UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

ABS AERIAL IMAGING SERVICE FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMEN TS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(a ), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNI NG COMMERCIAL OPERATION OF THE DJI INSPIRE 1 UNMANNED AIRCRAFT SY STEMS

PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Submitted on June 18, 2015 ABS Aerial Imaging Service Peter Scott Myers (Owner) 4322 Long Lane Franklin, TN 37064 (615) 504-7676 Cell/Office scottm@abssite.com2 TABLE OF CONTENTS Page

GLOSSARY OF ABBREVIATIONS..........................

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SUMMARY............................................

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INTRODUCTION AND INTERESTS OF PETITIONER........... .........................................4

BACKGROUND.........................................

................................................... ........................5

BASIS FOR PETITION.................................

................................................... .....................5

NAME AND ADDRESS OF PETITIONER.....................

................................................... .8

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH ABS A ERIAL IMAGING SERVICE SEEKS EMPTION..............................

................................................... ..............8

THE EXTENT OF RELIEF ABS AERIAL IMAGING SERVICE SEE KS AND THE REASON ABS AERIAL IMAGING SERVICE SEEKS THE RELIEF... .......................12

THE REASONS WHY GRANTING ABS AERIAL IMAGING SERVICE ’S REQUEST WOULD BE IN THE PUBLIC INTEREST ....................... ..............................................15

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT AD VERSELY AFFECT SAFETY......................................

................................................... ......................18

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGIST ER..................32 ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVA ILABLE TO SUPPORT ABS AERIAL IMAGING SERVICE’S REQUEST .................. ............33

CONCLUSION.........................................

................................................... ........................33

APPENDICES............................................................... .........................353 GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level AOI Area of Interest ATC Air Traffic Control ATO Air Traffic Organization AV Aerial Vehicle CFR Code of Federal Regulations COA Certificate of Authorization FAA Federal Aviation Administration FAR Federal Aviation Regulation GCS Ground Control Station GPS Global Positioning System LOL Loss of Link NAS National Airspace System NOTAM Notice to Airman PIC Pilot In Command Section 333 FAA Modernization and Reform Act of 2 012 (FMRA) Section 333 SO Safety Observer SOP Standard Operating Procedures UA Unmanned Aircraft UAS Unmanned Aircraft System VFR Visual Flight Rules VLOS Visual Line of Site VMC Visual Meteorological Conditions VTOL Vertical Takeoff and Landing4 SUMMARY ABS Aerial Imaging Service seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91. 405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section

333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit ABS Aerial Imaging Service to operate an Unm anned Aircraft System (UAS) for the commercial purpose of conducting aerial video a nd photography within the National Airspace System (NAS).

INTRODUCTION AND INTERESTS OF THE PETITIONER Peter Scott Myers, owner of ABS Aerial Imaging Ser vice, is a private pilot with a glider rating - certificate number 3147544, with ov er 700 hours of flight experience and 470 flights. He has over 10 years recreational/hob by experience with radio controlled model airplanes and video/photography. The objectiv e of ABS Aerial Imaging Service is to provide high quality imaging for a variety of co mmercial, public, and residential uses, specifically targeting, but not limited to:

• Construction sites before and after

• Appraisals

• Real-estate marketing

• Weddings and Special Events

• Aerial acquisitions used for inspections of public and private structures.

• Search and Rescue operations

• Marine/Maritime inspections and photography

BACKGROUND5 Unmanned Aircraft System: DJI Inspire 1 ABS Aerial Imaging Service seeks an exemption to op erate DJI Inspire 1 system for compensation or hire within the NAS. The DJI In spire 1 is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing integrated touchscreen control, electronic tablet o r smart phone systems. This aircraft has four rotors and four motors in a quadcopter configu ration (X4). It is only capable of vertical takeoff and landing. This UAS weighs less than 55 lbs. including payload. Can fly, under normal conditions at a speed of no more than 42.8 knots and has the capability to hover, and move in the vertical and horizontal plan e simultaneously. This UAS is equipped with GPS and auto-return function to the predetermi ned safe landing area as well as allowing reading of magnetic interference that can cause loss of GPS signal. The UAS will operate only in visual line of sight and will opera te only within a sterile closed-set area of a residential or commercial listing, open desolate ar eas near rural farms or a closed-set special event. Such operations will insure that the UAS will “not create a hazard to users of the national airspace system or the public.” (Refor m Act Section 333 (b)). The DJI Inspire 1 will be operated by ABS Aerial Im aging Service and 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, ABS Aerial Imaging Service, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FA A Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereby6

petitions the Administrator to commercially operate the DJI Inspire 1 in the National Airspace System (NAS), and for an exemption from th e 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 li mited operating area associated with the unmanned aircraft and its operation, ABS A erial Imaging Service’s operation of DJI Inspire 1 meets the conditions of FMRA Section 333 and therefore, will not require an

