UNITED STATES OF AMERI CA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

WASHI NGTON, DC

Regulatory

Docket No. _______________

**IN T**  **HE MAT**  **T E**  **R OF THE PETITION FOR EXEMPTION OF:** 

David Garith Grinnell **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 O F**  **DJ I PHANTOM 2 VISION+ 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 March 25 , 2015 David Garith Grinnell 3115 Commonwealth Court, Suite B6, Owensboro, KY 270-485-38582 **TABLE OF CONTENTS** Page GLOSSARY OF ABBREVIATIONS...................................................................................3 SUMMARY................................................................................................ ...........................4 IN TRODUCTION AND INTERESTS OF PETITIONER....................................................4 BACKGROUND................................................................................................................... .4 BASI S FOR PETITION.........................................................................................................5 NAME AND ADDRESS OF PETITIONER.............................................................7 THE SPECI FI C SECTIONS OF 14 C.F.R. FROM WHI CH David Garith Grinnell SEEKS EXEMPTI ON.................................................................8 THE EXTENT OF RELIEF David Garith Grinnell SEEKS AND THE REASON David Garith Grinnell SEEKS THE RELIEF.........................11 THE REASONS WHY GR ANTING David Garith Grinnell's REQUEST WOUL D BE IN THE PUBLIC INTEREST .........................................................15 THE REASONS WHY GRANTING THE EXEMPTI ON WOULD NOT ADVERSEL Y AFFECT SAFETY..........................................................................19 SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGI STER......34 ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUM ENTS AVAILABLE TO SUPPORT David Garith Grinnell's REQUEST.........34 CONCL USION................................................................................................................... .35 APPENDI CES........................................................................................373 **GLOSSARY OF ABB REVIATIONS**  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 Sy stem LOL Loss of Link NAS National Airspace Sy stem NOTAM Notice to Airman PI C Pilot I n 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 Sy stem VFR Visual Flight Rules VLOS Visual L ine of Site VMC Visual Meteorological Conditions VTOL Vertical Takeoff and Landing4 **SUMMARY** David Garith Grinnell seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91. 1 21, 91.151(b) , 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a) (2), and 9 1.417(a) & ( b), to operate an Unmanned Aircraft Sy stem pursuant to Section 3 33 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit David Garith Grinnell to operate an Unmanned Aircraft Sy stem (UAS) for the commercial purpose of con ducting aerial video and ph o tograph y of construction sites, real estate, and landscape over certain areas of the United States.

**INTRODUCTION AND INTERESTS OF THE PETITIONER** David Garith Grinnell provides its clients with expertise and k n o wledge in advanced t echnologies and solutions to increase efficiency , productivity and effectiveness. David Garith Grinnell has over 10 y ears of professional experien ce in Information Technology and is recognized as an expert in network infrastructu r e and project management. He has over 10 ye ars recreational/hobby experience in all aspects of aerial

v ideo and photograph y . Th e o bjective of David Garith Grinnell aerial video and p hotography operation s is to provide high quality imagin g for a variety of co mme rcial, p u b lic, and residential uses, specificall y targeting:

 Construction sit es before and after

 Appraisals

 Real

- estate marketing

 Motion Picture Filming

 Aerial acquisitions used fo r inspections of public and private structures.

 Search and Rescue operations5 **BACKGROUND** Unmanned Aircraft Sy stems: DJI Phantom 2 Vision+, DJ I Inspire 1 UASs David Garith Grinnell seeks an exemption to operate DJI sy s tems for compensation
o r hire within the NAS. The DJI Phantom 2 Vision + and DJ I Inspire 1 are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station ( GCS)

u tilizin g electronic tablet or smart phone sy stems. The DJ I Phantom 2 Vision+ has a maximum gro ss weight of app roximately 2 pounds 11 ounces, while having a length of 16 inches width of 16 inches, height of 8 inches, and a maximum speed of approximately 29 knots. The DJ I Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17. 3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of app r ox imately 4 2 k

nots. The DJ I P hantom 2 Vision+ and DJ I Inspire 1UAs are equipped with four main rotors; driven by L ithium Poly mer battery powered electric motors. The DJ I Phantom 2 V ision+ and DJ I I n spire 1 UAs that will be op erated b y David Garith Grinnell 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, D a v i d G a r i t h G r i n n e l l , p u rsuant to t he provis i o n s o f t h e F edera l A v iation R e g u l a t i o n s (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 ( FMRA), Sec t i o n 3 3 3 , S p e c i a l R u l e s f

o r C e r t a i n U n m a n n e d A i r c r a

f t S y s t e m s , h e r e b y p et i t i o n s t h e A d m i n i s t r a t o r t o c o m m e rciall y opera t e t h e DJ I Phantom 2 Vision +, DJI I nspire 1 U A Ss in the National Airspace S ys tem (NAS), and for an exemption from the6

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 consider atio n o f the speed, weight, size, and li mited operating area associated with the unmanned aircraft and its operatio n, David Gar ith Grinnell op eration o f DJI Phantom 2 Vision+ and DJ I I n spire 1 UASs meets the co n d itions of FMRA Section 333 and therefore, w ill not require an airworthiness certificate i n accordance with 14 C.F.R. Part 21, Subpart H

