June 5, 2015

Exemption No. 11738 Regulatory Docket No. FAA

– 20 15

– 0871
Mr. Guy Stacy Walker WalkerStudio 310 Main Street Evansville, IN 47708
Dear Mr. Walker : This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends. By letter dated March 22, 2015 , you petitioned the F ederal Aviation Administration (FAA) for an exemption . The petitioner requested to operate an unmanned ai rcraft system (UAS) to conduct aerial photography and videography

. See Appendix A for the petition submitted to the FAA des cribing the proposed operations and the regulations that the petitioner seeks an exemption

. The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner

. Airworthiness Certification The UAS proposed by the petitioner is a DJI Inspire 1. In accordance with the statutory criteria provided in Section 333 of P ublic Law 112

− 95 in reference to 49 U

. S

. C

. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the Secretary of Transportation2

has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA finds that relief from 14 CFR part 21 , C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates , and any associated noise certification and testing requirements of part 36, is not necessary. The Basis for Our Decision You have requested to use a UAS for aerial data collection 1

. The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No s . 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater propo rtions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest. Having reviewed your reasons for requesting an exemption, I find that

—

 They are similar in a ll material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213 ;  The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to the situation you present; and
 A grant of exemption is in the public interest. Our Decision In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by th e Administrator, Guy Stacy Walker is granted an exemption from 14 CFR §§ 61.23(a) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a) , 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. This exemption is subject to the conditions and limitations listed below. Conditions and Limitations
In this grant of exemption, Guy Stacy Walker is hereafter referred to as the operator.

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (pa rticulate measurement, etc.), or any other gathering of data by instruments aboard the UA.3

Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption. 1. Operations authorized by this grant of exemption are limited to the DJI Inspire 1 when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption

. 2. Operations for the purpose of closed

- set motion picture and television filming are not permitted. 3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine co mpliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer. 4. The UA must be operated at an altitude of no more than 400 feet above gr ound level (AGL). Altitude must be reported in feet AGL. 5. The UA 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 or U.S. driver’s license.
6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times ; e lectronic messaging or texting is not permitted during flight operations. The PIC must be designated b efore the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.
7. This exemption and all documents needed to operate the UAS and conduct its operations i n accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon reque st. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow t he procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised4

documents to the Administrator or any law enforce ment official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the F AA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FA A’s UAS Integration Office (AFS− 80) may be contacted if questions arise regarding updates or revisions to the operating documents. 8. Any UAS that h as undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. , replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functiona l test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.
9. The operator is responsi ble for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation. 10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g. , inoperable components, items, or equipment. 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.
11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components. 12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins. 13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airma n medical certificate or a valid U.S. driver’s license issued by a state, the District of Col u mbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exempt ion, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with5

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (traini ng, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During traini ng, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticip ants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorolo gical conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized. 16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbo l as denoted on the current FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. T he letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request. 17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visi bility is less than 3 statute miles from the PIC. 18. If the UAS loses communications or loses its GPS sign al, the UA must return to a pre - determined location within the pr ivate or controlled

- access property. 19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies. 20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at lea st five minutes or with the reserve power recommended by the manufacturer if greater. 21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be cond ucted in accordance with an ATO

- issued COA. The exemption hold er may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA

. 22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance w ith 14 CFR part 47, and have identification (N− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.6

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents re quired under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request. 24. The UA must remain clear and give way to all manned aviation operations and activities at all times. 25. The UAS may not be operated by the PIC from any moving device or vehicle. 26. All Flight operations must be conducted at least 500 feet from all nonpartici pating persons, vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons r emain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons ; and b. The owner/ controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard

. The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption. 27. All operations shall be conducted over private or control led

- access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted. 28. Any incident, accident, or flight op eration that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FA A's UAS Integration Office (AFS− 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

. If this exemption permits operations for the purpose of closed

- set motion picture and television filming and production, the following a dditional conditions and limitations apply. 29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.7

30. At least 3 days before aerial filming, the operator of the UAS affected by this exempti on must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the a rea of proposed filming. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities must inclu de at least the following: a. Dates and times for all flights; b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption; c. Name and phone number of th e person responsible for the on

- scene operation of the UAS; d. Mak e, model, and serial or N− Number of UAS to be used; e. Name and certificate number of UAS PICs involved in the aerial filming; f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request; g. Signature of exemption holder or representative; and h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation. 31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM. Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91. This exemption terminates on June 30, 3017 , unless sooner superseded or rescinded. Sincerely,

John S. Duncan Director, Flight Standards Service EnclosuresUNITED STATES OF AMERI CA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

