UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC Regulatory Docket No. _______________ IN THE MATTER OF THE PETITION FOR EXEMPTION OF: INTERIOR PIXELS, INC. FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF DJI PHANTOM 2 AND DJI INSPIRE 1 UNMANNE D AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95) Submitted on May 26, 2015 Brendan Carlisle Interior Pixels, Inc. 5640 Via Bonita Newbury Park, CA 91320 Tel: (818) 427

-9863

TABLE OF CONTENTSGLOSSARY OF ABBREVIATIONS...................................................................................3

SUMMARY...................................................................................................................... .....4 INTRODUCTION A ND INTERESTS OF PETITIONER....................................................4 BACKGROUND................................................................................................................... .4 BASIS FOR PETITION.........................................................................................................5 NAME AND ADDRESS OF PETITIONER.............................................................7 THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH IN TERIOR PIXELS SEEKS EXEMPTION.................................................................8 THE EXTENT OF RELIEF INTERIOR PIXELS SEEKS AND THE REASON INTERIOR PIXELS SEEKS THE RELIEF.........................11 THE REASONS WHY GRANTING INTERIOR PIXEL’S REQUEST WOULD BE IN THE PUBLIC INTEREST .........................................................15 THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY..........................................................................19 SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER......34 ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT INTERIOR PIXEL’S REQUEST.........34 CONCLUSION.................................................................................................. ..................35 APPENDICES........................................................................................37 3 GLOSSARY OF ABBREVIATIONS AGL Above Ground Level AOI Area of Interest ATC Air Traffic Control ATO Air Traffic Organization AV Aerial VehicleCFR Code of Federal Regulations

COA Certificate of Authorization FAA Federal Aviation Administration FAR Federal Aviation Regulation GCS Ground Control Station GPS Global Positioning System LOL Loss of Link NAS National Airspace System NOTAM Notice to Airman PIC Pilot In Command Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333 SO Safety Observer SOP Standard Operating Procedures UA Unmanned Aircraft UAS Unmanned Aircraft System VFR Visual Flight Rules VLOS Visual Line of Site VMC Visual Meteorological Conditions VTOL Vertic al Takeoff and Landing 4 SUMMARY Interior Pixels seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permitInterior Pixels to operate an Unmanned Aircraft System (UAS) for the

commercial purpose of conducting ae rial real estate and landscape video and p hotography for the purpose of producing real estate videos and commercials. INTRODUCTION AND INTERESTS OF THE PETITIONER Interior Pixels provides its clients with expertise and knowledge in various aspects of aeri al video and photography. The objective of Interior Pixel ’s aerial video and photography operations is to provide low cost, high quality imaging for a variety of commercial and residential customers. BACKGROUND Unmanned Aircraf

t Systems: DJI Phantom 2 , DJ I Inspire 1 UASs Interior Pixels seeks an exemption to operate DJI systems for compensation or hire within th e NAS. The DJI Phantom 2 and DJI Inspire 1 are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart p hone systems. The DJI Phantom 2 has a maximum gross weight of approximately 2 pounds 11 ounces, while having a length of 16 inches, width of 16 inches, height of 8 inches, and a maximum speed of 5 approximately 29 knots. The DJI 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 approximately 42 knots. The DJI Phantom 2 and DJI Inspire 1UAs are equipped with four main rotors; driven by Lithium Polymer battery powered electric motors. The DJI Phantom 2 and DJI Inspire 1 UAs that will be operated by Interior Pixels 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 inaccordance with 14 C.F.R. Part 45, Identification and Registration Marking.

