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### Pure Art Productions LLC July 23, 2015 U.S. Departm ent of Transportation Docket Managem ent System 1200 New

Jersey Ave., SE Wa shington, DC 20590
Re: **Exemption Petition under Section 333 of the FAA Modernization & Reform Act, and Title 14 Part 11 of the Code of Federal Regulations (CFR)**  14 CFR 61.113, 14 CFR 91.7, 91.119, 91.121, 91.151 14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417) Dear Sir or Madam, Pursuant to Section 333 of the FAA Modernization & Reform Act and 14 C.F.R. Part 11, Pure Art Productions LLC ( Pure Art Productions ) hereby applies for the grant of exem ption fro m certain Federal Aviation Regulations for Inspire 1 ( Inspire) Unm anned Aircraf t manufactured by DJI Co.,Ltd. of China. The requested exem ption would support an application for a commercial Certificate of Author ization (COA) to use the Inspire to support real estate photography, videogra phy, and aerial surveying for other comm ercial industries. The Inspire Unm anned Aircraft System (U AS) consists of a lightweight (6.5 lb) battery op erated quadcopter unman ned aircraft, onboard cam eras, and associated communications equipm ent. The Inspire Unm anned Aircraft (UA) has previously demonstrated to have successfully m et the safety and operat ional requirem ents resulting in previous grants of section 333 exem ption requests by other commercial UAS operators. The Inspire UA carries an onboard cam era system th at allows it to perform aerial photography, videography, and surveying. By approving th e exemption, the Pure Art Productions’ UAS operation s w ill create benefits to both the econom y and the environm ent which are ultim ately in the public interest. The aircraft w ill be operated with both a Pilot in Command and a Visual Observer in accordance with the following additional restrictions:Page 2

- All operations will occur at no m ore than 400' AGL

- The aircraft will be operated with the perm issio n of the property owner

- Wh en necessary, applicable perm its w ill be acquired from local authorities

- The aircraft will not be operated over urban or populated areas

- The aircraft will not be operated at air shows or over an open
- air assembly of peopl e

- The aircraft will not be operated over heavily trafficked roads

- Operations will be lim ited to day, visual m eteorological conditions

- Aircraft w ill rem ain within Visual Line of Sight at no greater than 1/2 NM of the PIC at all tim e

- Wh ile the aircraft is airborne, the VO will be positioned within voice distance to the PIC

- Wh en necessary and applicable, Pure Art Productions will file a NOTAM providing radial/DME, radius, and a date/tim e group for each operation For certain com p lex operations, Pure Art Productions m ay assign one or two sensor/software operators to assist the operations. We subm it that the combinatio n of ;

- Inspire UAV’s light weight and historically demonstrated safe operat ion and receiving approvals of mult iple section 333 petitions

- Fully qualified flight crew

- Restricted operations under the guidelines established within the grant, the FAA can have confidence that Pure Art Productions ’ UAS the operations will have an equivalent or greater level of safety of manned aircraft performing the sam e m ission. Weare prepared to m odif y or am end any part of this request to satisfy the need for an equivalent level of safety. Additional docum en ts supporting this petition will be subm itted follow ing this request. Welook forward to working with your office. Please contact us at any tim e if you require additional inform ation or clarification. Respectfully,

Thom as Chang Pure Art Producti ons LLC 5156 W oodfield Dr ive Centreville, Virginia 20120 Tel: 571
- 330
- 1786 Em ail: thomassungchang@gm ail.comPage 3



## TA **BLE OF CONTENTS**

NAME, ADDRESS CONTACT INFORMATION OF PETITIONER .......................Page 4 THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH PURE ART PRODUCTIONS SEEKS EXEMPTION.......................................................................Page 4 THE EXTENT OF RELIEF PURE ART PRODUCTIONS SEEKS AND THE REASONS PURE ART PRODUCTIONS SEEKS THE RELIEF .

............................. . Pages 4 to 6 THE REASONS WHY GRANTING PURE ART PRODUCTIONS’S REQUEST WOULD BE IN THE PUBLIC INTEREST ................