WASHI NGTON, DC

Regulatory

Docket No. _______________

**IN THE MATTER OF THE PETITION FOR EXEMPTION OF: Guy Stacy Walker**  **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 VISION+ AND DJI INSPIRE 1 UNMANNED**  **AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF**  **THE FAA MODERNIZATION AND REFORM ACT OF 2012**

**(PUBLIC LAW 112**
**- 95)** 

Submitted on March 22, 2015 Guy Stacy Walker WalkerStudio 310 Main St Evansville, IN 47708 812

- 402

- 41242 **TABLE OF CONTENTS** Page GLOSSARY OF ABBREVIATIONS...................................................................................3 SUMMARY.......................................................................................... .................................4
IN TRODUCTION AND INTERESTS OF PETITIONER....................................................4 BACKGROUND................................................................................................................. ...4 BASI S FOR PETITION.........................................................................................................5 NAME AND ADDRESS OF PETITIONER.............................................................7 THE SPECI FI C SECTIONS OF 14 C.F.R. FROM WHI CH GUY STACY WAL KER SEEKS EXEMPTI ON.................................................................8 THE EXTENT OF RELIEF TRAVIS LEE BERRY SEEKS AND THE REASON GUY STACY WAL KER SEEKS THE RELIEF.........................11 THE REASONS WHY GRANTING GUY STACY WAL KER’S REQUEST WOUL D BE IN THE PUBLIC INTEREST .........................................................15 THE REASONS WHY GRANTING THE EXEMPTI ON WOULD NOT ADVERSEL Y AFFECT SAFETY... .......................................................................19 SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGI STER......34 ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT GUY STACY WALKER’S REQUEST.........34 CONCL USION.. ..................................................................................................................35 APPENDI CES........................................................................................373 **GLOSSARY OF ABBREVIATIONS** AGL Above Ground Level AOI Area of Interest ATC Air Tra ffic Control ATO Air Traffic Organization AV Aerial Vehicle CFR Code of Federal Regulations COA Certificate of Authorization FAA Federal Aviation Administration FAR Federal Aviation Regulation GCS Ground Control Station GPS Global Positioning Sy stem LOL Loss of Link NAS National Airspace Sy stem NOTAM Notice to Airman PI C Pilot I n Command Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333 SO Safety Observer SOP Standard Operating Procedures UA Unmanned Aircraft UAS Unmanned Aircraft Sy stem VFR Visual Flight Rules VLOS Visual L ine of Site VMC Visual Meteorological Conditions VTOL Vertical Takeoff and Landing4 **SUMMARY** Guy Stacy Walker 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 S ys tem pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This ex emption will permit Guy Stacy Walker to operate an Unmanned Aircraft Sy stem (UAS) for the commercial purpose of conducting aerial video and p hotography of real estate, landscape s , and

c ommercial clients over certain areas of the United States.

**INTRODUCTION AND INTERESTS OF THE PETITIONER** Guy Stacy Walker provides his clients wit h expertise and knowledge in photograph y and videography to increase efficiency , productivity and effectiveness. Gu y Stacy Walker has over 1 4 ye ars of professional expe ri ence in photograph y and is recognized as an expert in this area . He has over 3 ye ars recreational/hobby experience in all aspects of aerial video and photograph y. The objective of Gu y Stacy Walker aerial video and photograph y operation s is to provide high qualit y imaging for a variet y of

comme rcial, public, and residential uses, specifically targeting:

 Wedding Cinematography

 Real

- estate marketing

 Motion Picture and Commercial Filming

 Aerial acquisitions used fo r inspections of public and private structures. **BACKGROUND** Unmanned Aircraft Sy stems: DJI I nspire 1 UASs5 Guy Stacy Walker seeks an exemption to operate DJI s ys tems for compensation or hire within the NAS. The DJI I nspire 1 is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone s ys t ems. The DJ I Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of approximat ely 42 knot s. The DJI I nspire 1UAs is equipped with four main rotors; driven b y Li thium Poly mer battery

powered electric motors. The DJ I Inspire 1 UA that will be operated b y Gu y Stacy Walker 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, Guy

Stacy Walker , pursuant to the provisions of the Fede ral 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 , hereb y petitions the Administrator to commerciall y operate the DJ I Inspire 1 UAS in the National Airspace S ys tem (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). In consideration of the speed, weight, size, and li mited operating area associated with the unmanned aircraft and its operation, Gu y Stacy Walker’S operat ion of the D JI Inspire 1 UAS 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 Accordingl y, Gu y Stacy Walker 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 onl y appl y to aircraft with an airwor thiness certificate. Guy Stacy Walker submits that the requested relief is proper since an equivalent level of safety

will be ensured. Gu y Stacy Walker will use experienced personnel or technicians to perform maintenance, alterations, or pre ventive mainte nance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log , and DJ I Inspire 1 Instruction Manual). Furthermore, Gu y Stacy Walker will document and maintain all maintenance records for the DJ I Inspire 1 UAS

. Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command , is requested by Gu y Stacy Walker to the extent necessary

to allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an airman medical certificate, and who has demonstrated, b y meeting minimum flight

- hour and currency requirements, that the PI C is a ble to safely

opera te the
DJI I nspire 1 UA s in a manner consistent with this exemption, including evasive and
emergency

maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Guy Stacy Walker seeks relief from Secti on 91.7(a), entitled Civil aircraft airworthiness , becau se the DJ I Inspire 1 UAS do es not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Gu y Stacy Walker submits that he will ensure tha t the DJI Inspire 1UAS is in an airworthy condition, prior to every

flight, by determining that the UASs are in compliance with the operating documents (i.e.,7

Monthly Maintenance Log, and DJ I Inspire 1 Instruction Ma nual), and that the aircraft is in a condition for safe flight. Guy Stacy Walker also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , a s the DJ I Inspire 1 UA will not have a ty pical barometric altimeter onboard. However, altitude information o f the DJ I Inspire 1UAs will be prov ided to the PI C via Global Positioning Sy stem (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 Guy Stacy Walker’ s operation o f the DJ I Inspire 1 UASs within vis ual line of sight, at or below 4 00 feet AGL, will ensure a level of safet y equivalent to Section 91.121. Additionally , Gu y Stacy Walker seeks an exemption from the requirements of Section 91.151(b), entitled F uel requirements for flight in VFR conditions

. Guy Stacy Walker submits that safety will not be affected by

operation o f the DJ I Inspire 1 UA during day light hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough batte ry

power to fl y for a total duration of approximately 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fl y after that for at least 4.5 minutes. In accordance with 14 C.F.R. § 11.81, Gu y Stacy Walker 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: Guy Stacy Walker WalkerStudio 310 Main St Evansville I n 477088

812

- 402

- 4124 Email:stacy @walkerstudiophoto.com **B. The Spec ific Sections Of 14 C.F.R. From**  **Which Guy Stacy Walker**  **Seeks Exemption.**  **1. Guy Stacy Walker**  **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 (PI C) of an aircraft that is carry ing passenge rs or propert y 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 an y business or emplo ym ent if

— (1) The flig ht is only

incidental to that business or employ ment; and (2) The aircraft does not carry passengers or property

for compensation or hire.

**2. Guy Stqcy Walker**  **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. **3. Guy Stacy Walker**  **Seeks Exemption From The Requirements Of Section 91.121.**  Section 91.121, entitled Altimeter settings , subsection (a), states the following, in part: (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, b y reference to an altimeter that is set, when operating

-- (1) Below 18,000 feet MSL , to

--9 (i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the cur

rent reported altimeter setting of an appropriate available station; or (iii) I n the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure.
**4. Guy Stacy Walker**  **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. Guy Stacy Walker**  **Seeks Exemption From The Requirement Of Section 91.405(a).**  Section 91.405, entitled Maintenance required , subsection (a), states the following: Each owner or operator of an aircraft

— (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.]
**6. Guy Stac**  **y Walker 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

aircraf t that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

-- (1) It has been approved for return to service b y a person authorized under § 43.7 of this chapter[.]10 **7. Guy Stacy Walker**  **Seeks Exemption From The Requirements O f 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 b y a person authorized 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. Guy Stacy Walker**  **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) 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 wo rk 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 ser

vice of the airframe, each engine, each propeller, and each rotor.11 (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 ar e required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safet y directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms prescribed b y § 43.9(d) of this chapter for each major alteration to the airframe and currentl y installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded b y other work or for 1 ye ar after the work is performed. (2) The records specified in p aragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are r epaired and the aircraft is approved for return to service. **C. The Extent Of Relief Guy Stacy Walker**  **Seeks And The Reason Guy Stacy Walker**  **Seeks The Relief. 1. Extent Of Relief**  **Guy Stacy Walker And The Reason**  **Guy Stacy Walker 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 PI C holding a private pilot or higher level certificate , as well as a current and valid airman medical12

certificate, and who has met certain flight

- hour and currency requirements, to conduct the proposed UAS flight operations for compensation or hire. This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may , for compensation or hire, act as PI C of an aircraft in connection with an y business or emplo ym ent if: (1) The flight is only incidental to that business or employ

ment; and (2) The aircraft does not carr y passengers or propert y for compensation or hire. As set forth more full y below , Gu y Stacy Walker submits that an equivalent level of safet y will be maintained because no PIC will be allowed to operate t he DJI I nspire 1 UAS unless that PI C has met c ertain flight