airworthiness certificate in accordance with 14 C.F .R. Part 21, Subpart H. Accordingly, ABS Aerial Imaging Service requests re lief 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 air craft with an airworthiness certificate. ABS Aerial Imaging Service submits that the request ed relief is proper since an equivalent level of safety will be ensured. ABS Aer ial Imaging Service will perform maintenance, alterations, and/or preventive mainten ance on the DJI Inspire 1 using the methods, techniques, and practices prescribed in th e operating documents (i.e., Aircraft Maintenance Log and DJI Inspire 1 Instruction Manua ls). Furthermore, ABS Aerial Imaging Service will document and maintain all main tenance records for the DJI Inspire 1. Relief from certain requirements of Section 61.113( a) and (b), entitled Private pilot privileges and limitations: Pilot in command , is requested by ABS Aerial Imaging Service to the extent necessary to allow the proposed UAS f light operations to be conducted by a Pilot in Command (PIC) holding a private pilot or h igher level certificate, and who has demonstrated, by meeting minimum flight - hour and currency requirements, that the PIC is able to safely operate the DJI Inspire 1 in a ma nner consistent with this exemption,7

including evasive and emergency maneuvers and maint aining appropriate distances from people, vessels, vehicles and structures. ABS Aerial Imaging Service seeks relief from Sectio n 91.7(a), entitled Civil aircraft airworthiness , because the DJI Inspire 1 does not require an air worthiness certificate in accordance with 14 C.F.R. Part 21, S ubpart H. As such, ABS Aerial Imaging

Service submits that we will ensure that the DJI In spire 1 is in an airworthy condition, prior to every flight, by determining that it is in compliance with the operating documents (i.e., Aircraft Maintenance Log and DJI Inspire 1 I nstruction Manuals), and that the aircraft is in a condition for safe flight. ABS Aerial Imaging Service also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , as the DJI Inspire 1 will not have a typical barometric altimeter onboard. However, altitude inf ormation of the DJI Inspire 1 will be provided to the PIC via Global Positioning System ( GPS) equipment and radio communications telemetry data link, which downlinks from the DJI Inspire 1 to the GCS for active monitoring of the flight path. The maxi mum altitude of the DJI Inspire 1 is factory limited to 400 feet AGL by onboard software . This altitude information, combined with ABS Aerial Imaging Service’s operation of the DJI Inspire 1 will be within visual line of sight, at or below 400 feet AGL, will ensure a l evel of safety equivalent to Section

91.121. Additionally, ABS Aerial Imaging Service seeks an e xemption from the requirements of Section 91.151(a), entitled Fuel requirements for flight in VFR conditions

. ABS Aerial Imaging Service submits that safety will not be affected by operation of the DJI Inspire 1 during daylight hours in visual meteo rological conditions (VMC) under8

visual flight rules (VFR), with enough battery powe r to fly for a total duration of 13 minutes to the first point of intended landing and, assuming a normal cruising speed, to fly after that for at least 5 minutes (i.e. 20 percent battery power remaining). In accordance with 14 C.F.R. § 11.81, ABS Aerial Im aging Service provides the following information in support of its petition fo r exemption:

A. Name And Address Of The Petitioner. The name and address of the Petitioner and point of contact is: Peter Scott Myers, Owner ABS Aerial Imaging Service 4322 Long Lane Franklin, TN 37064 (615) 504-7676 Cell/Office Email:scottm@abssite.com B. The Specific Sections Of 14 C.F.R. From Which AB S Aerial Imaging Service Seeks Exemption. 1. ABS Aerial Imaging Service Seeks Exemption From The Requirements Of Section 61.113(a) And (b). Section 61.113, entitled Private pilot privileges a nd limitations: Pilot in command , subsections (a) and (b) prescribe the following, in relevant part: (a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire , act as PIC of an aircraft. (b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if— (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or prope rty for compensation or hire.

2. ABS Aerial Imaging Service 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 civil aircraft unless i t is in an airworthy condition.

3. ABS Aerial Imaging Service Seeks Exemption From The Requirements Of Section 91.121. Section 91.121, entitled Altimeter settings, subsec tion (a), states the following, in

part: (a) Each person operating an aircraft shall maintai n the cruising altitude or flight level of that aircraft, as the case may be, by refe rence to an altimeter that is set, when operating-- (1) Below 18,000 feet MSL, to-- (i) The current reported altimeter setting of a sta tion along the route and within 100 nautical miles of the aircraft; (ii) If there is no station within the area prescri bed in paragraph (a)(1)(i) of this section, the current reported altimeter settin g of an appropriate available station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setti ng available before departure.

4. ABS Aerial Imaging Service 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 un der VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assumin g normal cruising speed, to fly after that for at least 20 minutes.