. Accordingl y, Dav id Garith Grinnell requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 9 1 .417(a) & (b), as these sections set forth req u ir emen ts f

o r maintenance that onl y appl y to ai rcraft with an airworthiness certificate. David Garith Grinnell submits that the requested relief is proper since an equivalent l ev el of safety will be ensured. Dav id Garith Grinnell will use experienced personnel or technicians to p erform mainten ance, alterations, or preventive maintenance on the UASs using the met h ods, techniqu es, and practices prescribed in the operating documents (i.e., M o n th ly Maintenance Log , and DJ I Ph antom 2 Visio n + and DJ I Inspire 1 Instruction M anual). Further mo re, Dav id Garith Grinnell will do cument and maintain all maintenance records for the DJ I Phantom 2 Vision+ and DJ I In spire 1 UASs. Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in comma n d , is requested by David Garith Grinnell 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- h o u r and currency r eq u ir ements, that the P IC is able to safely o perate the DJI Phan to m 2 Visio n + an d DJI I nspire 1 UASs in a manner con sistent with this7

exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. David Garith Grinnell seeks relief from Section 91.7(a), entitled C ivil aircraft

a irworthiness , b ecause the DJ I P hantom 2 Vision+ and DJ I In spir e 1 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, David Garith Grinnell submits that he will ensure that the DJI P hantom 2 Vision+ and DJ I I n spire 1UASs are in an airworth y condition, prior to every f light, b y determining that the UASs are in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJ I Phantom 2 Vision+ and DJ I I n spire 1 Instruction Manual), and that the aircraft are in a condition for safe flight. David Garith Grinnell also seeks an exemption fro m th e requiremen ts of Sectio n 91.121, entitle d Altimeter Settings , as the DJ I P h an to m 2 Vis ion+ and DJ I In spire 1 UAs will not have a t ypical barometric altimeter onboard. However, altitude information of the DJ I Ph antom 2 Vision+ and DJI I nspire 1UAs will be provided to the PI C via Global Po sitioning Sy stem (GPS) equipment an d radio communicati ons telemetry data link, which downlinks from the UA to the GCS for active monitorin g of the flight path. This altitude i nformation, combined with David Garith Grinn ell's op eration of the DJ I Phantom 2 Vision+ and DJ I Inspire 1 UASs within visual line of sight, at or below 5 00 feet AGL, will ensure a lev el o f saf

ety eq u ivalent to Section 91.121. Additionally , David Garith Grinnell seeks an exemption from the requirements
o f Section 91.151(b), entitled Fuel requirements for flight in VFR conditions

. Dav id Garith Grinnell submits that safety will not be affected b y operation of the DJ I Phantom 2 Vision+ and DJ I I n spire 1 UAs during day light hours in visual meteorological conditions (VMC)8

under visual flight rules (VFR), with enough battery power to fl y for a total duration of approximately

13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fl y after that for at least 4.5 minutes. In accordance with 14 C.F.R. § 11.81, David Garith Grinnell pr ov ides the following information in support of i ts petition for exemption: **A. Name And Address Of The Petitioner.**  The name and address of the Petitioner and point of contact is: David Garith Grinnell 3115 Commonwealth Court, Suite B6, Owensboro, KY 270

- 485

- 3858 Email: David @tannerwest.com **B .**  **T he**  **Spec ific Sections Of**  **1 4**  **C.F.R. From Which**  David Garith Grinnell **Seeks Exemption.**  **1.** David Garith Grinnell **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) p rescribe the following, in relevant part: (a) No person who holds a private pilot certificate may act as a pilot in command (PI C) of an aircraft that is carry ing passengers or propert y for compensation or hire; nor may

that person, for compensation or hir e, act as PIC of an aircraft. (b) A private pilot may , for compensation or hire, act as PIC of an aircraft in connection with an y business or emplo ym ent if

— (1) The flight is only

incidental to that business or employ ment; and (2) The aircraft does not carr y passengers or property for compensation or hire.
**2.** David Garith Grinnell **Seeks Exemption From The Requirements Of Section**  **91. 7(a).** 9 Section 91.7, entitled Civil aircraft airworthiness , subsection (a), states the following: (a) No person may

operate a c ivil aircraft unless it is in an airworthy condition. **3.** David Garith Grinnell **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, b y 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) I n 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.** David Garith Grinnell **Seeks Exemption From The Requirements Of**  **Sect ion**  **91.151(b).** Sectio n 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 fue l to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes. **5.** David Garith Grinnell **Seeks Exemption From The Requirement Of**  **Sect ion**  **91. 4**  **0 5**  **(a).**10 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 d iscrepancies repaired as prescribed in part 43 of this chapter[.] **6.** David Garith Grinnell **Seeks Exemption From The Requirem**  **ent s Of**  **Section 9**  **1.407(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 b y a person authorized under § 43.7 of this chapter[.] **7.** David Garith Grinnell **Seeks Exemption From The Requirements Of**  **Sect ions**  **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 b y a person authorized by § 43.7 of this chapt er; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. **8.** David Garith Grinnell **Seeks Exemption From The Requirements Of**  **Sect ions**  **91.417(a) And 91.417(b).** Section 91.417, entitled Maintenance rec ords , 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:11 (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, a nd 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 cur