.................................. ................Page 7 THE REASONS WHY GRANTING PURE ART PRODUCTIONS THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY.........

....................... Page 8 SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER.......

...... Page 9 ANY ADDITIONAL INF ORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT PURE ART PRODUCTIONS ’S REQUEST.................................

......... Page 10 ACRONYMS............ ...........................................................................Pages 11 & 12Page 4

**NAME, ADDRESS AND CONTACT INFORMATION OF PETITIONER** Thom as Chang Pure Art Productions LLC 5156 W oodfield Drive Centreville, Virginia 20120 Tel: 571
- 330
- 1786 Em ail: thomassungchang@gm ail.com
**THE SPECIFIC SECTIONS OF 14 CFR TO BE RELIEVED FROM**  14 CFR 61.113, 14 CFR 91.7, 91.119, 91.121, 91.151 14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417)
**THE EXT**  **ENT OF RELIEF PURE A**  **RT PRODUCTIONS SEEKS AND THE REASONS**  **PURE A RT PRODUCTIONS**  **S EEKS THE RELIEF**  **14 CFR 61.113 Private pilot privileges and limitations:**  Part 61.113 provides that no person that holds a private pilot certificate m ay act as pilot in command of an aircraft for com pensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command of an aircraft in connection with any business or em ploym ent if; (1) F light is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire
. Since the aircraft cannot carry passengers or property, we request to be relieved from this regulation if our pilots at m inimum, (1) hold at least a current private pilot certificate and, (2) hold a current third class m edical certificate. By m eeting con ditions (1) and (2), we believe that equ ivalent level of safety can be achieved by com plying with 61.113 Subparagraph (b) even though the intent of this application is to conduct a business. **14 CFR 91.7 Civil A**  **ircraft A irworthiness.**  14CFR 91.7 (a) states,
“No person may operate a civil aircraft unless it is in an airworthy condition .” This rule prohibits the operation of an aircraft w ithout an airworthiness certificate. Since there is no suc h existing certificate that is applica ble for the Inspire U AS to properly com ply with the FARs, we request that Pure Art Productions to be relieved from this regulation. To provide equivalent level of safety, we will ensure that the Inspire UAS is inPage 5

airworthy condition prior to every flight by follow ing safety procedures described in our operating docum ents. **14 CFR 91.119 Minimum safe altitudes: General** Thi s regulation provides that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the aircraft w ill be operating at a m axim um of 400 feet AGL, we cannot com ply with this requirem ent. To provide an equivalent level of safety we will only fly over private property with th e p erm ission of the land owner. The land owner will be briefed of the expected route of flight and the associated risks to persons and property on the ground. W e maintain that due to the sm all size of the Inspire , the hazard to persons, vessels, vehicles, and structures is not com parable to m anned aircraft and should be considered in granting the exem ption.
**14 CFR 91.121 A ltimeter Settings**  This regulation provides that aircraft shall m aintain cruising altitudes by reference to an altim eter setting available within 100 nautical m iles of the aircraft. The Inspire aircraft w ill fly below 400 feet AGL and will not need to m aintain hem ispherica l cruising altitudes in order to de
- conflict w ith other aircraft. To provide an equivalent level of safety, the PIC w i ll check and confirm the Inspire’s GPS al titude read out before each flight.
**14 CFR 91.151 Fuel requirements for flight in VF R conditions.**  The regulation provides that no person m ay begin a flight in an airplane under day
-VFR conditions unless there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 minutes. Webeli eve the intention of this rule is to provide a reserve of energy as a safety buffer for go
- arounds and other delays to landing. The Inspire UAS is battery operated and the maxim um duratio n of flight with full payload fro m asingle battery charge is approxim ately 18 mi nutes. Webelieve that equivalent level of safety can be achieved b y lim iting our flight tim e to 14 minu tes with reserve energy 20 % (4 mi nutes) on the battery.Page 6