- hour and currency requirements, demonstrating that the PI C is able to safely operate the DJ I Inspire 1 UAS in a manner consistent with the operations specifications as described in this exemption, including evasive and
emergency

maneuvers, a s well as maintaining appropriate distances from people, vessels, vehicles and structures. Further, Gu y Stacy Walker submits that all flights of the DJ I Inspire 1 UAS , conducted b y the PIC pursuant to the grant of this Petition: (1) will be incidental to G uy Stacy Walker ’s business; and (2) will not carry passengers or propert y for compensation or hire. **2. Extent Of Relief Guy Stacy Walker**  **Seeks And The Reason Guy Stacy** 

**Walker 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 Guy Stacy Walker to determine tha t the DJ I Inspire 1 UAS is in airworth y condition prior to every flight b y ensuring that the UAS is in compliance with13

the operating documents (i.e., the Gu y Stacy Walker Aerial Operations Manual, Monthly Maintenance Lo g , and DJI I nspire 1 Instruction Manual). Guy Stacy Walker seeks the requested relief because the DJ I Inspire 1 UASs does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Gu y Stacy

Walker will ensure tha t the DJI I nspire 1 UAS is in airworthy condition based upon its compliance with the operating documents (i.e ., Monthly Mai ntenance Lo g, and DJI I nspire 1 Instruction Manual) prior to every flight, and further, determine that the aircraft is in condition for safe flight, as stated in the conditions and limitations below. **3. Extent Of Relief Guy Stacy Walker**  **Seeks And The Reason Guy Stacy**  **Walker Seeks Relief From Section 91.121.**  Relief from Section 91.121, entitled Altimeter settings , may be required to allow flight operations of the D JI I nspire 1 UAS , which utilize a barometric pressure sensor, GPS equipme nt, and a radio communications telemetry data link to downlink altitude information from the UA to the PI C at the ground control station (GCS). Since the FAA requires that an y altitude information concerning UAS operations be reported to air traffic
contro l (ATC) in feet above ground level (AGL), Guy Stacy Walker seeks the requested relief becaus e the DJ I Inspire 1 UA’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight. Cons idering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply

with the applicable conditions and limitations stated below. As more full y set forth herein, an equivalent level of safet y will b e maintained sinc e the DJI I nspire 1 UA is equipped with a barometric pressure sensor and GPS equipment, which automaticall y ensures that a ground level pressure setting will14

be established prior to each flight, and provides the PI C with altitude informati on of the UA on the heads

- up display of the GCS. **4. Extent Of Relief Guy Stacy Walker**  **Seeks a nd The Reason**  **Guy Stacy Walker**  **Seeks Relief From Section 91.151(b).** Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions , is requested to the extent required to allow flights of the battery po wered DJ I Inspire 1 UAs during daylight hours in visual meteorological 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. Guy Stacy Walker seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery po wered DJ I Inspire 1 UA will severel y constrain the practicalit y of an y aerial video or still photo flight operations that Guy Stacy Walker proposes to conduct pursuant to this Petition. Significantl y, as set forth below, the technical specifications o f the DJ I Inspire 1 UAS, the DJ I Inspire 1 operating documents, and Guy Stacy Walker ’s proposed operating limitations, ensure that Guy Stacy Walker will safely

operate the battery

po wered DJ I Inspire 1 UA during day light hours in visual meteorological conditions (VMC), under visual flig ht rules (VFR), with enough battery power to fl y for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fl y after that for at least 4.5 minutes. **5. Extent Of Relief Guy Stacy Walker**  **Seeks And The Reason**  **Guy Stacy Walker**  **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 appl y to aircraft with an airworthiness certificate, Gu y Stacy Walker requests relief15

from th ese Sections because the DJ I Inspire 1 UAS do es not require airworthiness certificates. As set forth more fully below , the DJI Inspire 1 UAS meet s the co nditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingl y, Gu y Stacy Walker will use trained technicians to perform maintenance, alterations, or
pre ventive maintenance on the UAS using the methods, techniques, and practic es prescribed in the UAS operating documents (i.e., the Gu y Stacy Walker Aerial Operations Manual, Monthly

Maintenance Log , and DJ I Inspire 1 Instruction Manual). Furthermore, Guy Stacy Walker will document and maintain all maintenance records fo r the DJ I Inspire 1 UAS. **D. The Reasons Why Granting Guy Stacy Walker**  **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 public interest b y allowing Guy Stacy Walker to safel y, efficiently , and economicall y perform aerial video and pho tograph y of real estate, and landscape over certain areas of the United States. Addit ionally , use of the DJI I nspire 1 UAS will decrease congestion of the NAS, reduce pollution, and provide sign ificant benefits to the econom y. Notabl y, the benefits of Guy Stacy Walker ’s propos ed operation of the DJ I In spire 1 UAS will be realized without implicating an y privacy

issues. **1. The Public Will Benefit From Decreased Congestion Of The NAS.** The DJ I Inspire 1 UA is battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery

. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an

e xemption allowing the us e of a DJ I Inspire 1 UAS would reduce the amount of manned16

aircraft in the NAS, reduce noise and air pollution, as well as increase the safet y of life and propert y in the air and on the ground. Furthermore, b y reducing the number of manned aircraft operating in the NAS, congestion around airports caused b y arriving and departing aircraft will be reduced . The
DJI I nspire 1 UA do es not require an airport to takeoff or land. Li kewise, a reduction of manned aircraft conducting aerial v ideo and photography missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations. **2. The Public Will Benefit From The Safety And Efficiency Of T he**  **DJI Inspire 1**  **UAS .**  Conducting aerial acquisitions with the DJI I nspire 1 UASs instead of manned aircraft, will greatl y benefit the public by drastically

reducing the levels of air and noise pollution generated during traditional aerial video and still photograph y flight operations. By using battery

power and electric motors , the DJI I nspire 1 UAS produc es no air pollution, and is the most viable environmentall y conscious alternative to the cabin class, six cy linder internal combustion engine aircraft t hat are t ypically utilized for aerial video and photograph y, while burning approximately 20

- 30 gallons per hour of leaded aviation fuel . The DJ I Inspire 1 UA, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as t he UAs are propelled by battery powered electric motors, rather than an internal combustion engine. By usin g the DJ I Inspire 1 UAS to perform aerial acquisitions, the substantial risk to life and propert y in the air and on the ground, which is usually ass ociated with traditional manned aircraft flight operations, will be substantially reduced or completel y eliminated. Aside from the lack of flight crew members located onboard the aircraft, the17

D JI I nspire 1 UAs (weighing appro ximately 6 pounds 7.5 ounces at its maximum gross weight with length of 17.3 inches , width of 17.7 inches , and with no fuel on board), has less phy sical potential for collateral damage to life and propert y on the ground, and in the air, compared to the manned aircra ft that t ypicall y conduct similar operations (weighing approximately

6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity

of 180 gallons). **3. Performing Aerial Video and Photography Operations Wit h The**  **DJI Inspir**  **e 1 UASs Will Benefit The Economy.** In addition to being safe and efficient, the DJ I Inspire 1 UAS is also an economical alternative to using manned aircraft to conduct similar aeria l operations. As such, operation of the DJ I Inspire 1 UAS will allow Unit ed States based companies, like Guy Stacy Walker’s , to remain competitive and contribute to growth of the U.S. economy

. Specificall y, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory

actions phasing out leade d aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery

powered DJ I Inspire 1 UAS is one such technology that not only allows companies greater operational flexibil ity compared to manned aircraft, but provides such flexibility

without the high operational cost of a traditional manned aircraft. By operating the DJ I Inspire 1 UAS, companies such as Gu y Stacy Walker’s , can remain competitive and profitable, and therefore, provide greater job stability to emplo ye es and contractors, which will ultimately contribute to growth of the U.S. economy . Improved financial performance of U.S. companies, through commercial use of the DJI Inspire 1 UAS , provides a stable workforce that increases consumer spending; improves local, state,18

and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the United States and ab road. **4. There Are No Privacy Issues.** Similar to the manned aerial acquisition flight operations that have been conducted for decades, Gu y Stacy Walker ’ s proposed operation of the DJ I Inspire 1 UAS will not implicate any

privacy issues. Specificall y, the DJ I I nspire 1 UAS will be operated onl y in compliance with operating documents (i.e., the Guy Stacy Walker Aerial Operations Manual, Monthly

Maintenance Log, and D JI I nspire 1 Instruction Manual) which requires propert y 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 Wou**  **ld Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which**  **Guy Stacy Walker Seeks Exemption.**  **1. Reasons Why The DJI Inspire 1 UA**  **Meet s**  **The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333.**  In consid eration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, Gu y Stacy Walker’ s operation of the DJ I Inspire 1 UAS meet s the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national securit y. Specificall y, FMRA Section 333 states the 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 of19 Transportation shall determine if certain unmanned aircraft systems may operate safely in the nat ional airspace system before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act. (b ) Assessment of Unmanned Aircraft Systems.

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

-- (1 ) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security; and (2 ) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United St ates 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 na tional airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system. In seeking this exemption, Guy Stacy Walker submits that the DJI I nspire 1 UAS can operate safel y in the N AS pursuant to FMRA Section 333, as demonstrated b y: (a) the characteristics of the DJ I Inspire 1 UAS ; (b) the pilot certification requirement; and (c) the specific operating limitations.

**a. The Specifications Of The DJI Inspire 1**  **UAS Demonstrate**  **s Its Safe**  **Characteristics.** The DJ I Inspire 1 UAS do es not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability

.