rent 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 safe ty directives including, for each, the method of compliance, the AD or safet y 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 prescri bed b y § 43.9(d) of this chapter for each major alteration to the airframe and currentl y installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed: (1) The records speci fied in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded b y other work or for 1 ye ar after the work is performed.12 (2) The records specified in paragraph (a)(2) of this section shall be retained and transferred wi th 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**  David Garith Grinnell **Seeks And The Rea son**  David Garith Grinnell **Seeks The Relief. 1.**  **E x**  **t ent Of Relief**  David Garith Grinnell **Seeks And The Rea son**  David Garith Grinnell **Seeks Relief From Section 61.113(a) And (b).** Relief from Section 61.113(a) and (b) entitl ed Private pilot privileges and limitations: Pilot in command , is requested to the extent necessary to allow a PI C holding a private pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met certain fligh t- 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 a s PI C of an aircraft in connection with an y business or emplo ym ent if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or propert y for compensation or hire. As set forth more full y below, David Garith Grinnell submits that an equivalent level of s afet y will be main tained because no PIC will be allowed to operate the DJ I Phantom 2 Vision+ UAS or DJ I Inspire 1 UAS unless that PIC has met certain flig ht -h our and currency r equirements, d emonstrating that the PIC is able to safely operate either the DJ I Phantom 2 Vision+ or DJI I nspire 1 UAS in a manner consistent with the operations sp ecifications as described in this exemption, including evasive and emergency maneuv ers, as well as maintaining appropriate distances from people, vessels, vehicles and structures.13 Further, David Garith Grinnell su b mits that all flights of the DJ I Phantom 2 Vision + and DJI I nspire 1 UASs, conducted by the PI C pursuant to the gr ant of this Petition: (1) will be incidental to David Garith Grinnell's business; and (2) will not carry passengers or p r o p ert y for compensation o r h ire. **2. E**  **x t**  **ent Of Relief** David Garith Grinnell **Seeks And The Reason** David Garith Grinnell **Seeks Relief From Section 91.7(a).** Relief from Section 91.7(a) entitled C ivil a ircraft airworthiness , is requested to the extent required to allow David Garith Grinnell to determine that the DJ I Phantom 2 Vision + and D JI I n spire 1 UASs are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the ope rating documents (i.e., the David Garith Grinnell Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJ I Inspire 1 Instruction Manual). David Garith Grinnell seeks the requested relief because the DJ I Phantom 2 Vision + and D JI I n spire 1 UASs do not require an airworthiness certificate in accordance with 14 C .F.R. Part 21, Subpart H. Therefore, David Garith Grinnell will ensure that the DJI Phantom 2 Vision+ and DJ I Inspire 1 UASs are in airwor th y condition based upon its compliance with t h e operating documents (i.e. , Monthly Maintenance Log, and DJI Phantom 2 Vision+ and D JI I nspire 1 Instruction Manual) prior to every flight, and further, d etermine that the aircraft are in condition for safe flight, as stated in the conditions and lim itations below. **3. E**  **x t**  **ent Of Relief** David Garith Grinnell **Seeks And The Reason** David Garith Grinnell **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 2 Vision+ 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 station14

(GCS). Since th e FAA requires that an y altitude information concerning UAS operations b e reported to air traffic control (ATC) in f eet above ground level (AGL), David Garith Grinnell seeks the requested relief because the DJ I P h antom 2 Vision+ and DJ I In spire 1 UA’s altimeter may be set on the ground to zero feet AGL , rather than the local barometric p r essure 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 full y set forth herein, an equivalent level of safet y will be maintained since the DJI Phant om 2 Vision+ and DJI I nspire 1 UAs are equipped with a barometric pressure sensor and GPS equipment, which automaticall y ensures that a ground level pressure setting will be established prior to each flight, and provides the PI C with altitude information o f the UA on the heads

- up display of the GCS. **4. E**  **x t**  **ent Of Relief** David Garith Grinnell **Seeks And The Reaso**  **n** David Garith Grinnell **Seeks Relief From Section 91.151(b).** Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions , is reques ted to the extent required to allow flights of the battery powered DJ I Ph antom 2 Vision+ and DJI I n sp ire 1 UAs during day light hours in visual meteorolog ical conditions (VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to the fir st point of intended landing and, assuming normal cruising spee d, to fly after that for at least 4.5 minutes. David Garith Grinnell seeks the requested relief because without an exemption from Section 91.151(b), the flight time duratio n of the battery p owered D JI Phantom 2 Vision + and DJI I nspire 1 UAs will severel y co nstr ain th e p racticality of any aerial video or still photo flight operatio n s that Dav idGarith Grinnell pr oposes to conduct p ursuant to this Petition.15 Significantl y , as set forth below, the technical specificatio ns of the DJ I P hantom 2 Vision+ and DJ I Inspire 1 UASs, the DJI P hantom 2 Vision+ and DJ I Inspire 1 operating d ocuments, and David Garith Gr innell's p r o p o sed o p eratin g limitations, ensure that David Gar ith Gr in n ell will safel y operate the battery po wered DJ I Phantom 2 Vision + and DJI I n spire 1 UAs durin g day light hours in visual meteorological conditions (VMC), under visual flight r

u les (VFR), with enough batter y p ower to fly f

o r a total duratio n o f

13.5 minutes to the first point of in ten d ed lan ding and, assuming normal cruising speed, to fl y after that for at least 4.5 minutes. **5. E**  **x t**  **ent Of Relief** David Garith Grinnell **Seeks And The Reason** David Garith Grinnell **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)
o nly appl y to aircraft with an airworthiness certificate, David Garith Grinnell requests relief from these Sections because the DJ I P hantom 2 Vision+ and DJ I In spire 1 UASs do

n o t requ ire airworthiness certificates. As set forth more fully below, the DJ I P hantom 2 Vision+ and DJ I Inspire 1 UASs meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingl y, David Garith Grinnell will use trained techn icians 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 David Garith Grinnell Aerial Operations Manual, Monthly Maintenance L og, and DJ I Phantom 2 Vision+ and DJI I nspire 1 I nstruction Manual). Furthermore, David Garith Grinnell will document and maintain all maintenance records for the DJ I P hantom 2 Vision+ and DJI I nspire 1 UASs. **D. The Reasons Why Granting**  David Garith Grinnell **Request Would Be In The Public**  **Interest; That Is, How It Would Benefit The Public As A Whole.**16 Granting the present Petition will further the public interest b y allowing David Garith Grinnell to safel y, efficiently, and economically perform aerial video and photograph y of construction sites, real estate, and landscape over certain areas of the United States. Additionally , use of the DJI Phan to m 2 Visio n + and DJI I nspire 1 UASs will d ecrease cong estion of the NAS, reduce pollution, and provide significant benefits to the e conom y. Notabl y, the benefits of Dav id Garith Grinnell's proposed operation of the DJI Ph antom 2 Vision+ and DJI I nspire 1 UASs will be realized without implicating any p rivacy issues

