 pounds maximum gross weight: DJI Inspire 1 Unmanned Aircraft Systems. Proposed operations of any oth er aircraft will require a new petition or a petition to amend this grant. 2. UAS operations under this exemption will be l imited to conducting operations for the purpose of aerial video and photography. 3. The UAS may not be flown at an indicated airspeed exceeding 20 knots. 4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved by ATC. All al titudes 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

- is sued 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. Th e 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 ob stacles/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 d iscrepancy exists between the conditions and limita tions contained in the grant of exemption and the procedures outlined in the operatin g documents, the conditions and limitations contained in the grant of exemption take p recedence and must be followed. Ot herwise, 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 ope rator must also present updated and revised documents if it petitions for extensi on 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 ofexemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if questions arise regarding update s or revisions to the operating documents. 10. Prior to each flig ht the PIC must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition tha t affects the safe operation of the UAS, the aircraft is prohibited from operating unti l the necessary maintenance has been performed and the UAS is found to be in a condit ion 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 main tenance 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 ai rcraft/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, inspectio n, 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 U AS 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 p ossess 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 theoperator’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, airports, 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 close st 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 lette r 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 req uest. 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 andforecast 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 opera tor must obtain an Air Traffic Organization (ATO) issued Certificate of Wa iver or Authorization (COA) prior to conducting an y operations under the grant of exemption. This COA will also require the operato r to request a Notice to Airman (NOTAM) not more th an 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accord ance with airspace requirements in the ATO issued COA including class of airspac e, 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 (Number) markings in accordance with 14 C.F.R. pa rt 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 Fe deral Communications Commission (FCC) or other appropriate government oversight agency requirements. 28. Th e 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 5 00 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 operatormust 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 operatio ns 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 in cident, 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 We b site: www.ntsb.gov.

**2. Reasons Why**

**A n Exemption From The Requirements Of Section 61.113(a) A** **nd (b) Would Not A** **dversely A**  **ffect Safety**

**.** DRONEYE 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 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 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 DRONEYE’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 Inspire 1 UAS, DRONEYE submits that theadditional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for DRONEYE’s specific proposed flight operations.

The FAA has previously g ranted 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). DRONEYE will not allow any PIC to operate the DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight

- hour requirements or the DJI Inspire 1 UAS training and currency requirements, that the PIC is able to safely operate the 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 accumu lated and logged, in a man ner 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 exemp tion). 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 DRONEYE’s proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe ope rations, 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 UASpilot 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 ho urs 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 tha t 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 experience

- building 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, DRONEYE will ensure safe operations by not allowing any PIC to o perate the 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 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**

**A n Exemption From The Requirements Of Section 91.7(a) Would**  **Not Ad**  **versely**

**A ffect Safety** 

**.** The equivalent level of safety established by Section 9 1.7(a) will be maintained because prior to every flight, DRONEYE will ensure that the 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.Additi onally, 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, 1113 6, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

**4. Reasons Why**

**A n Exemption From The Requirements Of Section 91.121 Would**  **Not Ad**  **versely**

**A ffect Safety** 

**.** The equivalent level of safety established by Section 91.121 will be maintained becau se the altitude information of the 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 i nformation, combined with DRONEYE’s operation of the 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 establis hed by the UAS at ground level. The FAA has previously granted relief from Section 91.121 sp ecific to UAS, in circumstances similar, in all material respe cts, to those presented herein (e. g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 111 38, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

**5. Reasons Why**

**A n Exemption From The Requirements**  **Of Section 91.151(b )**  **Would Not Ad**  **versely A ffect 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 Inspire 1 UAS; (2) the limitations on the propos ed flight operations; and (3) the location of the proposed flight operations. Accordingly, DRONEYE will ensure that it will safely operate the battery powered DJI Inspire 1 UAS during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 23 minutes. Here, as in Exemption No. 11109, the technical specifications of the DJI Inspire 1 UAS; the limitations on the proposed flight operations; and the location of the proposedoperations, 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 Inspire 1 UAS provide audible and visual warnings to the PIC at the GCS when the UAS experiences low battery voltage, the first warning oc curring at approximately 3 3% remaining battery power, and again at approximately 10% remaining battery power. At the critically low battery level, the DJI Inspire 1 UAS 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, inclu ding 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, 11 062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

**6. Reasons Why**

**A n Exemption From The Requirements Of Sections**  **91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), A nd 91.417(a)**  **& (b) Would Not Ad**  **versely**

**A ffect Safety** 

**.** In seeking this exemption, DRONEYE 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 DRONEYE will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e Monthly Ma intenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, DRONEYE will document and maintain all maintenance records for the DJI Inspire 1 UAS. Since the DJI Inspire 1 UAS will be inspected as prescribed by the operating documents, DRONEYE will ma intain 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 Inspire 1 User Manuals are attached;Likewise, the exemption sought will not adversely affect safety because DRONEYE 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 Inspire 1 UAS will be performed by trained technicians. Maintenance will be documented and maintained 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. I n consideration of DRONEYE’s proposed operating limitations, the operating documents, and the technical aspects of the DJI Inspire 1 UAS, DRONEYE 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, 1 1080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

**7. The FAA**

**Ma y**  **Prescribe A ny** 

**Other Conditions For Safe Operation.** In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 1 4 C.F.R. § 21.16 entitled Special Conditions, DRONEYE requests that the FAA prescribe special conditions for the intended operation of the DJI Inspire 1 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, 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. FMRASection 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 Inspire 1 UAS, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standard s, 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 there to for the product. The special conditions are issued in accord ance with Part 11 of this chapter and contain such safety standards for the aircraft, aircraft engine or propelle r 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 Inspire 1 UAS, which contain such safety standards that the Administrator finds ne cessary to establish a l evel 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 C**  **an Be Published In t he F**  **ederal Register, stating: The Rules From Which DRONEYE Seeks Exemption:**  DRONEYE 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 DRONEYE Seeks:**  This exemption will permit DRONEYE to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and Photography over certain areas of the United States.

**An y**  **Ad ditional Information, Views, Or A** **rguments A vailable To Support**  **DRONEYE’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 certa in UAS may operate safely in the NAS. As such, DRONEYE’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. As discussed in detail above, DRONEYE will operate t he DJI Inspire 1 UAS safely in the NAS, 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, DRONEYE seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI Inspire 1 UAS commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing DRONEYE to safely, efficiently, and economically operate the DJI Inspire 1 UAS commercially within the NAS. **WHEREFORE** , in accordance with the Federal Aviation Regulations and the FAAModernization and Reform Act of 2012, Section 333, DRONEYE respectfully requests that the Administrator g rant this Petition for an 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), and permit Leading Edge to operate the DJI Inspire 1 UAS commercially for the purpose of conducting aerial video and photography over certain areas of the United States.
Respectfully submitted,

Norman Harris III President DRONEYE LLC 42 Bunn Rd Hamburg, NJ 07419 908

- 509

-4885 Droneye1@gmail.com

Appendices: Link to DJI Inspire 1 Manual: Click on link below https://www.dji.com/product/inspire

- 1/download https://dl.djicdn.com/downloads/inspire_1/en/Inspire%20_1_User_Manual__V1.8.pdf