BASIS FOR PETITION Petitioner, Interior Pixels, 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 o perate the DJI Phantom 2 , DJI Inspire 1 UASs in the National Airspace System (NAS), and fo r 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 th e unmanned aircraft and i ts operation, Interior Pixels’s operation of DJI Phantom 2 and DJI Inspire 1 UASs meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H
. 6 Accordingly, Interior Pixels 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. Interior Pixels submits that the requested relief is proper since an equivalent level of safety wil l be ensured. Interior Pixels will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documen ts (i.e., the Interior Pixels Aerial Operations Manual, Monthly Mainten ance Log, and DJI Phantom 2 and DJI Inspire 1 Instruction Manual). Furthermore, Interior Pixels will document a nd maintain all maintenance recordsfor the DJI Phantom 2 and DJI Inspire 1 UASs.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested by Interior Pixels to the ext ent 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 safe ly
o perate the DJI Phantom 2 and DJI Inspire 1 UASs in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Interior Pixels seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, b ecause the DJI Phantom 2 and DJI Inspire 1 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Interior Pixels submits that it will ensure that the DJI Phantom 2 and 7 DJI Inspire 1UASs are in an airworthy condition, prior to every flight, by determining that the UASs are in compliance with the operat ing documents (i.e., the Interior Pixels Aerial Operations Manual, Monthly Mai ntenance Log, and DJI Phantom 2 and DJI Inspire 1 Instruction Manual), and that the aircraft are in a condition for safe flight. Interior Pixels also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settin gs, as the DJI Phantom 2 and DJI Inspi re 1 UAs will not have a typical barometric altimeter onboard. However, altitude information of the DJI Phantom 2 and DJI Inspire 1UAs will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with Interior Pixel ’s operation of the DJI Phantom 2and DJI Inspire 1 UASs within visual line of sight, at or below 500 feet AGL, will

en sure a level of safety equivalent to Section 91.121. Additionally, Interior Pixels seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions Interior Pixels submits that safety will not be affected by operation of the DJI Phantom 2 and DJI Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration of approximatel y 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. 8 In accordance with 14 C. F.R. § 11.81, Interior Pixels provides the following information in support of its petition for exemption: A. Name And Address Of The Petitioner. The name and address of the Petitioner and point of contact is: Brendan Carlisle Interior Pixels, Inc. 5640 Via Bonita Newbury Park CA 91320 Tel: (818) 427

-9863 E mail: bcarlisle@interiorpixels.com B. The S pecific Sections Of 14 C.F.R. From Which Interior Pixels Seeks Exemption. 1. Interior Pixels Seeks Exemption From The Requirements Of Section 61.113(a) And (b). Section 61.113, entitled Private pilot privileges and limitations: Pilot in command,subsections (a) and (b) prescribe the following, in relevant part:

(a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PIC of an aircraft. (b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if
— (1) The flight is only incidental to that business or employment; and (2) T he aircraft does not carry passengers or property for compensation or hire. 2. Interior Pixels Seeks Exemption From The Requirements Of Section 91.7(a). Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following: (a ) No person may operate a civil aircraft unless it is in an airworthy condition. 9 3. Interior Pixels Seeks Exemption From The Requirements Of Section 91.121. Section 91.121, entitled Altimeter settings, subsection (a), states the following, in p art: (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) ofthis section, the current reported altimeter setting of an appropriate

available statio n; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure. 4. Interior Pixels Seeks Exemption From The Requirements Of Section 91.151(b). Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states the following: (b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes. 5. Interior Pixels Seeks Exemption From The Requirement Of Section 91.405(a). Section 91.405, entitled Ma intenance 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 t his section, have discrepancies repaired as prescribed in part 43 of this chapter[.] 10 6. Interior Pixels 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 perso n authorized under § 43.7 of this chapter[.] 7. Interior Pixels Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2). Section 91.409, entitled Inspections, subsection (a), states the following: (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

-- (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person aut horized by § 43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. 8. Interior Pixels Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b). Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following: (a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preventive maintenance, and alteration and records of the 100

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

--

11 (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) T he signature, and certificate number of the person approving the aircraft for return to service. (2) Records containing the following information: (i) The total time in service of the airframe, each engine, each propeller, and each rotor. (ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and s afety 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 presc ribed by § 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances.(b) The owner or operator shall retain the following records for the periods

prescribed: (1) The records speci fied 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 wit h 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. 12 C. The Ext ent Of Relief Interior Pixels Seeks And The Reason Interior Pixels Seeks The Relief. 1. Ext ent Of Relief Interior Pixels Seeks And The Reason Interior Pixels Seeks Relief From Section 61.113(a) And (b). Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command, is requested to the extent necessary to allow a PIC holding a private pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met certain flight