. **1. The Public Will Benefit From Decreased Congestion Of The NAS.** The DJ I Phantom 2 Vision+ and DJ I Inspire 1 UAs are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aeri al imagery . By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJ I Phantom 2 Vision+ or DJ I Inspire 1 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution , as well as increase the safet y of life and propert y in the air and on the ground. Furthermore, b y reducing the number of manned aircraft operating in the NAS, congestion around airports caused b y arriving and departing aircraft will be reduced. The DJI Phantom 2 Vision+ and DJI I nspire 1 UAs do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photograph y missions would result in fewer aircraft that must be handled b y air traffic control durin g 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 2 Vision+ and DJI Inspire 1 UASs.** 17 Conducting aerial acquisitions with the DJI Phantom 2 Visio n+ and DJ I Inspire 1 UASs, instead of manned aircraft, will greatl y benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still photograph y flight operations. By using battery power a nd electric motors, the DJ I Phantom 2 Vision+ and DJI I nspire 1 UASs produce no air pollution, and is the most viable environmentall y conscious alternative to the cabin class, six cy linder internal combustion engine aircraft that are t ypicall y utilized for aerial video and photography , while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The DJ I Phantom 2 Vision+ and DJI I nspire 1 UAs, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAs are propelled b y battery powered electric motors, rather than an internal combustion engine. By using the DJ I Phantom 2 Vision+ and DJ I Inspire 1 UASs to perform aerial acquisitions, the substantial risk to life and property in the air and on the grou nd, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completel y eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI Phantom 2 Vision+ and DJI I nspire 1 UAs (weighing approximately

2 pounds 11 ounces and 6 pounds 7.5 ounces respectivel y, at their maximum gross weights with lengths of 16 inches and 17.3 inches respectively , widths of 16 inches and 17.7 inches respectivel y, and with no fuel on board), has l ess phy sical potential for collateral damage to life and propert y on the ground, and in the air, compared to the manned aircraft that ty pically conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a leng th of 34 feet, and a fuel capacity of 180 gallons).18 **3. Performing Aerial Video and Photography Operations With The DJI Phantom 2 Vision+ and DJI Inspire 1 UASs Will Benefit The Economy.**  In addition to being safe and efficient, the DJ I P hantom 2 Vision+ and DJ I In spire 1 UASs are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJ I Phantom 2 Vision+ and DJI I nspire 1 UASs will allow United States based companies, like David Garith Grinnell , to remain competitive and contribute to growth of the U.S. economy . Specificall y, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions p h asing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery p o wered DJ I Phantom 2 Vision+ and DJI I nspire 1 UASs is one such technology that not only allows companies greater operational flexibilit y compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircr aft. By operating the DJ I P hantom 2 Vision+ and DJ I Inspire 1 UASs, companies such
as David Garith Grinnell , can remain competitive and profitable, and therefore, provide greater j o b stability to employ ees and contractors, which will ultimately contribute to growth of t he U.S. econom y. Improved financial performance of U.S. companies, through commercial use of the DJI Phantom 2 Vision+ and DJI I n spire 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 abro ad. **4. There Are No Privacy Issues.** Similar to the manned aerial acquisition f light operation s that have b een conducted for d ecades, David Garith Grinnell's propo sed o peration of the DJ I Phantom 2 Vision+ and DJI19

Inspire 1 UASs will not implicate any privacy issues. Specificall y, the DJ I Phantom 2 Vision+ and DJ I I n spire 1 U ASs will be operated only in compliance with operating d ocuments (i.e., the David Garith Grinn ell Aerial Operations Man ual, Monthly Maintenance Lo g, and DJ I P hantom 2 Vision+ and DJ I Inspire 1 I nstruction Manual) which requires p r opert y owner involvemen t as well as lo cal 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** David Garith Grinnell **Seeks Exemption. 1. Reasons Why The**  **DJI Phantom 2 Vi sion+ 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, David Garith Grinnell operation of the DJ I Phantom 2 Vision+ and DJI I nspire 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 securit y. Specificall y, FMRA Section 333 states the follow ing, 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 sa fely 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.20 (b ) Assessment of Unmanned Aircraft Systems.

-- In making the determination under subs ection (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 titl e 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 s afely 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, David Garith Grinnell submits that the D JI Phan tom 2 Vision+ and DJ I Inspire 1 UASs can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated b y: (a) the characteristics of the DJ I Phantom 2 Vision+ and DJ I Inspire 1 UASs; (b) the pilot certification requirement; and (c) the specific operating limitations.

**a. The Specifications Of The DJI Phantom 2 Vision+ and DJI Inspire 1**  **UASs Demonstrate Its Safe Characteristics.** The DJ I Phantom 2 Visi on+ and DJ I Inspire 1 UASs do not create a hazard to users of the NAS or the public, or otherwise pose a threat to national securit y considering its size, weight, speed, and operational capability

.