5. ABS Aerial Imaging Service Seeks Exemption From The Requirement Of Section 91.405(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 prescribe d in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.] 6. ABS Aerial Imaging Service 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 und ergone maintenance, preventive maintenance, rebuilding, or alteration unless-- (1) It has been approved for return to service by a person authorized under § 43.7 of this chapter[.] 7. ABS Aerial Imaging Service 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 sec tion, no person may operate an aircraft unless, within the preceding 12 calendar m onths, 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 airworthin ess certificate in accordance with part 21 of this chapter. 8. ABS Aerial Imaging Service 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 followi ng records for the periods specified in paragraph (b) of this section:11 (1) Records of the maintenance, preventive maintena nce, and alteration and records of the 100-hour, annual, progressive, and o ther required or approved inspections, as appropriate, for each aircraft (inc luding the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include-- (i) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of completion of the work performed; and (iii) The signature, and certificate number of the person approving the aircraft for return to service. (2) Records containing the following information: (i) The total time in service of the airframe, each engine, each propeller, and each rotor. (ii) The current status of life-limited parts of ea ch airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul of all items ins talled on the aircraft which are required to be overhauled on a specified time b asis. (iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compl iance, the AD or safety directive number and revision date. If the AD or sa fety directive involves recurring action, the time and date when t he next action is required. (vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe and currently inst alled engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the followin g records for the periods prescribed: (1) The records specified in paragraph (a)(1) of th is section shall be retained until the work is repeated or superseded by other w ork or for 1 year after the work is performed.12 (2) The records specified in paragraph (a)(2) of th is section shall be retained and transferred with the aircraft at the time the a ircraft is sold. (3) A list of defects furnished to a registered own er or operator under § 43.11 of this chapter shall be retained until the defects ar e repaired and the aircraft is approved for return to service. C. The Extent Of Relief ABS Aerial Imaging Service Seeks And The Reason ABS Aerial Imaging Service Seeks The Relief. 1. Extent Of Relief ABS Aerial Imaging Service Seeks And The Reason ABS Aerial Imaging Service 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 P IC holding a private pilot or higher level certificate, as well as a current and valid drivers license, and who has met certain flight-hour and currency requir ements, to conduct the proposed UAS flight operations for compensation or hire. This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does n ot carry passengers or property for compensation or hire. As set forth more fully below, ABS Aerial Imaging S ervice submits that an equivalent level of safety will be maintained becau se no PIC will be allowed to operate the DJI Inspire 1 unless that PIC has met certain fligh t-hour and currency requirements, demonstrating that the PIC is able to safely operat e DJI Inspire 1 in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropr iate distances from people, vessels,

vehicles and structures.13 2. Extent Of Relief ABS Aerial Imaging Service Seeks And The Reason ABS Aerial Imaging Service Welsh Seeks Relief From Section 91.7(a). Relief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to the extent required to allow ABS Aerial Imaging Service to determine that the DJI Inspire 1 is in airworthy condition prior to every flight by ens uring that the DJI Inspire 1 is in compliance with the operating documents (i.e., Airc raft Maintenance Log and DJI Inspire 1 Instruction Manual). ABS Aerial Imaging Service seeks the requested reli ef because the DJI Inspire 1 does not require an airworthiness certificate in ac cordance with 14 C.F.R. Part 21, Subpart H. Therefore, ABS Aerial Imaging Service will ensur e that the DJI Inspire 1 is in airworthy condition based upon its compliance with the operating documents (i.e., Aircraft Maintenance Log and DJI Inspire 1 Instruction Manua l) prior to every flight, and further,

determine that the aircraft are in condition for sa fe flight, as stated in the conditions and

limitations below. 3. Extent Of Relief ABS Aerial Imaging Service Seeks And The Reason ABS Aerial Imaging Service Seeks Relief From Section 91.121. Relief from Section 91.121, entitled Altimeter sett ings, may be required to allow flight operations of the DJI Inspire 1, which utili ze a barometric pressure sensor, GPS equipment, and a radio communications telemetry dat a link to downlink altitude information from the UA to the PIC at the ground co ntrol station (GCS). Since the FAA requires that any altitude information concerning U AS operations be reported to air traffic control (ATC) in feet above ground level (AGL), ABS Aerial Imaging Service seeks the requested relief because the DJI Inspire 1 altimete r may be set on the ground to zero feet AGL, rather than the local barometric pressure or f ield altitude, before each flight.14 Considering the limited altitude of the proposed op erations, relief from 14 CFR 91.121 is sought to the extent necessary to comply with the applicable conditions and limitations stated below. As more fully set forth h erein, an equivalent level of safety will be maintained since the DJI Inspire 1 is equipped w ith a barometric pressure sensor and GPS equipment, which automatically ensures that a g round level pressure setting will be established prior to each flight, and provides the PIC with altitude information of the UA on the touchscreen of the GCS or is limited by onbo ard software. 4. Extent Of Relief ABS Aerial Imaging Service Seeks And The Reason ABS Aerial Imaging Service Seeks Relief From Section 91.151(b). Relief from Section 91.151(b) entitled Fuel require ments for flight in VFR conditions, is requested to the extent required to allow flights of the battery powered DJI Inspire 1 during daylight hours in visual meteorolo gical conditions (VMC), under visual flight rules (VFR), for a total duration of 13 minu tes to the first point of intended landing and, assuming normal cruising speed, to fly after t hat for at least 5 minutes. ABS Aerial Imaging Service seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered DJI Inspire 1 will severely constrain the practicality of any aerial video or s till photo flight operations ABS Aerial Imaging Service proposes to conduct pursuant to thi s Petition. Significantly, as set forth below, the technical sp ecifications of the DJI Inspire 1 operating documents, and ABS Aerial Imaging Service ’s proposed operating limitations, ensure that ABS Aerial Imaging Service will safely operate the battery powered DJI Inspire 1 during daylight hours in visual meteorolo gical conditions (VMC), under visual flight rules (VFR), with enough battery power to fl y for a total duration of 13 minutes to15