- h our 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 PI C 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, Interio r Pixels submits that an equivalent

level of safety will be maintained because no PIC will be allowed to operate the DJI Phantom 2 UAS or DJI Inspire 1 UAS unless that PIC has met certain flight

- hour and currency requirements, demonstrating that the PIC is able to safely operate either the DJI Phantom 2 or DJI Inspire 1 UAS in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from peo ple, vessels, vehicles and structures. Further, Interior Pixels submits that a ll flights of the DJI Phantom 2 and DJI Inspire 1 UASs, conducted by the PIC pursuant to the grant of this 13 Petition: (1) will be incidental to Interior Pixel ’s business; and (2) will not carry passengers or property for compensation or hire. 2. Ext ent Of Relief Interior Pixels Seeks And The Reason Interior Pixels Seeks Relief From Section 91.7(a). Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent requ ired to allow Interior Pixels to determine that the DJI Phantom 2 and DJI Inspire 1 UASs are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operat ing documents (i.e., the Interior Pixels Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 and DJI Inspire 1 Instruction Manual). Interior Pixels seeks the requested relief because the DJI Phantom 2 and DJI Inspire 1 UASs do not require an airworthiness certificate in accorda nce with 14 C.F.R. Part 21, Subpart H. Therefore, Interior Pixels will ensure that the DJI Phantom 2 and DJI Inspire 1 UASs are in airworthy condition based upon its compliance with the operating documen ts (i.e., the Interior Pixels AerialOperations Manua l, Monthly Maintenanc e Log, and DJI Phantom 2 and DJI

Inspire 1 Instruction Manual) prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated in the conditions and limitations below. 3. Extent Of Relief Interior Pixels Seeks And The Reason Interior Pixels Seeks Relief From Section 91.121. Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operati ons of the DJI Phantom 2 and DJI Inspire 1 UASs, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAS opera tions 14 be reported to air traffic control (ATC) in feet a bove ground level (AGL), Interior Pixels seeks the requested relief b ecause the DJI Phantom 2 and DJI Inspire 1 UA’s altimeter may be set on the ground to zero feet AGL, rather than the local barom etric pressure or field altitude, before each flight. Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply with the applicable conditions and limitations stated below. As more fu lly set forth herein, an equivalent level of safety will be maintained since the DJI Phantom 2 and DJI Inspire 1 UAs are equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the PIC with altitude information of the UA on the heads

- up display of the GCS. 4. Extent Of Relief Interior Pixels Seeks And The Reason Interior Pixels Seeks Relief From Se ction 91.151(b). Relief from Section 91.151(b) entitled Fuel requirements for flight in VFRconditions, is requested to the extent required to allow flights of the battery powered DJI

Phantom 2 and DJI Inspire 1 UAs during daylight hours in visual meteorol ogical conditions (VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. Interior Pixels seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered DJI Phantom 2 and DJI Inspire 1 UAs will severely constrain the practicality of any aerial video or still photo flight op erations that Interior Pixels proposes to conduct pursuant to this Petition. 15 Significantly, as set forth below, the technical specifications of the DJI Phantom 2 and DJI Inspire 1 UASs, the DJI Phantom 2 and DJI Inspire 1 operating d ocuments, and Interior Pixel ’s proposed operating l imitations, ensure that Interior Pixels will safely operate the batte ry powered DJI Phantom 2 and DJI Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a tot al duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. 5. Extent Of Relief Interior Pixels Seeks And The Reason Interior Pixels Seeks Relief From Section s 91.405(a), 91.407 (a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b). Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, Interior Pixels requests relief from these Se ctions because the DJI Phantom 2 and DJI Inspire 1 UASs do not require airworthiness certificates. As set forth more fully below, the DJI Phantom 2 and DJI Inspire 1 UASs meet the conditions of FMRA Section 333 for operationwithout an airworthiness certificate. Accordingly, Interior Pixels will use trained

technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the UAS operating documents (i.e. , the Interior Pixels Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 and DJI Inspire 1 Instruction Manual). Furthermore, Interior Pixels will document and maintain all maintenance records for the DJI Phantom 2 and DJI Inspire 1 UASs. D. The Reasons Why Granting Interior Pixel ’s 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 pu blic interest by allowing Interior Pixels to safely, efficiently, and economically perform aerial video and photography of real estate and landscape over certain areas of the United States. Additionally, use of the DJI Phantom 2 and DJI Inspire 1 UASs will decrease congestion of the NAS, reduce pollution, and provide si gnificant benefits to the economy. Notably, th e benefits of Interior Pixel ’s proposed operation of the DJI Phantom 2 and DJI Inspire 1 UASs will be realized without implicating any privacy issues. 1. The Public Will Benefit From Decreased Conge stion Of The NAS. The DJI Phantom 2 and DJI Inspire 1 UAs are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft neede d to perform aerial acquisitions, an exemption allowing th e use of a DJI Phantom 2 or DJI Inspire 1 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air an d on the ground.Furthermore, by reducing the number of manned aircraft operating in the NAS,

congestion around airports caused by arriving and departing aircraft will be reduced. The DJI Phantom 2 and DJI Inspire 1 UAs do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography operations would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations. 2. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 2 and DJI Inspire 1 UASs. Conducting aerial acquisitions with the DJI P hantom 2 and DJI In spire 1 UASs, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric m otors, the DJI Phantom 2 and DJI Inspire 1 UASs produce no air pollution, and is the most viably environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically utilized for aerial video and photography, while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The DJI Phantom 2 and DJI Inspire 1 UAs, while reducing the carbon footprint of aerial operations, al so eliminates noise pollution, as the UAs are propelled by battery powered electric motors, rather than an internal combustion engine. By using the DJI Phantom 2 and DJI Inspire 1 UASs to perform aerial operations, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI Phantom 2 and DJI Inspire 1 UAs (weighing approximately 2 pounds 11 ounces and 6 pounds 7.5 ounces respectively, at theirmaximum gross weights with lengths of 16 inches and 17.3 inches respectively, widths of

16 inches and 17.7 inches respectively, and with no fu el on board), has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximat ely 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons). 17 3. Performing Aerial Video and Photography Operations With The DJI Phantom 2 and DJI Inspire 1 UASs Will Benefit The Economy. In addition to being safe and effi cient, the DJI Phantom 2 and DJI Inspire 1 UASs are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operat ion of the DJI Phantom 2 and DJI Inspire 1 UASs will allow United States based co mpanies, like Interior Pi xels, to remain competitive and contribute to growth of the U.S. econom y. Specifically, with the cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies m ust adopt new and alternative technology in order to remain competitive. Operating the battery powered DJI Phantom 2 and DJI Inspire 1 UASs is one such technology that not only allows greater operational flexibility compared to manned aircraft, but provid es such flexibility without the high operational cost of a traditional manned aircraft. By ope rating the DJI Phantom 2 and DJI Inspire 1 UASs, companies such as Interior Pixels, can remain competitive and profitable, and therefore, provide greater job stab ility to employees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through commercial use of the DJI Phantom 2 and DJI Inspire 1 UASs, provides a stablework force 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
. 4. There Are No Privacy Issues. Similar to the manned a erial acquisition flight operations that have been conducted for decades, Interior Pixel ’s proposed operat ion of the DJI Phantom 2 and 18 DJI Inspire 1 UASs will not implicate any privacy issues. Specifically, the DJI Phantom 2 and DJI Inspire 1 UASs will be operated only in compliance with operating documen ts (i.e., the Interior Pixels Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 and DJI Inspire 1 Instruction Manual) which require property owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119. E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Ru le From Which Interior Pixels Seeks Exemption. 1. Reaso ns Why The DJI Phantom 2 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 i ts operations. Interior Pixel ’s operation of the DJI Phantom 2 and DJI Inspire 1 UASs meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.Section 333 provides authority for a UAS to operate without airworthiness

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

-- Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act. 19 (b) Assessment of Unmanned Aircraft Systems.