**i. Technical Specifications Of The DJI Phantom 2 Vision+**  **and DJI Inspire 1**  **UASs.** The technical specifications of the DJ I Phantom 2 Vision+ and DJ I Inspire 1 UASs are set forth b y the DJ I Phantom 2 Vision+ and DJI I nspire 1 Specifications and Data Sheet, attached hereto as Exhibit A and B.21 **ii. The DJI Phantom**  **2 Vision+ and DJI Inspire 1 UASs Autonomous**  **Flight And Navigation Modes Enable The UASs To Remain Within A Defined Operational Area.**  The DJ I Phantom 2 Vision+ and DJ I Inspire 1 UASs may be operated in both manual and full y autonomous flight modes. A comp lete description of the flight and navigational modes of the DJ I Phantom 2 Vision+ and DJ I Inspire 1 UASs is provided at pages 25

- 35 of the DJ I Phantom 2 Vision+ and pages 12

- 16 and 45

- 50 of the DJ I Inspire 1 User Manuals , attached hereto as Exhibit C and D.

**iii. The DJI Phantom 2 Vision+ 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 L ink is lost, the DJI Phantom 2 Vision+ and DJ I Inspire 1 UAs will remain stationary , in flight, for 3 seconds or more. If, after 3 seconds, the DJ I Phantom 2 Vision+ and DJ I Inspire 1 UAs do not reacquire control link data from the GCS, the UAs will assume that the Control L ink is lost and the UAs will return to th e 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 DJ I Phantom 2 Vision+ UAS are set forth at pages 27 through 29 and for the DJ I Inspire 1 at pages 13 through 15 of the DJ I Phantom 2 Vision+ and DJ I Inspire 1 User Manuals, attached hereto as Exhibit C and D. **iv. The DJI Phantom 2 Vision+ and DJI Inspire 1**  **GCS And Its**

**Operation.** A complete description of the operation and specifications of the DJ I Phantom 2 Vision+ and DJ I Inspire 1 GCS and flight control software is provided at pages 32 through 43 of the DJ I Phantom 2 Vision+ User Manual and pages 40 through 47 of the DJ I Inspire22

1 User Manual. DJ I Phantom 2 Vision+ and DJ I Inspire 1 User Manuals are attached hereto as Exhibits C and D.

**b. Flight Operations Of DJI Phantom 2 Vision+ and DJI Inspire 1**  **UASs Are Limited To The Line Of Sight Of A Certificated Pilot in Command**  **With A S afety Observer.**  David Garith Grinnell will only u tilize certificated pilots who possess a current and

v alid airman medical certificate to act as a pilot in command (PI C) of th e DJ I P han tom 2 Vision+ and DJ I I nspire 1 UASs. Addition ally , a safet y observer will assist all pilots d u ring flight t ime. **c. Flights Of DJI Phantom 2 Vision+ and DJI Inspire 1**  **UASs Will Be Conducted Pursuant To Specific Operating Limitations.**  In seeking this exemption, David Garith Grinnell p ro poses to commerciall y
o p erate DJ I Phantom 2 Vision+ an d DJI I nspire 1 UASs for t he special purpose of conducting aerial video and photogr ap h y over certain areas of United States, pur suant to the following s pecific operating limitations: 1. Operations authorized by this grant of exemption will be limited to the following aircraft descr ibed in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: DJ I Phantom 2 Vision+ and DJ I Inspire 1 Unmanned Aircraft S ys tems. Proposed operations of an y other aircraft will require a new petition or a petition to am end this grant. 2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photograph y. 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 b y ATC. All altitudes reported to ATC must be in feet AGL. 5. The UAs must be o perated within visual line of sight (VLOS) of the PI C at all times. This requires the PIC to be able to use human vision unaided by an y device other than corrective lenses, as specified on the PI C’s FAA

- issued airman medical certificate.23 6. The use of first person view (FPV) b y the PI C or safet y observer (SO) is not permitted. 7. All operations must utilize a safet y observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC alway s maintains VL OS capability

. The SO and PI C 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 PI C must ensure that the SO can perform the functions prescribed in the operating documents. 8. The SO must not perform any other duties bey ond assisting the PI C with seeing and avoiding other air traffic and other ground based obstacles/obstruction s 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 co nditions 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 follo w 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 I ntegration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operating documents. 10. Prior to each flight the PI C must inspect the UA S 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 properl y documented in the aircraft records. 11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PI C who conducts the functional test flight must make an entry in the aircraft records. 12. The pre

- flight ins pection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not alread y covered in the relevant sections of the operating documents.24 13. The operator must follow the UAS manufacturer’s aircraft/component, mainte nance, 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 aircraf t 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. T he authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections. 17. The PI C 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 PI C meets the operator’s qualification criteria and demonstrates the ability to safel y 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 tr aining 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 f light operations are considered nonparticipants, and the PI C 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.25 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 PI C.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 PI C must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating document s. 24. The PI C 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 an y operations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not m ore 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 requirem ents. 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 require ments. 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 an y time the UAS is operating. These documents must be made available to the Administrator or an y law enforcement official upon request. 29. The UA must remain clear and yi eld the right of way to all manned aviation operations and activities at all times. 30. The UAS may

not be operated b y 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 PI C, SO, operator trainees or essential persons), vessels, vehicles, and structures unless:26 a. Barriers or structures are present that suf ficiently 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 protectio n 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 PI C h as made a safet y 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 PI C, 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 wil l 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 Off ice (AFS

- 80) within 24 hours. Accidents must be reported to the National Transportation Safet y Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