the first point of intended landing and, assuming n ormal cruising speed, to fly after that for

at least 5 minutes. 5. Extent Of Relief ABS Aerial Imaging Service Seeks And The Reason ABS Aerial Imaging Service Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b). Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1 ) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certif icate, ABS Aerial Imaging Service requests relief from these Sections because the DJI Inspire 1 does not require a airworthiness certificate. As set forth more fully below, the DJI Inspire 1 meets the conditions of FMRA Section 333 for operation withou t an airworthiness certificate. Accordingly, Peter Scott Myers, owner of ABS Aerial Imaging Service, will use his experience working on operating model aircraft to p erform maintenance, alterations, or preventive maintenance on the DJI Inspire 1 using t he methods, techniques, and practices prescribed in the operating documents (i.e Aircraft Maintenance Log and DJI Inspire 1 Instruction Manuals). Furthermore, ABS Aerial Imagi ng Service will document and maintain all maintenance records for the DJI Inspir e 1. D. The Reasons Why Granting ABS Aerial Imaging Serv ice Request Would Be In The Public Interest; That Is, How It Would Benefit The Public As A Whole. Granting the present Petition will further the publ ic interest by allowing ABS Aerial Imaging Service to safely, efficiently, and economically perform aerial video and photography within the National Airspace System. Additionally, use of DJI Inspire 1 will decrease co ngestion of the NAS, reduce pollution through use of electric propulsion, and p rovide significant benefits to the economy. Notably, the benefits of ABS Aerial Imagin g Service’s proposed operation of the DJI Inspire 1 will be realized without implicat ing any privacy issues.16 1. The Public Will Benefit From Decreased Congestio n Of The NAS. The DJI Inspire 1 is battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally ut ilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to pe rform aerial acquisitions, an exemption allowing the use of the DJI Inspire 1 wou ld reduce the amount of manned aircraft in the NAS, reduce noise and air pollution , as well as increase the safety of life and property in the air and on the ground. Furthermore, by reducing the number of manned aircr aft operating in the NAS, congestion around airports caused by arriving and d eparting aircraft will be reduced. The DJI Inspire 1 does not require an airport to takeof f or land. Likewise, a reduction of manned aircraft conducting aerial video and photogr aphy missions would result in fewer aircraft that must be handled by air traffic contro l during the ground, takeoff, departure, arrival, and landing phases of flight operations. 2. The Public Will Benefit From The Safety And Effi ciency Of The DJI Inspire 1. Conducting aerial acquisitions with the DJI Inspire 1 instead of manned aircraft, will greatly benefit the public by drastically redu cing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, the DJI Inspire 1 produces no air pollution, and is the most viable environmentally conscious alternative t o the cabin class, six cylinder internal combustion engine aircraft that are typically utili zed for aerial video and photography, while burning approximately 20-30 gallons per hour of leaded aviation fuel. The DJI Inspire 1 while reducing the carbon footprint of ae rial acquisitions, also eliminates noise17

pollution, as the UAs are propelled by battery powe red electric motors, rather than an internal combustion engine. By using the DJI Inspire 1 to perform aerial video and photo acquisitions, the substantial risk to life and property in the air an d 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 fl ight crew members located onboard the aircraft, the DJI Inspire 1 (weighing approximately 6.25lbs at maximum gross weight, with length of 29 inches and width of 29 inches, and wit h no fuel on board), has less physical potential for collateral damage to life and propert y on the ground, and in the air, compared to the manned aircraft that typically conduct simil ar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 fe et, a length of 34 feet, and a fuel capacity of 180 gallons). 3. Performing Aerial Video and Photography Operatio ns With The DJI Inspire 1 Will Benefit The Economy. In addition to being safe and efficient, the DJI In spire 1 is also an economical alternative to using manned aircraft to conduct sim ilar aerial operations. As such, operation of the DJI Inspire 1 will allow United States based companies or individuals, like ABS Aerial Imaging Service, to remain competitive and c ontribute to growth of the U.S. economy. Specifically, with the rising cost of avia tion fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasin g out leaded aviation fuels, U.S. owned and operated companies must adopt new and alt ernative technology in order to remain competitive. Operating the battery powered D JI Inspire 1 is one such technology that not only allows companies or individuals great er operational flexibility compared to18

manned aircraft, but provides such flexibility with out the high operational cost of a