-- In making the determination under subsection (a), the Secretary shall determine, at a minimum

-- (1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create
a hazard to users of the national airspace system or the public or pose a threat to national security; and (2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1). (c) Requirements for Safe Operation.

-- If the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airsp ace system, the Secretary shall establish requirements for the safeoperation of such aircraft systems in the national airspace system.

20 In seeking thi s exemption, Interior Pixels submits that the DJI Phantom 2 and DJI Inspire 1 UASs can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characterist ics of the DJI Phantom 2 and DJI Inspire 1 UASs; (b) the pilot certification requirement; and (c) the specific operating limitations. a. The Specificati ons Of The DJI Phantom 2 and DJI Inspire 1 UASs Demonstrate Its Safe Characteristics. The DJI Phantom 2 and DJI Inspire 1 UASs do not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and opera tional capability. i. Technical Specificati ons Of The DJI Phantom 2 and DJI Inspire 1 UASs. The technical specificati ons of the DJI Phantom 2 and DJI Inspire 1 UASs are set fo rth by the DJI Phantom 2 and DJI Inspire 1 Specifications and Data Sheet, attache d hereto as Exhibit A and B. 21 ii. The DJI Phantom 2 and DJI Inspire 1 UASs Autonomous Flight And Navigation Modes Enable The UASs To Remain Within A Defined Operational Area. The DJI Phantom 2 and DJI Inspire 1 UASs may be operated in both manual and fully autonomous flight modes. A complete description of the flight and navigational mo des of the DJI Phantom 2 and DJI Inspire 1 UASs is provided at pages 25
- 35 of the DJI Phantom 2 and pages 12

- 16 and 45

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

iii. The DJI Phantom 2 and DJI Inspire 1 UASs Are Designed For Automatic Return To Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation. When the Control Link is lost, the DJI Phantom 2 and DJI Insp ire 1 UAs will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 2 and DJI Inspire 1 UAs do not reacquire control link data from the GCS, the UAs will assume that the Control Link is lost and the UAs will return to t he home position (i.e., fail safe mode) via GPS, and will descend to the takeoff position and shutdown. A complete description of the Failsafe Functi ons of the DJI Phantom 2 UAS are set forth at pages 27 through 29 and for the DJI Inspire 1 at pages 13 through 15 of the DJI Phantom 2 and DJI Inspire 1 User Manuals, attached hereto as Exhibit C and D. iv. The DJI Phantom 2 and DJI Inspire 1 GCS And Its Operation. A complete description of the operation and specifications of the DJI Phantom 2 and DJI Inspire 1 GCS and flight control software is provided at pages 32 through 43 of the DJI Phantom 2 User Manual and pages 40 through 47 of the DJI Inspire 22 1 Us er Manual. DJI Phantom 2 and DJI Inspire 1 User Manuals are attached hereto as Exhibits C and D. b. Fli ght Ope rations Of DJI Phantom 2 and DJI Inspire 1 UASs Are Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer. Interior Pixels will only utilize certificated pilots who possess a currentand valid airman medical certificate to act as a pilot in command (PIC) of the DJI Phantom

2 and DJI Inspire 1 UASs. Additionally, a safety observer will assist all pilots during flight time.
c. Flights Of DJI Phantom 2 and DJI Inspire 1 UASs Will Be Conducte d Pursuant To Specific Operating Limitations. In seeking th is exemption, Interior Pixels proposes to commercially operate DJI Phantom 2 and DJI Inspire 1 UASs for the special purpose of conducting aerial video and photography over certain areas of United States, pursuant to the following specific operating limitations: 1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gro ss weight: DJI Phantom 2 and DJI Inspire 1 Unmanned Aircraft Systems. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant. 2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photography. 3. The UAs may not be flown at an indicated airspeed exceeding 20 knots. 4. The UA must be operated at an altitude of no more than 500 feet above ground level (AGL), as indicated by the procedures specified in t he operating documents unless a special request is made and approved by ATC. All altitudes reported to ATC must be in feet AGL. 5. The UAs must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate.23