**14 CFR 91 Subpart E ( 91.405, 91.407, 91.409, 91.417 ) Maintenance, Preventive Maintenance, and A**  **lterations** The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy condition, including com pliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to service by a person authorized under 43.7 " after maintenance and inspection. It is our intention that the PIC, VO or authorized personnel to perform m aintenance and inspection of the aircraft and "be authorized to approve the aircraft for return to service." Pure Art Productions requests that exem ptions to the regulations under conditions below; (1) Pure Art Productions will follow Inspire ’s m anufact urer maintenance instructions, techniques and procedures (2) Pure Art Produ ctions will designate, train, and docum ent the personnel who will be authorized to perform Inspection, Maintenance and Alterations by m eans of above stated maintenance instructions. Such de signated personnel m ay include PIC, VO or other equivalent trained persons (3) To ensure e quivalent level of safety, PIC wi ll inspect the UA before each flight looking for any structural or m echanical m alfunctions Due to the sm all size, light weight and sim plicity of the Inspire UAS, we believe t hat the equivalent safety will be achieved by perm itting any of the PIC, VO or equivalent trained personnel, to perform maintenance, inspection and al terations of the aircraft and " be authorized to approve the aircraft for return to service. "Page 7

**THE REASONS WHY GRA NT**  **ING PURE A**  **RT PRODUCTIONS**  **’S REQUEST WOULD BE IN THE PUBLIC INTEREST**  Webelieve that granting our exem ption request from, 14 CFR Part 21.191 14 CFR Part 45.23, 45.29 14 CFR 61.113, 61.133 14 CFR 91.9, 91.119, 91.121, 91 .151 14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417), is in the public’s interest and will benefit the public as a whole for the following reasons. 1
- Inspire is battery operated and free from the harmful em issions associated with the manned aircraft that are currently used for aerial photography and videography. As recently proven by several grants of section 333 petitions, UASs offer equivalent level of safety while reducing environm ental im pacts, which is in the public interest. 2
- Pure Art Productions’ UAS operations will contribute to a **positive aggregate economic impact**  resulting in **creation of jobs**  both direct and indirectly. Econom ic Research estim ates that the UAS market will grow from $6 billion to $ 94 billion over the next decade res ulting in a new

workforce developm ent. Because Pure Art Productions ’ operations will create **new jobs** such as pilots, flight operation staff, and administrative supporting staff, it w ill directly cause **positive economic impact**  , hence granting Pure Art Production s’ petition will benefit the public as a whole. 3
- **Congress has already proclaimed**  that it is in the public’s interest to integrate Commercially flown UAS(s) into the national airsp ace system , hence the passing of the FAA Modernization and Reform Act of 2012. Granting Pure Art Productions’ petition furthers the public’s interest as a dem onstrated progression of integrating Unm anned Aircraft System s into National Air Space, thus it w ill benefit public as a whole

.Page 8

**THE REASONS WHY GRA NT**  **ING PURE A RT** **PRODUCTIONS THE EXEMPTION WOULD NOT ADVERSELY A**  **FFECT SA FETY**  Pure Art Productions believes that the grant of exem ption from, 14 CFR 61.113, 14 CFR 91.7, 91.119, 91.121, 91.151 14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417), will not adversely affect safety by a com bination of the reasons listed below. (a) W e have stated in the above section **“ THE EXTENT OF RELIEF**  **PURE ART PRODUCTIONS**  **SEEKS AND THE REASONS PURE ART PROD**  **UCTIONS SEEKS THE RELIEF**  **”** by describing how we intend to m itigate risk and accom plish FAA equivalent and acceptable level of safety for each 14 CFR part. (b) As a result of Inspire unm anned aircraft’s size, weight, speed, operational capability, prox im ity to airports and populated areas, operation within visual line of sight com bined with the im plem entation Pure Art Productions ’ of safety procedures, we be lieve that granting Pure Art Productions ’ exem pt ion request w ill not adversely affect safety. (c) DJI Inspire 1 has demonstrated to satisfy necessary safe ty risk m itigation by FAA thus resulting in m ultiple grants of section 333 petitions. Becau se of the combination of Inspire ’s proven success and the conditions and lim itations of our operations , we believe granting Pure Art Productions’ request w ill not adversely affect safety.Page 9