traditional manned aircraft. By operating the DJI Inspire 1, companies such as ABS Aerial Imaging Service can remain competitive and profitable, and therefore, p rovide greater job stability to employees and contractors, which will ultimately contribute t o growth of the U.S. economy. Improved financial performance of U.S. companies, through co mmercial use of the DJI Inspire 1, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to inves t in research and development in order to remain competitive both in the United States and abroad. 4. There Are No Privacy Issues. Similar to the manned aerial acquisition flight ope rations that have been conducted for decades, ABS Aerial Imaging Service’s proposed oper ation of the DJI Inspire 1 will not implicate any privacy issues. Specifically, the DJI Inspire 1 will be operated only in compliance with operating documents including the D JI Inspire 1 Instruction Manual, Limitations imposed by the Grant of Exemption and i n accordance with the Federal Aviation Regulations, including the minimum altitud e requirements of 14 C.F.R. § 91.119 (sections as applicable). E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safet y At Least Equal To That Provided By The Rule From Which ABS Aerial Imaging Service Seeks Exemption. 1. Reasons Why The DJI Inspire 1 Meets The Conditio ns Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333. In consideration of the size, weight, speed, and li mited operating area associated with the unmanned aircraft and its operation, ABS A erial Imaging Service’s operation of19

the DJI Inspire 1 meets the conditions of FMRA Sect ion 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 consi dering whether a UAS will create a hazard to users of the NAS or the public, or otherw ise pose a threat to national security. Specifically, FMRA Section 333 states the following , in part: (a) In General.--Notwithstanding any other requirem ent 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 befo re completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act. (b) Assessment of Unmanned Aircraft Systems.--In ma king the determination under subsection (a), the Secretary shall determine, at a minimum-- (1) which types of unmanned aircraft systems, if an y, as a result of their size, weight, speed, operational capability, proxim ity to airports and populated areas, and operation within visual line o f sight do not create a hazard to users of the national airspace system o r 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 air craft systems identified under paragraph (1). (c) Requirements for Safe Operation.--If the Secret ary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall estab lish requirements for the safe operation of such aircraft systems in the national airspace system. In seeking this exemption, ABS Aerial Imaging Servi ce submits that DJI Inspire 1 can operate safely in the NAS pursuant to FMRA Sect ion 333, as demonstrated by: (a) the characteristics of the DJI Inspire 1 (b) the pilot certification requirement by the owner, Peter Scott Myers; and (c) the specific operating l imitations.20 a. The Specifications Of The DJI Inspire 1 Demonstr ate Its Safe Characteristics. The DJI Inspire 1 does not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security consid ering its size, weight, speed, and operational capability.

i. Technical Specifications DJI Inspire 1. The technical specifications of the DJI Inspire 1 i s set forth by the DJI Inspire 1 Specifications and Data Sheet, attached hereto as A ppendix A.

ii. The DJI Inspire 1 Autonomous Flight And Navigat ion Modes Enable The UASs To Remain Within A Defined Operational Are a. The DJI Inspire 1 may be operated in both manual an d autonomous flight modes. A complete description of the flight and navigational modes of the DJI is provided in the instruction manual – Appendix B

iii. The DJI Inspire 1 is Designed For Automatic Re turn To Home Point Or Hover In The Event Of Loss Of The Control Link O r Navigation. When the Control Link is lost, the DJI Inspire 1 wi ll remain stable in flight and initiate a controlled return flight to the point of original departure. This is known as the “Return to Home” feature. Upon arrival at the “Hom e Point” the UA(s) will begin a controlled descent and landing. Additional protect ions are integrated into this safety feature to help mitigate any potential contingencie s that may happen during this automated flight. Furthermore, the “Return to Home” safety f eature may be activated at any time the

PIC becomes disoriented or loses visual contact wit h the UA. This serves as an additional feature to assure safe and controlled operation of the UA at all times. A complete description of the “Return to Home” Function of the DJI Inspire 1 is in the instruction manual, Appendix B.21 iv. The DJI Inspire 1 GCSs and its operation. A complete description of the operation and specifi cations of the DJI Inspire 1 contained in the Instruction Manual, attached heret o as Appendix B. The DJI Inspire 1 is compliant with all Federal Communications Commissio n (FCC) requirements, and the radio frequency spectrum used for operation and con trol of the DJI Inspire 1 is in the Instruction manual, attached hereto as Appendix B.

b. Flight Operations Of DJI Inspire 1 Is Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observe r. ABS Aerial Imaging Service will only utilize certif icated pilots, who possess a current and valid driver’s license, to act as a pil ot in command (PIC) of the DJI Inspire 1. Additionally, a Safety Observer will assist the PIC during flight time.