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted. 7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the SO can perform the functions prescribed in the operating documents. 8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is not permitted to operate the camera or other instruments. 9. The operating documents and the grant of exemption must b e accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditio ns and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the ope rator’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. I f the operator determines that any update or revision would affect the basis upon which the FAA grantedthe exemption, then the operator must petition for amendment to its grant of

exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if qu estions arise regarding updates or revisions to the operating documents. 10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records. 11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical compo nent, 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 equip ment, not already covered in the relevant sections of the operating documents. 24 13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. 14. The operator must car ry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircraft records, including tota l time in service, description of work accomplished, and the signature of the authorized person returning theUAS to service.

15. Each UASs operated under this exemption must comply with all manufacturer Safety Bulletins. 16. The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections. 17. The PIC must possess at least a private pilot certificate and at least a current third

- class medical certificate. 18. The operator m ay not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator’s PICs are pe rmitted 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 n onparticipants, 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 unde r 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 opera te 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 visib ility 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. 2 3. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents. 24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 25% battery power remaining. 25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Author ization (COA) prior to conducting any operations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operation s shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace,altitude level and potential transponder requirements.

26. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (N

- Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable. 27. Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PI C 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 aviati on operations and activities at all times. 30. The UAS may not be operated by the PIC from any moving device or vehicle. 31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than the PIC, SO, operator t rainees or essential persons), vessels, vehicles, and structures unless: 26 a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must ceaseimmediately and/or;

b. The aircraft is opera ted 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 pre sent 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 pe rmission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted. 33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instru ctions contained on the NTSB Web site: www.ntsb.gov. 2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety. Interior Pixels submits that the equivalent level of safety established by Sect ion 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI Phantom 2 and DJI Inspire 1 UASs unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely
o perate the DJI Phantom 2 or DJI Inspire 1 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriatedistances from people, vessels, vehicles and structures.

Considering Interior Pixel ’s proposed area of operations, and the operating limitations set forth

- above; the parallel nature of private pilot aeronautical 27 knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely o perate the DJI Phantom 2 or DJI I nspire 1 UAS, Interior Pixels submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for Interior Pixel ’s specific proposed flight ope rations. 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). Interior Pixels will not allow any PIC to operate the DJI Phantom 2 or DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight

- hour requireme nts or the DJI Phantom 2 or DJI Inspire 1 UAS training and currency requirements, that the PIC is able to safely o perate the DJI Phantom 2 or DJI Inspire 1 UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate di stances from people, vessels, vehicles and structures. Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In addition to the hour requirements,the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency

purposes). 28 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 Interior Pixel ’s proposed operations. The Administrator has held that prior docume nted flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows: In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi

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

- rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight

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

- building flights can also be conducted under the grant of exemption

to accomplish the required flight time. During training, proficiency, and experience
- building flights the PIC is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119. Exempt ion No. 11138 at page 15. Accordingly, Interior Pixels will ensure safe operations by not allowing any PIC to o perate the DJI Phantom 2 or DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely o perate the DJI Phantom 2 or DJI Inspire 1 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 29 3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety. The equivalent level of safety established by Section 91.7(a) will be maintained becau se prior to every flight, Interior Pixels wil l ensure that the DJI Phantom 2 or DJI Inspire 1 UAS is in an airworthy condition based upon the UAS’s compliance with its operating documents and as stated in the conditions and limitations herein. Additionally, the FAA has previously granted relief from Section 91.7(a) spec ific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety.The equivalent level of safety established by Section 91.121 will be maintained