**i. Technical Specifications Of T he**  **DJI Inspire 1 UAS**  **.** The technical specifications of the DJ I Inspire 1 UAS is set forth by the D JI I nspire 1 Specifications and Data Sheet, att ached hereto as Exhibit A20 **ii. The DJI Inspire 1**  **UASs Autonomous Flight And N**  **avigation Modes Enable The UAS**  **To Remain Within A Defined Operational Area.** The DJ I Inspire 1 UAS may be operated in both manual and full y autonomous flight modes. A complete description of the flight and navigational modes of the DJ I Inspire 1 UAS i s provided at pa ges 12

- 16 and 45

- 50 o f the DJ I Inspire 1 User Manual , attached hereto as Exhibit B

.

**iii. The D**  **JI Inspire 1 UAS Is**  **Designed For Automatic Return To Home Point Or Hover In The Event Of Loss Of The Control Link Or**  **Navigation.** When the Control L ink is lost, the DJI I nspire 1 UA will remain stationary , in flight, for 3 seconds or more. If, after 3 seconds, the DJ I Inspire 1 UA do es not reacquire control link data from the GCS, the UA will assume that the Control L ink is lost and the UA will return to the home position (i.e., fa ilsafe mode) via GPS, and will descend to the takeoff position and shutdown. A complete description of the Fails afe Functions of the DJ I Inspire 1 at pa ges 13 through 15 of the User Manuals, at tached hereto as Exhibit B

.

**iv. The D**  **JI Inspire 1 GCS And Its**  **Operation.** A complete description of the operation and specifications of the D JI I nspire 1 GCS and flight co ntrol software is provided at p ages 40 through 47 of the DJ I Inspire 1 User
Man ual. D JI I nspire 1 User Manual is att ached hereto as Exhibits B

.

**b. Flight Operations Of D**  **JI Inspire 1 UAS**  **Is Limited To The Line Of Sight**  **Of A Certificated Pilot in Command With A Safety Observer.** Guy Stacy Walker will only

utilize traine d p ilots to act as a pilot in command (PI C) of t he DJ I Inspire 1 UAS . Additionally , a safet y observer will assist all pilots during flight time.21 **c. Flights Of D**  **JI Inspire 1 UASs Will Be Conducted Pursuant To Specific**  **Operating Limitations.** In seeking this exemption, Guy Stacy Walker proposes to commerciall y ope rate D JI Inspire 1 UAS for the special purpose of conducting aerial video and photography over certain areas of United States, pursuant to the following specific operating limitations: 1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the oper ating documents, rotorcraft UAS weighing less than 15 pounds maximum gross weight: DJ I Inspire 1 Unmanned Aircraft Sy stems. 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 photog raph y. 3. The UAs may

not be flown at an indicated airspeed exceeding 20 knots. 4. The UA must be operated at an altitude of no more than 4 00 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a sp ecial request is made and approved b y 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 PI C at all times. This requires the PIC to be able to use human vision unaided by an y devi ce other than corrective lenses, as specified on the PI C’s FAA

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

. The SO and PI C must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be des ignated before the flight and cannot transfer his or her designation for the duration of the flight. The PI C must ensure that the SO can perform the functions prescribed in the operating documents. 8. The SO must not perform any other duties bey ond assis ting the PI C 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 be accessible during UAS ope rations and made available to the Administrator upon request. If a discrepancy

exists between the conditions and limitations contained in the grant22 of exemption and the procedures outlined in the operating documents, the conditions and limitations containe d 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 operator’s responsibility to t rack such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. If the operator determines t hat any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its grant of exemption. The FAA’s UAS I ntegration Office (AFS

- 80) may be contacted if questions arise regarding upd ates or revisions to the operating documents. 10. Prior to each flight the PI C 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 pro hibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properl y d ocumented in the aircraft records. 11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PI C who cond ucts the functional test flight must make an entry in the aircraft records. 12. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not alread y covered in the relevant sections of the o perating 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, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircraf t records, including total time in service, description of work accomplished, and the signature of the authorized person returning the UAS to service. 15. Each UASs operated under this exemption must comply with all manufacturer Safety Bulletins. 16. T he authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections. 17. The PI C must possess at least a private pilot certificate and at least a current third

- class medical certificate.23 18. The operator may

not permit any

PIC to operate unless the PI C meets the operator’s qualification criteria and demonstrates the ability to safel y operate the UAS in a manner consistent with how the UAS will be operated under the exemption , including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of tr aining the operator’s PICs are permitted under the terms of the exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency , and experience