c. Flights Of The DJI Inspire 1 Will Be Conducted P ursuant To Specific Operating Limitations. In seeking this exemption, ABS Aerial Imaging Servi ce proposes to commercially operate the DJI Inspire 1 for the special purpose o f conducting aerial video and photography within the National Airspace System, pu rsuant 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, roto rcraft UASs weighing less than 55 pounds maximum gross weight: 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 limi ted to conducting operations for the purpose of aerial video and photography. 3. The UAs may not be flown at an indicated grounds peed exceeding 20 knots. 4. The UA must be operated at an altitude of no mor e than 400 feet above ground level (AGL), as indicated by the procedures specifi ed in the operating documents unless a special request is made and appr oved by ATC. All altitudes reported to ATC must be in feet AGL.22 5. The UAs must be operated within visual line of s ight (VLOS) of the PIC at all times. This requires the PIC to be able to use huma n vision unaided by any device other than corrective lenses. 6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted for navigation. 7. All operations must utilize a safety observer (S O). The SO may be used to satisfy the VLOS requirement as long as the PIC always main tains 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 hi s or her designation for the duration of the flight. The PIC must ensure that th e 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 bas ed obstacles/obstructions and is not permitted to operate the camera or other ins truments. 9. The operating documents and the grant of exempti on must be accessible during UAS operations and made available to the Administra tor upon request. If a discrepancy exists between the conditions and limit ations contained in the grant of exemption and the procedures outlined in the ope rating documents, the conditions and limitations contained in the grant o f exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator m ay update or revise its operating documents. It is the operator’s responsib ility to track such revisions and present updated and revised documents to the Ad ministrator 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 granted the exemption, then the operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS-80 ) may be contacted if questions arise regarding updates or revisions to t he operating documents. 10. Prior to each flight the PIC must inspect the U AS to ensure that it is in a condition for safe flight. If the inspection reveal s a condition that affects the safe operation of the UAS, the aircraft is prohibit ed from operating until the necessary maintenance has been performed and the UA S is found to be in a condition for safe flight. The Ground Control Stati on must be included in the preflight inspection. All maintenance and alteratio ns must be properly documented in the aircraft records. 11. Any UAS that has undergone maintenance or alter ations that affect the UAS operation or flight characteristics, e.g. replaceme nt of a flight critical component, must undergo a functional test flight. T he PIC who conducts the functional test flight must make an entry in the ai rcraft records.23 12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not alr eady covered in the relevant sections of the operating documents. 13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. 14. The operator must carry out its maintenance, in spections, and record keeping requirements, in accordance with the operating docu ments. Maintenance, inspection, alterations, and status of replacement/ overhaul component parts must be noted in the aircraft records, including to tal time in service, description of work accomplished, and the signature of the auth orized person returning the UAS to service. 15. Each UASs operated under this exemption must co mply with all manufacturer Safety Bulletins. 16. The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies disco vered between inspections. 17. The PIC must possess at least a private pilot c ertificate and at least a current driver’s license. 18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS wil l be operated under the exemption, including evasive and emergency maneuver s and maintaining appropriate distances from persons, vessels, vehicl es and structures. PIC qualification flight hours must be logged in a mann er consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training th e operator’s PICs are permitted under the terms of the exemption. However , training operations may only be conducted during dedicated training session s. During training, proficiency, and experience-building flights, all p ersons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in a ccordance with 14 C.F.R. § 91.119. 19. UAS operations may not be conducted during nigh t, 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 re quest will be made at the FAA office closest to proposed area of operations. Flig hts 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 cha rt unless a letter of agreement with that airport’s management is obtaine d, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA.24 The letter of agreement with the airport management must be made available to the Administrator upon request. 21. The UA may not be operated less than 500 feet b elow or less than 2,000 feet horizontally from a cloud or when visibility is les s 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 ar ea and land or be recovered in accordance with the operating documents. 23. The PIC must abort the flight in the event of u npredicted obstacles or emergencies in accordance with the operating docume nts. 24. The PIC is prohibited from beginning a flight u nless (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 Organiz ation (ATO) issued Certificate of Waiver or Authorization (COA) prior to conductin g any operations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance , but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA in cluding class of airspace, altitude level and potential transponder requiremen ts. 26. All aircraft operated in accordance with the ex emption must be identified by serial number, registered in accordance with 14 C.F .R. part 47, and have identification (N- Number) markings in accordance w ith 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable

. 27. Before conducting operations, the radio frequen cy spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government ov ersight agency requirements. 28. The documents required fewer than 14 C.F.R. 91. 9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made avai lable to the Administrator or any law enforcement official upon request. 29. The UA must remain clear and yield the right of way to all manned aviation operations and activities at all times. 30. The UAS may not be operated by the PIC from any moving device or vehicle.25 31. Flight operations must be conducted at least 50 0 feet from all nonparticipating persons (persons other than the PIC, SO, operator t rainees or essential persons), vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficie ntly protect nonparticipating persons from the UA and/or debris in the event of a n accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticip ating persons leave such protection and are within 500 feet of the UA, fligh t operations must cease immediately and/or; b. The UA is operated near vessels, vehicles or str uctures where the owner/controller of such vessels, vehicles or struc tures has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined th at it does not present an undue hazard, and; c. Operations nearer to the PIC, SO, operator train ees 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 a uthorized 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 tha t transgresses the lateral or vertical boundaries of the operational area as defi ned by the applicable COA must be reported to the FAA's UAS Integration Offic e (AFS-80) within 24 hours. Accidents must be reported to the National T ransportation Safety Board (NTSB) per instructions contained on the NTSB Web s ite: www.ntsb.gov