. **2. Reasons Why An Exemption From The Requiremen ts Of Section 61.113(a)**  **And (b) Would Not Adversely Affect Safety.** David Garith Grinnell submits that the equivalent level of safet y established by Section 61.113(a) and (b) will be maintained because n o PIC will be allowed to operate the DJ I Phantom 2 Vision+ and DJI I nspire 1 UASs unless that PI C has demonstrated, b y meeting minimum flight-h our and currency requirements, that the PI C is able to safely
o p erate the DJI Phantom 2 Vision+ o r DJ I Inspire 1 UAS in a manner consistent with the exemption, incl uding evasive and emergency maneuvers and maintaining appropriate distanc es from p eople, vessels, vehicles and structures. C onsidering David Garith Grinnell's proposed area of operations, and the operating l imitations set forth -a bove; the parallel nature of p r ivate pilot aeronautical knowledge27

requirements to those of commercial pilot requirements ( See Exemptio n No. 1 10 62 ); and th e airmanship skills necessar y to safel y operate the DJ I P hantom 2 Vision+ or DJ I In spir e 1 UAS, David Garith Grinnell submits that the add itional manned airmanship experience
o f a commerciall y certif

icated pilot would not correlate to the airmanship sk ills necessar y f or David Garith Grinnell's specif ic 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). David Garith Grinnell will not allow any PI C to operate the DJ I P hantom 2 Vision+ or DJI I nspire 1 UAS unless that PI C has demonstrated, by meeting minimum flight-h o u r requirements or the DJ I Phantom 2 Vision+ or DJI Inspire 1 UAS training and currency requiremen ts, that the PIC is able to safel y operate the DJ I P hantom 2 Vision+
or DJ I Inspire 1 UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels,

v ehicles and structu res. Specificall y, the PI C 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 PI C must accomplish 3 takeoffs and landings in the preceding 90 day s (for currency purposes).28 As in Exemption Nos. 11062, 11138, and 11153, prior documented flight expe rience that was obtained in compliance with applicable regulations will ensure an equivalent level of safet y during David Garith Grinnell's proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance w ith 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 PI C must also have accumulate d 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 PI C must accomplish 3 takeoffs and landings in the preceding 9 0 day s (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 accom plish the required flight time. During training, proficiency , and experience

- building flights the PI C is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15. Accordingl y, David Garith Grinn ell will ensure safe operations by n ot allowing any PIC to operate the DJ I Phantom 2 Vision+ or DJ I Inspire 1 UAS unless that PI C has demonstrated, b y meeting minimum flight

- hour and currency requirements, that the PI C is able to safel y operate the DJI Pha ntom 2 Vision+ or DJ I 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.29 **3. Reasons Why An Exemption From The Requirements Of Section 91.7(a)**  **Would Not Adversely Affect Safety.** The equivalent level of safet y established b y Section 91.7(a) will be maintained b ecause prior to every f

light, David Garith Grinnell will ensure that the DJI P h antom 2 Vision+ or DJ I Inspire 1 UAS is in an airworth y condition based upon the UAS’s compli ance 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 circumstance s 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 Fr om**  **The Requirements Of Section 91.121 Would Not Adversely Affect Safety.**  The equivalent level of safet y established b y Section 91.121 will be maintained because the altitude information of the DJ I Phantom 2 Vision+ and DJ I Inspire 1 UAs will b e provided to the PI C via GPS equipment and a radio communications telemetry data link, which downlinks from the UA to the GCS for active monitor ing of the flight path and altitude. This altitude informatio n, combined with David Garith Grinnell's operation of the DJ I Phant om 2 Vision+ and DJI I nspire 1 UAs within visual line of sight, at or below 500 feet A GL, will ensure a level of safet y equivalent to Section 91.121. The altitude information will be generated b y GPS equipment installed onboard the aircraft. Prior to each flight, a z ero altitude initiation point is automatically established by the UASs at ground level. The FAA has previou sly g r anted relief from Section 91.121 specific to UAS, in circumstances similar, in all material resp ects, to tho se 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).30 **5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely Affect Safe**  **ty.** A grant of this exemption wou ld ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b) as a result of (1) the tech n ical specifications of the DJ I Ph antom 2 Vision+ and DJI I nspire 1 UASs; ( 2 ) th e limitation s o n the proposed f light
o perations; and (3) the location o f the proposed flight operations. Accordingl y, David Garith Grinnell will ensure that it will safely o perate the battery po wered DJ I P h anto m 2 Vision+ and DJ I Inspire 1 UAs during day light hours in VFR co nditions, with en ough b attery p o wer to fl y for a total d u r ation of 13.5 minutes to the first point of intended lan d ing and, assu ming normal cruising speed, to fl y after that for at least 4.5 minutes. Here, as in Exemption No. 11109, the technical specifications of the DJ I Phantom 2 Vision+ and DJ I 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 b y 14 C.F.R. Section 91.151(b). Furthermore, safety will be ens ured as the DJI Phantom 2 Vision+ and DJ I Inspire 1 UASs provide audible and visual warnings to the PI C at the GCS when the UAs experiences low battery voltage, the first warning occurring at approximately

33% remaining battery

power, and again at approxim ately 10% remaining battery power. At the critically

low battery

level, the DJ I Phantom Vision+ and DJ I Inspire 1 UASs will descend and land automatically

. Significantl y, previous exemptions granted b y the FAA concerning Section 91.151 establish that safe ty

is not adversel y 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. 268 9, 5745, and 10650. Moreover, the FAA has previously granted relief31

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, 1106 5, 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, David Garith Grinnell submits that th e equivalen t level of safet y with regar d to th e regulatory maintenance and alteration requirements establishe d b y Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met b ecause David Garith Grinnell will use trai ned technicians to perform main tenance, alterations, or preventiv e maintenance on the UASs using the methods, techniques, and p r actices prescribed in the operating documents (i.e., the David Garith Gr inn ell Aer ial Op erations Manual, Monthly Maintenance Log, and DJ I P hantom 2 Vision+ an d DJ I I n spire 1 Instruction Manual). Further more, David Garith Grinnell will document an d maintain all maintenance reco r d s f o r the DJ I P hantom 2 Vision+ and DJ I Inspire 1 UASs. Sin ce the DJ I Phant om 2 Vision+ and DJ I Inspire 1 UASs will be inspected as p r escribed b y the operating documents, David Garith Grinnell will maintain the equivalen t level o f safet y established by Sectio n s 9 1