because the altitude informat ion of the DJI Phantom 2 and DJI Insp ire 1 UAs will be provided to the PIC via GPS equipment and a radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path and altitude. This altitude information, combined with Interior Pixels’s operation of the DJI Phantom 2 and DJI Inspire 1 UAs within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically established by the UASs at ground level. The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption 30 Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 5. Reasons Why An Exemptio n From The Requirements Of Section 91.151(b) Would Not Adversely Affect Safety. A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJI Phant om 2 and DJI Inspire 1 UASs; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, Interior Pixels will ensure that it will safely operate the battery powered DJI Phantom 2 and DJI Inspire 1 UAs during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 2

and DJI Inspire 1 UASs; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safety established by 1 4 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Phantom 2 and DJI Inspire 1 UASs provide audible and visual warnings to the PIC at the GCS when the UAs experiences low battery voltage, the first warning occurring at approximatel y 33% remaining battery power, and again at approximately 10% remaining battery power. At the critically low battery level, the DJI Phantom and DJI Inspire 1 UASs will descend and land automatically. Significantly, previous exemptions granted by the FAA co ncerning 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 31 aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 6. Reasons Why An Exemption From The Requ irements 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 th is exemption, Interior Pixels 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 b e met because Interior Pixels will use trained technicians to perform

maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the opera ting documents (i.e., the Interior Pixels Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 and DJI Inspire 1 Instruction Manual). Furthermore, Interior Pixels will do cument and maintain all maintenance records for the DJI Phantom 2 and DJI Inspire 1 UASs. Since the DJI Phantom 2 and DJI Inspire 1 UASs will be inspected as prescribed by the operati ng documents, Interior Pixels will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A c opy of the DJI Phantom 2 and DJI Inspire 1 User Manuals are attached hereto as Exhibit C and D; a copy of the DJI Phantom 2 and DJI Inspire 1 UAS Maintenance LOG is attached hereto as Exhibit E. 32 Likewise, the exemption sought will not advers ely affect safety because Interior Pixels will use trained technicians to perform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescri bed by the operating documents. Furthermore, the exemption sought would maintain an equivalent level of safety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI Phantom 2 and DJI Inspire 1 UASs 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 theUAS are considered.

In con sideration of Interior Pixel ’s proposed operating limitations, the operating documents, and the technical aspe cts of the DJI Phantom 2 and DJI In spire 1 UASs, Interior Pixels submits that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417( a) and (b). The FAA has previously granted relief specific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 7. The FAA May Prescribe Any Other Conditions For Safe Operation. In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Specia l Condi tions, Interior Pixels 33 requests that the FAA prescribe special conditions for the intended operation of the DJI Phantom 2 and DJI Inspire 1 UASs, which contain such safety standards that the Administrator finds necessary to establish a level of safety e quivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAs for the limited purpose of conducting aerial video and photography over certain areas of the United States for compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification in accordance with any requirements that must be established for the safe operation of the UAS in the NAS.Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R.

§ 21.16, for operati on of the DJI Phantom 2 and DJI Inspire 1 UASs, since the airworthiness regulations of 14 C.F. R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special Conditions, states the following: If the FAA finds that the airworthiness regulations of this s ubchapter 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 the reto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent to that established in the regulations. See 14 C.F.R. § 21.16. 35 Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe spe cial conditions for Interior Pixel ’s intended operation of the DJI Phantom 2 and DJI Inspire 1 UASs, w hich contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a) (1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). F. A Summary That Can Be Published In The Federal Register, stating: The Rules Fro m Which Interior Pixels Seeks Exemption: Interior Pixels 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 Th e Nature Of The Exemption Interior Pixels Seeks: This exemptio n will permit Interior Pixels to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States. G. Any Additional Information, Views, Or Arguments Available To Support Interior Pixel ’s Request. This Petition is made pursuant to th e FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. As such, Interior Pixel ’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. 36 As discussed in detail above, Interior Pixels will operate the DJI Phantom 2 and DJI Inspire 1 UASs 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, Interior Pixels 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 op erat ion of the DJI Phantom 2 and DJI Inspire 1UASs 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 Interior Pixels to safely, efficiently, and economically
o perate the DJI Phantom 2 and DJI Inspire 1 UASs commercially within the NAS. WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, Interior Pixels respectfully requests that the Administrator grant this Petit ion 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 Interior Pixels to operate the DJI Phantom 2 and DJI Inspire 1 UASs commercially for the purpose of conducting aerial video and photography over certain areas of the United States. Dated: May 26, 2015
Respectfully submitted, Interior Pixels, Inc. /s/ Brendan Carlisle