. 2. Reasons Why An Exemption From The Requirements O f Section 61.113(a) And (b) Would Not Adversely Affect Safety. ABS Aerial Imaging Service submits that the equival ent level of safety established by Section 61.113(a) and (b) will be maintained bec ause no PIC will be allowed to operate the DJI Inspire 1 unless that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safe ly operate the DJI Inspire 1 in a manner consistent with the exemption, including evasive an d emergency maneuvers and maintaining appropriate distances from people, vess els, vehicles and structures.26 Considering ABS Aerial Imaging Service’s proposed a rea of operations, and the operating limitations set forth-above; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safe ly operate the DJI Inspire 1, ABS Aerial Imaging Service submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for ABS Aerial Imaging Service’s specific proposed flig ht operations. The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material resp ects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 1 1067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11 160, 11161). ABS Aerial Imaging Service will not allow any PIC t o operate the DJI Inspire 1 unless that PIC has demonstrated, by meeting minimu m flight-hour requirements of the DJI Inspire 1 training and currency requirements, t hat the PIC is able to safely operate the DJI Inspire 1 in a manner consistent with this exem ption, including evasive and emergency maneuvers and maintaining appropriate distances fro m people, vessels, vehicles and

structures. Specifically, the PIC must have accumulated and log ged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time a s a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot op erating 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).27 As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with app licable regulations will ensure an equivalent level of safety during ABS Aerial Imagin g Service’s proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows: In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar o perations), 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 l east 10 hours logged as a UAS pilot with a multi-rotor UAS. Prior to operations u nder 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 the se 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 th e 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addit ion 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 requ irement. Training, proficiency, and experience-building flights can also be conduct ed under the grant of exemption to accomplish the required flight time. During trai ning, proficiency, and experience-building flights the PIC is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15. Accordingly, ABS Aerial Imaging Service will ensure safe operations by not allowing any PIC to operate the DJI Inspire 1 unles s that PIC has demonstrated, by meeting minimum flight-hour and currency requiremen ts, that the PIC is able to safely operate the DJI Inspire 1 in a manner consistent wi th the exemption, including evasive and emergency maneuvers and maintaining appropriate dis tances from people, vessels,

vehicles and structures.28 3. Reasons Why An Exemption From The Requirements O f Section 91.7(a) Would Not Adversely Affect Safety. The equivalent level of safety established by Secti on 91.7(a) will be maintained because prior to every flight, ABS Aerial Imaging S ervice will ensure that the DJI Inspire 1 is in an airworthy condition based upon the UAS’s compliance with its operating

documents and as stated in the conditions and limit ations herein. Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all material r espects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 1 1067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11 159, 11160, 11161). 4. Reasons Why An Exemption From The Requirements O f Section 91.121 Would Not Adversely Affect Safety. The equivalent level of safety established by Secti on 91.121 will be maintained because the altitude information of the DJI Inspire 1 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 software limiting of maximum altitude (400’ AGL) and ABS Aerial Imaging Service’s operation of the DJI Inspire 1 wi thin visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information will be generated by GPS equipment inst alled onboard the aircraft. Prior to each flight, a zero altitude initiation point is au tomatically 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. Exemption29

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 1108 0, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11 161). 5. Reasons Why An Exemption From The Requirements O f Section 91.151(b) Would Not Adversely Affect Safety. A grant of this exemption would ensure an equivalen t level of safety established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJI Inspire 1; (2) the limitations on the proposed flight opera tions; and (3) the location of the proposed flight operations. Accordingly, ABS Aerial Imaging Service will ensure that it will safely operate the battery powered DJI Inspire 1 during da ylight hours in VFR conditions, with enough battery power to fly for a total duration of 13 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 5 minutes. Here, as in Exemption No. 11109, the technical spec ifications of the DJI Inspire 1; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safe ty established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as t he DJI Inspire 1 will provide audible, tactile and visual warnings to the PIC at the GCS w hen the UAs experiences low battery voltage, the first warning occurring at approximate ly 20% remaining battery power, and again at approximately 10% remaining battery power. At the critically low battery level, the DJI Inspire 1 will descend and land automatical ly. Significantly, previous exemptions granted by the F AA concerning Section 91.151 establish that safety is not adversely affected whe n the technical characteristics and operating limitations of the UAS are considered. Re lief has been granted for manned aircraft to operate at less than the minimums presc ribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief30

from Section 91.151 specific to UAS, in circumstanc es similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 1 0808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11 136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 6. Reasons Why An Exemption From The Requirements O f 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, ABS Aerial Imaging Servi ce submits that the equivalent level of safety with regard to the regulatory maint enance and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91 .409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because Peter Scott Myers, owner of ABS Aerial Imaging Service, will use his experience operating model aircraft to perform main tenance, alterations, or preventive maintenance on the UASs using the methods, techniqu es, and practices prescribed in the operating documents (i.e., Aircraft Maintenance Log and DJI Inspire 1 Instruction Manual). Furthermore, ABS Aerial Imaging Service wi ll document and maintain all maintenance records for the DJI Inspire 1. Since the DJI Inspire 1 will be inspected as prescr ibed by the operating documents, ABS Aerial Imaging Service will maintain the equiva lent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI Inspire 1 Instruction Manual is attached hereto as Appendix B; a copy of the DJI Inspire 1 aircraft Maintenance log is attached hereto as Appendix C. Furthermore, the exemption sought would maintain an equivalent level of safety established by Sections 91.407, 91.417(a) and 91.41 7(b), because all maintenance of the DJI Inspire 1 will be performed by ABS Aerial Imagi ng Service. Maintenance will be documented and maintained utilizing the Aircraft Ma intenance log.31 Significantly, previous exemptions granted by the F AA 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 character istics and operating limitations of the