- building flights, all persons not essential for f light operations are considered nonparticipants, and the PI C must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119. 19. UAS operations may

not be conducted during night, as defined in 14 C.F.R. § 1.1. Al l operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not a

uthorized. 20. The UA may

not operate within 5 nautical miles of an airport reference point as denoted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted i n 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. 21. The UA may

not be operated less than 500 feet below or less than 2,000 feet hor izontally

from a cloud or when visibility is less than 3 statute miles from the PI C. 22. If the UA loses communications or loses its GPS signal, it must return to a pre

determined location within the planned operating area and land or be recovered in ac cordance with the operating documents. 23. The PI C must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents. 24. The PI C is prohibited from beginning a flight unless (considering wind and for ecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 25% battery power remaining. 25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting an y operations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 4824 hours prior to the operation. All op erations 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 PIC at the Ground Control Station of the UAS an y time the UAS is operating. These documents must be made available to the Administrator or an y law enforcement officia l upon request. 29. The UA must remain clear and yi eld the right of way to all manned aviation operations and activities at all times. 30. The UAS may

not be operated b y the PIC from any moving device or vehicle. 31. Flight operations must be conducte d at least 500 feet from all nonparticipating persons (persons other than the PI C, SO, operator trainees or essential persons), vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating per sons 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, f light operations must cease immediately

and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PI C has made a safet y assessment of the ris k of operating closer to those objects and determined that it does not present an undue hazard, and; c. Operations nearer to the PI C, SO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a). 32. All operations shall be conducted over private or controlled

- access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted.25 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 r eported to the National Transportation Safet y Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

. **2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adverse**  **ly Affect Safety.** Guy Stacy Walker submits that the equivalent level of safet y established b y Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the D JI Inspire 1 UAS unless that PI C has demonstrated, by meeting minimu m flight

- hour and
currency requirements, that the PI C is able to safely operate the DJ I Inspire 1 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering Gu y Stacy Walker ’s proposed area of operations, and the operating limitations set forth

- above; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements ( See Exemption No . 11062); and the airmanship skills necessary to safel y oper ate the DJ I Inspire 1 UAS, Guy Stacy Walker submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for Gu y Stacy Walker ’s specific proposed flight operations. The FAA has previously

granted relief from Sec tion 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). Guy Stacy Walker will not allow any PIC to oper ate the DJ I Inspire 1 UAS unless that PI C has demonstrated, by meeting minimum flight

- hour requirements or the D JI26

Inspire 1 UAS training and currency requirements, that the PI C is able to sa fely operate the
D JI I nspire 1 UAS in a manner consistent with this exemption, including evasive and
emergency

maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Specificall y, the PI C must have accumulated and l ogged, 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 a ddition to the hour requirements, the PI C must accomplish 3 takeoffs and landings in the preceding 90 day s (for currency purposes). As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with appli cable regulations will ensure an
eq uivalent level of safet y during Gu y Stacy Walker ’s proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe oper ations, stating as follows: In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51( b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi

- rotor UAS. Prior to operations under Exemption No. 11062, the PI C must also have 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 requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 ho urs of multi

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

- hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary

to safely conduct the petitioner’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance27 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 PI C is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15. Accordingl y, Gu y Stacy Walker will ensure safe operations b y not allowing a ny PI C to oper ate the DJ I In spire 1 UAS unless that PIC has demonstrated, b y meeting minimum flight

- hour and currency requirements, that the PI C is ab le to safely operate the
D JI I nspire 1 UAS in a manner consistent with the exemption, including evasive an d
emergency

maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. **3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety.**  The equivalent level of safet y established by Section 91.7(a) will be maintained because prior to every

flight, Gu y Stacy Walker will ensure t hat the D JI I nspire 1 UAS is in an airworth y 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) specific to UAS, in circumstance s similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). **4. Reasons Why An Exemption Fr om**  **The Requirements Of Section 91.121 Would Not Adversely Affect Safety.**  The equivalent level of safet y established b y Section 91.121 will be maintained because the altitude information of the DJ I Inspire 1 UAs will be provided to the PI C via GPS equipment and a radio communications telemetry data link, which downlinks from28

the UA to the GCS for active monitoring of the flight path and altitude. This altitude informati on , combined with Guy Stacy Walke r ’s oper ation of the D JI I nspire 1 UA within visual line of sight, at or below 500 feet AGL, will ensure a level of safet y equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to each fligh t, 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. Ex emption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). **5. Reasons Why An Exemption 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 DJ I Inspire
1 UAS ; (2) the limitations on the proposed flight operations; and (3) the loc ation of the proposed flight operations. Accordingl y, Gu y Stacy W alker will ensure that it will safely operate the battery

powered D JI I nspire 1 UA during day light hours in VFR conditions, with enough battery

power to fl y for a total duration of 13.5 minut es to the first point of intended landing and, assuming normal cruising speed, to fl y after that for at least 4.5 minutes. Here, as in Exemption No. 11109, the technical specifications of the D JI I nspire 1 UAS ; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safety established b y 14 C.F.R. Section 91.151(b). Furthermore, safet y will be ensured as the D JI I nspire 1 UAS provide aud ible29

and visual warnings to the PI C at the GCS when the UAs experiences low battery voltage, the first warning occurring at approximately 33% remaining battery

power, and again at approximately

10% remaining battery

power. At the criticall y low battery lev e l, the DJ I Inspire 1 UA s will descend and land automatically