. 4 05(a), 91.409(a)(1), and 91.409(a)(2). A cop y
o f the DJI Ph an to m 2 Vision+ and DJI I nspire 1 User Manuals are attached hereto as Ex h ibit C and D; a cop y of the DJ I Ph antom 2 Vision+ an d DJI I nspire 1 UAS Maintenance LOG is attached hereto as Exhibit E. Likewise, the ex emption sought will not adversel y af f ect saf ety because David Garith Gr in nell will use trained tech nicians to perform maintenance, alterations or preventive32

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 safet y established by

Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI Phantom 2 Vision+ and DJI I nspire 1 UASs will be performed b y trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log. Signif icantly, previous exemptions granted b y the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safet y is not adversel y affected when the technical characteristics and operating limitations of the UAS are considered. In consideration of David Garith Grinnell's proposed operating limitations, the operating d o cuments, and the technical aspects of the DJ I P han tom 2 Vision+ an d DJ I I n spire 1 UASs, David Garith Grinnell su bmits that safety will not be adversely affec ted by g ranting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a) (2), and 9 1 .417(a) and (b )

. The FAA has prev iousl y granted relief specific to UAS in circumstances similar, in all material respects, to those presented h er ein ( e.g. Exemption Nos. 11 062, 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 , David Garith Grinnell requests that the FAA prescribe special conditions for the intended operation of the DJI Phantom 2 Vision+ and DJ I I n spire 1 UASs , which contain such safety standards that the33

Administrator finds necessary to establish a level of safet y equivalent to that established b y 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 photograph y over certain areas of the United States for compensation or hire. FMRA Section 3 33 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 certific ation 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 DJ I Phantom 2 Vision+ and DJ I Inspire 1 UASs, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safet y 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 safet y standards for an aircraft, aircraft engine, or propeller because of a novel or unusual design feature of the aircraft, aircraft engine o r 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 f inds 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 L eading Edge’s inte nded operation of the DJ I Phantom 2 Vision+ and DJI I nspire 1 UASs, which contain such safet y standards that the34

Administrator finds necessary to establish a level of safet y equivalent to that established b y 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Secti ons 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** David Garith Grinnell **Seeks Exemption:** David Garith Grinnell seeks exemption from the requirements of 14 C.F.R Sections 6 1

. 1 1 3( a) &(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.4 09(a)(1) & (a )(2), and 91.417(a) & (b). **A Brief Description Of The Nature Of The Exemption** David Garith Grinnell **Seeks:** This exemption will permit David Garith Grinnell 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 Avai**  **lable To Suppo rt**  David Garith Grinnell'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 s uch, David Garith Grinnell'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 securit y; and further, provides the authority for such UAS to operate without airworth iness certification. As discussed in detail above, Dav id Garith Grinnell will operate the DJ I Phantom 2 Vision+ an d DJ I Inspire 1 UASs safel y in the NAS, without creating a h azard to users of the NAS, or the public, or otherwise pose a threat to national secur ity

.35 **CONCLUSION** As set forth herein, David Garith Grinnell seeks an exemption pursuant to 14 C.F.R . § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), w hich will permit safe operation of the DJ I Phantom 2 Vision+ and DJ I I n spire 1 UASs c ommerciall y, without an airworthiness certificate, for the limited p u r p o se of conducting aerial video and photography o v er certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandat e of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, b y allowing David Garith Grinnell to safel y, efficientl y, and economically operate the DJ I Phantom 2 Vision+ and DJI I nspire 1 UASs commercially within the NAS

. **W HEREFORE**  , in accordance with the Fed eral Av iation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, David Garith Grinnell respectfully

r equests that the Administrator grant this Petition for an exemp tion from the requiremen ts
o f 14 C

. F. R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a) , 91.4 07 (a)( 1) , 91.409(a)(1) & (a)(2), and 91.417(a) & (b ) , and permit L eading Edge to operate the DJ I Phantom 2 Vision + and DJI I nspire 1 UASs commerciall y for the purpose of co nd ucting aerial video and photography o ver certain areas of the United States. Date d : March 25 , 2015
R espectfully submitted, David Garith Grinnell

_________________________36 David Garith Grinnell 3115 Commonwealth Court, Suite B6, Owensboro, KY 270-485-3858 Email:David@tannerwest.com Appendic es : A

– DJ I Phantom 2 Vision+ Specifications Data Sheet B

– DJ I Inspire 1 Specifications Data Sheet C

– DJI Phantom 2 Vision+ Manufacturer’s User Manual D

– DJ I Inspire 1 Manufacturer’s User Manual E

– Monthly

Maintenance L og37 APPENDIX – A **DJI PHANTOM 2 VISION+ TECHNICAL SPECIFICATIONS**  David Garith Grinnell only utilizes safe and reliable UASs. DJI is an industry leader in small UAS production. DJ I U ASs are loaded with ground br eaking software enabling th e user to set parameters which will not allow flight into controlled air space. Parameters can also be s et to limit flight to no higher than a predetermined and set altitude as well as limit fli g h t to a p r edetermined and set distance. In ad dition, DJ I software pro vides real -time altitude and l o cation information to the PI C via the linked monitor (smart phone/t ablet devices) 1.1 DJI Phantom 2 Vision+ 1.1.1 Aircraft 1.1.1.1 Supported Battery

– DJ I 5200mAH LiPo Battery 1.1.1.2 Weight (Battery

& Propellers Included)

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

(Ready to Fl y)