UAS are considered. In consideration of ABS Aerial Imaging Service’s pr oposed operating limitations, the operating documents, and the technical aspects of the DJI Inspire 1, ABS Aerial Imaging Service submits that safety will not be adv ersely 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 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, 11 112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 7. The FAA May Prescribe Any Other Conditions For S afe Operation.

In accordance with Section 333 of the FAA Moderniza tion and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Condi tions, ABS Aerial Imaging Service requests that the FAA prescribe special conditions for the intended operation of the DJI Inspire 1, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that esta blished 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 sp ecial conditions will permit safe operation of the UAs for the limited purpose of con ducting aerial video and photography within the National Airspace System for compensatio n or hire. FMRA Section 333 sets forth the requirements for considering whether a UA S will create a hazard to users of the32

NAS or the public, or otherwise pose a threat to na tional security; and further, provides the authority for such UAS to operate without airworthi ness certification in accordance with any requirements that must be established for the s afe operation of the UAS in the NAS. Likewise, the Administrator may prescribe special c onditions pursuant to 14 C.F.R. § 21.16, for operation of the DJI Inspire 1, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safe ty standards, due to the novel or unusual design features of the aircraft. Section 21.16, ent itled Special Conditions, states the following: If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an air craft, aircraft engine, or propeller because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and ame ndments thereto for the product. The special conditions are issued in accordance wit h Part 11 of this chapter and contain such safety standards for the aircraft, air craft engine or propeller as the FAA finds necessary to establish a level of safety equivalent to that established in the regulations. See 14 C.F.R. § 21.16. Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for ABS Aerial Ima ging Service’s intended operation of the DJI Inspire 1, which contain such safety standa rds 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), 9 1.7(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 Reg ister, stating: The Rules From Which ABS Aerial Imaging Service Seeks Exemption:33 ABS Aerial Imaging Service seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). A Brief Description Of The Nature Of The Exemption ABS Aerial Imaging Service Seeks: This exemption will permit ABS Aerial Imaging Servi ce to commercially operate an Unmanned Aircraft System (UAS) for the purpose of c onducting aerial video and photography within the National Airspace System (NA S).

G. Any Additional Information, Views, Or Arguments Ava ilable To Support ABS Aerial Imaging Service’s Request. This Petition is made pursuant to the FAA Moderniza tion 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, ABS Ae rial Imaging Service’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 co nsidering 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 s uch UAS to operate without airworthiness

certification. As discussed in detail above, ABS Aerial Imaging Se rvice will operate the DJI Inspire 1 safely in the NAS, without creating a haz ard to users of the NAS, or the public, or otherwise pose a threat to national security.

CONCLUSION As set forth herein, ABS Aerial Imaging Service see ks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Moderniza tion and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI Inspire 1 commercially, without an35

Appendices: A – DJI Inspire 1, Specifications Data Sheet B – DJI Inspire 1, Manufacturer’s Instruction Manua l C – Aircraft (UA) Maintenance Log36 APPENDIX – A DJI Inspire 1 TECHNICAL SPECIFICATIONS ABS Aerial Imaging Service only utilizes safe and r eliable UASs. DJI is an industry leader in small UAS production. The DJI Inspire 1 is loade d 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 hi gher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJI software provides real-time altitude and location informatio n to the PIC via the integrated touch screen monitor. 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: 150 0 /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 0 F to 104 0 F (-10 0 C to 40 0 C) 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 Motio n: 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 +30 0 ; Pan: ±320 0 2.2.2.7 Mechanical Range – Pitch: -125 0 to 45 0 ; Pan: ±330 0 2.2.2.8 Max Controllable Speed – Pitch: 120 0 /s; Pan: 180 0 /s

2.2.3 Camera 2.2.3.1 Name – X3 2.2.3.2 Model – FC350 2.2.3.3 Total Pixels – 12.76M37 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: 1920x1080p24/25/30/48/50/6 0; HD: 1280x720p24/25/30/48/50/60 2.2.3.10 Operating Temperature Range - 32 0 F - 104 0 F (0 0 C - 40 0 C)

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) – 200 0m 2.2.4.4 Output Power – 9W 2.2.4.5 Operating Temperature Range - 14 0 F to 104 0 F (-10 0 C to 40 0 C) 2.2.4.6 Battery – 600mAh LiPo 2S