**SUMMARY THAT CAN BE PUBLISHED IN THE FEDERA L REGISTER**  Departm ent of Transportation Federal Aviation Adm inistration Petitioner: Pure Art Productions LLC
Petition of exem ption from sections of; 14 CFR 61.113, 14 CFR 91.7, 91.119, 91.121, 91.151 14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417) Description of relief sought; Pure Art Productions seeks an exem ption for com mercial operation of the Inspire unm anned aircraft manufactured by DJI Co, Ltd. of China. The Inspire unm anned aircraft system has an onboard cam era system capable of acquiring high resolution data. Proposed operations will offer real estate aerial photography, videography and aerial surveying services for other commercial industries.Page 10

**ANY ADDITIONA L INFORMATION, VIEWS, OR A**  **RGUMENTS AVAILA BLE TO**  **SUPPORT PURE ART PRODUCTIONS’S REQUEST** 

# Inspire 1 **Unmanned Ai**  **rcraft System General Features**  Ready to Fly, Multifunctional Quad
- rotor System Custom ized H3
- 2D and H3
- 3D Gim bal Support Precision Flight and Stable Hovering 18 mi n Flight Time & Sm art Battery Auto Return
-to
- Hom e & Landing Advanced Power Managem ent Intelligent Orientation Control (IOC) Easy Battery Replacement Self
-tightening Propeller Video Downlink Support CAN
- Bus Expansion Module Control Link radio operating frequency 2. 4 GHz ISM Operating Distance 0.65 m iles 

### Ai **rcraft Performance** Em pty W eight 5.2 lbs Max Take
- off We ight 6.5 lbs Max Flight Speed 30 Knots Hover Accuracy (Ready to Fly) Vertical: 0.5 m; Horizontal: 2.5m Max Yaw Angular Velocity 150 °/s Max Tilt Angle 35° Max Ascent / Descent Speed Ascent: 5m/s; Descent: 4 m/s Diagonal Length 559 mm Flight Tim e 18 mi nutes 

### No Privacy

**Issues** Pure Art Productions ’ proposed operations will create no privacy issues because the Inspire UAS will be operating in rural areas within the boundaries of the properties with the land owner’s perm ission. Pure Art Productions wi ll also obtain any perm its or author izations from local authorities when necessary.Page 11

**AC RONYMS**  AGL Above Ground Level ALoS Acceptable Level of Safety AMOC Alternative Method of Com pliance ASI Aviation Safety Inspector ATC Air Traffic Control ATCAA Air Traffic Control Assigned Airspace ATS Air Traffic Service AVS Aviation Safety CFR Code of Federal Regulations COA Certificate of Wa iver or Authorization CRM Crew Resource Managem ent CS Control Station CRS Certified Repair Station DCP Divert/Contingency Point DHS Departm ent of Hom eland Security DME Distance Measuring Equipm ent DOD Departm ent of Defense DSA Detect, Sense, and Avoid System FAA Federal Aviation Adm inistration FCC Federal Communications Commission FARs Federal Aviation Regulations FIR Flight Information Region FL Flight Level FSIMS Flight Standards Information Managem ent System FTP Flight Term ination Point FTS Flight Term ination System GHz Gigahertz GCS Inspire Inspire Ground Control Station Inspire Unm anned Aircraft System Inspire Unm anned Aircraft MHz Megahertz MTOW Maxim um Takeoff W eight NAS National Airspace System NM Nautical Mile NOTAM Notice To Airm an OPA Optionally Piloted Aircraft PIC Pilot in Comm and Pure Art Productions Pure Art Productions LLC R&D Research and Development RF RM RNAV RTB RVSM Radio Frequency Risk Managem ent Area Navigation Return to Base Reduced Vertical Separation Minim umPage 12

TAS TC UA UAS UAV VFR VMC VO Traffic Advisory Systems Type Certificate Unm anned Aircraft Unm anned Aircraft System s(s) Unm anned Aerial Vehicle Visual Flight Rules Visual Meteorological Conditions Visual Observer