– Vertical: .8m; Horizontal: 2.5m 1.1.1.4 Max Yaw Angular Velocit y - 200 0 /s 1.1.1.5 Max Tilt Angel - 35 0 1.1.1.6 Max Ascent Speed

– 6m/s 1.1.1.7 Max Descent Speed

– 2m/s 1.1.1.8 Max Flight Speed

– 15m/s (NOT RECOMMENDED) 1.1.2 Gimbal 1.1.2.1 Working Current

– Static: 750mA; Dy namic: 900mA 1.1.2.2 Control Accuracy

- ±0.03 0 1.1.2.3 Controllable Range

– Pitch: -90 0 - 0 0 1.1.2.4 Maximum Angular Speed

– Pitch: 90 0 /s 1.1.3 Camera 1.1.3.1 Operating Temperature Range - 32 0 F - 104 0 F (0 0 C - 40 0 C) 1.1.3.2 Sensor Size

– 1/2.3” 1.1.3.3 Effective Pixel s – 14M 1.1.3.4 Resolution – 4384x3288 4.1.3.5 HD Video Recording

– 1080p30 & 720p 4.1.3.6 Recording Field of View - 110 0 /85 0 1.1.4 Transmitter 1.1.4.1 Operating Frequency

– 5.728GHz

– 5.85GHz 1.1.4.2 Communication Distance (unobstructed)

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

- - 93dBm 1.1.4.4 Transmitter Power – FCC Compliance: 100mW 1.1.4.5 Working Voltage

– 120mA@3.7V 1.1.5 Range Extender 1.1.5.1 Operating Frequency – 2412- 2462MHz38 1.1.5.2 Communication Distance (unobstructed)

– 500

- 700m 1.1.5.3 Transmitter Power

– 20dBm 1.1.5.4 Power Consumption

– 2W39 APPENDIX – B **DJI INSPIRE 1 TECHNICAL SPECIFICATIONS**  David Garith Grinnell only utilizes safe and reliable UASs. DJI is an industry leader in small UAS production. DJ I U ASs are loaded with ground br eaking software enabling th e user to set parameters which will not allow flight into controlled air space. Parameters can also be s et to limit flight to no higher than a predetermined and set altitude as well as limit fli g h t to a p r edetermined and set distance. In ad dition, DJ I software pro vides real -time altitude and l o cation information to the PI C via the linked monitor (smart phone/t ablet devices) 2.2 DJI Inspire 1 2.2.1 Aircraft 2.2.1.1 Model
– T600 2.2.1.2 Weight (Battery Included)
– 6lbs 7.5291oz (2935g) 2.2.1.3 Hovering Accuracy (GPS Mode)
– Vertical: 0.5m; Horizontal: 2.5m 2.2.1.4 Max Angular Velocity – Pitch: 300 0/s; Yaw: 1500 /s 2.2.1.5 Max Tilt Angle

- 35 0 2.2.1.6 Max Ascent Speed
– 5m/s 2.2.1.7 Max Descent Speed
– 4m/s 2.2.1.8 Max Speed
– 22m/s (ATTI mode, no wind – NOT RECOMMENDED) 2.2.1.9 Max Flight Altitude
– 4500m 2.2.1.10 Max Wind Resistance
– 10m/s 2.2.1.11 Max Flight Time
– Approximately 18 minutes 2.2.1.12 Motor Model
– DJI 3510 2.2.1.13 Propeller Model – DJI 1345 2.2.1.14 Operating Temperature Range
– 14 0F to 1040F (

- 10 0C to 400C) 2.2.1.15 Dimensions
– 17 1⁄4” x 17 3⁄4” x 12” 2.2.2 Gimbal 2.2.2.1 Model
– ZENMUSE X3 2.2. 2.2 Output Power (with camera) – Static: 9W; In Motion: 11W 2.2.2.3 Operating Current – Static: 750mA; In Motion: 900mA 2.2.2.4 Angular Vibration Range

- ±0.03 0 2.2.2.5 Mounting
– Detachable 2.2.2.6 Controllable Range – Pitch:

- 90 0 to +300; Pan: ±3200 2.2. 2.7 Mechanical Range – Pitch:

- 125 0 to 450; Pan: ±3300 2.2.2.8 Max Controllable Speed
– Pitch: 1200/s; Pan: 1800/s 2.2.3 Camera 2.2.3.1 Name
– X3 2.2.3.2 Model
– FC350 2.2.3.3 Total Pixels – 12.76M40 2.2.3.4 Effective Pixels
– 12.4M 2.2.3.5 Image Max Size
– 4000x3000 2.2.3.6 ISO Range
– 100
- 3200 2.2.3.7 Field of View

- 94 0 2.2.3.8 CMOS
– Sony EXMOR 1/2.3” 2.2.3.9 HD Video Recording
– UHD(4K): 4096x2160p24/25, 3840x2160p24/25/30; FHD: 1920x1080p24/25/30/48/50/60; HD: 1280x720p24/25/30/48/50/60 2.2.3.10 Operat ing Temperature Range
- 32 0F

- 104 0F (00C

- 40 0C) 2.2.4 Transmitter 2.2.4.1 Name
– C1 2.2.4.2 Operating Frequency
– 5.728
- 5.850GHz; 2.400
- 2.483GHz 2.2.4.3 Communicating Distance (unobstructed)
– 2000m 2.2.4.4 Output Power
– 9W 2.2.4.5 Operating Temperatur e Range
- 14 0F to 1040F (

- 10 0C to 400C) 2.2.4.6 Battery
– 600mAh LiPo 2S41 APPENDIX

– C DJI Phantom 2 Vision+ Manufacturer’s User Manual42 APPENDIX

– D DJI I nspire 1 Manufacturer’s User Manual43 APPENDIX

– E

m o n t h :

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