_________________________ Brend an Carlisle 5640 Via Bonita Newbury Park, CA 91320 Tel: (818) 427

-9863 Appendices: A – DJI Phantom 2 Specifications Data SheetB – DJI Inspire 1 Specifications Data Sheet

C – DJI Phantom 2 Manufacturer’s User Manual D – DJI Inspire 1 Manufacturer’s User Ma nual E – Monthly Maintenance Log 37 APPENDIX – A DJI PHANTOM 2 TECHNICAL SPECIFICATIONS Interior Pixels only utilizes safe and reliable UASs. DJI is an industry leader in small U AS production. DJI UASs are equipp ed with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as to limit flight to a predetermined and set distance. In addition, DJI software provides real

-time altitude and location information to the PIC via the linked monitor (smart phone/tablet devices) 1.1 DJI Phantom 2 1.1.1 Aircraft 1.1.1.1 Supported Battery
– DJI 5200mAH LiPo Battery 1.1.1.2 Weight (Battery & Propellers Included )
– 2lbs 11.810oz (1242g) 1.1.1.3 Hover Accuracy (Ready to Fly)
– Vertical: .8m; Horizontal: 2.5m 1.1.1.4 Max Yaw Angular Velocity

- 200 0/s 1.1.1.5 Max Tilt Angel

- 35 0 1.1.1.6 Max Ascent Speed
– 6m/s 1.1.1.7 Max Descent Speed
– 2m/s 1.1.1.8 Max Flight Spe ed
– 15m/s (NOT RECOMMENDED) 1.1.2 Gimbal1.1.2.1 Working Current
– Static: 750mA; Dynamic: 900mA

1.1.2.2 Control Accuracy

- ±0.03 0 1.1.2.3 Controllable Range
– Pitch:

-90 0

- 0 0 1.1.2.4 Maximum Angular Speed
– Pitch: 90 0/s 1.1.4 Transmitter 1.1.4.1 Operati ng 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 38 1.1.5.1 Operating Frequency
– 2412
- 2462MHz 1.1.5.2 Communication Distance (unobstructed)
– 500
- 700m 1.1.5.3 Transmitter Power
– 20dBm 1.1.5.4 Power Consumption
– 2W 39 APPENDIX – B DJI INSPIRE 1 TECHNICAL SPECIFICATIONS Interior Pixels only utilizes safe and reliable UASs. DJI is an industry leader in small U AS production. DJI UASs are equipp ed with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be s et to limit flight to no higher than a predetermined and set altitude as well as to limit flight to a predetermined and set distance. In addition, DJI software provides real

-time altitude and location information to the PIC via the linked monitor (smart ph one/tabletdevices)

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: 1 500/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 Fligh t 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
– 140F to 1040F (

- 100C 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
– Detachable2.2.2.6 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: 120 0/s; Pan: 1800/s 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 (unobstru cted)
– 2000m 2.2.4.4 Output Power
– 9W 2.2.4.5 Operating Temperature Range
- 140F to 1040F (

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

APPENDIX – C (See attachment) DJI Phantom 2 Vision+ Manufacturer’s User Manual 42 APPENDIX – D (See attachment) DJI Inspire 1 Manufacturer’s User Manual 43 APPENDIX – E month:_________(year:________ UAS$#:$___________ Date(Issue( Discovered Date(Issue( Addressed Software(Updates Airframe(Engines

Propellers Camera(Gimbal Landing(Gear Vibration(Dampening Other: MONTHLY$MAINTENANCE$LOG Issue(Description(&(Maintenance(Conducted Maintenance(Performed(By:((( Print(&(Sign