. Significantl y, previous exemptions granted b y the FAA concerning Section 91.151 establish that safet y is not adversel y affected when the technical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 speci fic 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 Requirements Of Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would**  **Not Adversely Affect Safety.** In seeking this exemption, Guy Stacy Walker submits that the equivalent level of safet y with regard to the regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because Gu y Stacy Walker will use trained technicians to perform m aintenance, alterations, or pr eventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., the Gu y Stacy Walker Aerial Operations Manual, Monthly Maintenance Log, an d D JI I nspire 1 Instruction Ma nual). Furthermore, Gu y Stacy Walker will document and maintain all maintena nce records for the DJ I Inspire 1 UAS

.30 Since the DJ I Inspire 1 UAS will be inspected as prescribed b y the operating documents, Gu y Stacy Walker will maintain the equivalent level of safet y established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A cop y of the DJI I nspire 1 User Manual is at tached hereto as Exhibit B ; a copy of the D JI I nspire 1 UAS Maintenance LOG is attached hereto as Exhibit C

. Likewise, the exemption sought will not adversel y affect safety because Guy Stacy Walker will use trained technicians to perform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed by the
op erating documents. Furthermore, the exemption sought would maintain an equivalent level of safet y established by

Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of t he
DJI Inspire 1 UASs will be performed b y trained technicians. Mainten ance will be documented and maintained utilizing the monthly maintenance log. Significantl y, previous exemptions granted b y the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safet y is not advers el y affected when the technical characteristics and operating limitations of the UAS are considered. In consideration of Gu y Stacy Walker ’s proposed operating limitations, the operating documents, and the technical aspects of the DJ I Inspire 1 UAS , Guy St acy Walker submits that safety will not be adversel y affected b y 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 simi lar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064,31

11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). **7. The FAA May Prescribe Any Other Conditions For Safe Operation.** In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions , Guy Stacy Walker requests that the FAA prescribe spe cial conditions for the intended operation of the D JI I nspire 1 UAS , which contain such safet y standards that the Administrator finds necessary to establish a level of safet y equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 6 1.113(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 t he authority for such UAS to operate without airworthiness certification in accordance with
any requirements that must be established for the safe operation of the UAS in the NAS. Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of t he DJ I 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 subchapter do not contain adequate or appropriate safet y standards for an aircraft, aircraft engine, or propeller because of a novel or unusual design f eature of the aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product.32 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. Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA
may prescribe s pecial conditions for L eading Edge’s intended operation o f the DJ I Inspire 1 UAS , which contain such safet y standards that the Administrator finds necessary to establish a level of safet y 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**  **From Which Guy Stacy Walker**  **Seeks Exemption:** Guy Stacy Walker 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 Guy Stacy Walke**  **r Seeks:**  This exemption will permit Guy Stacy Walker 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 Arg**  **uments Available To Support Guy**  **Stacy Walker ’s**  **Request.** This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely

in the NAS. As such, Guy Stacy Walker ’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.33 FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national securit y; and further, provides the authority for such UAS to operate without airworthiness certification. As discussed in detail above, Gu y Stacy Walker will operat e the DJ I Inspire 1 UAS safel y in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national securit y. **CONCLUSION** As set forth herein, Gu y Stacy Walker seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation o f the DJ I Inspire 1 UAS commerciall y, without an airworthiness certificate, for the limited purpose of conducting aerial video and photograph y over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization a nd Reform Act of 2012, while also advancing the interests of the public, b y allowing Gu y Stacy Walker to safel y, efficientl y, and economically operate the DJ I Inspire 1 UAS commerciall y within the NAS. **WHEREFORE** , in accordance with the Federal Aviation Re gulations and the FAA Modernization and Reform Act of 2012, Section 333, Guy Stacy Walker respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151( b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit L eading Edge to operate the DJ I Inspire 1 UAS commercially for the purpose of conducting aerial video and photography34

over certain areas of the United States.
Date d: March 20 , 2015

Respectfully submitted, Guy Stacy Walker

_________________________ Guy Stacy Walker WalkerStudio 310 Main Street Evansville, IN 47708 812

- 402

- 4124

Appendic es : A

– DJ I Inspire 1 Specifications Data Sheet B

– DJ I Inspire 1 Manufacturer’s User Manual C

– Monthly

Maintenance L og35 APPENDIX

– A **DJI INSPIRE 1 TECHNICAL SPECIFICATIONS**  Travis Lee Berry onl y utilizes safe and reliable UASs. DJI is an industry

leader in small UAS production. DJ I UASs are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can al so be set to limit flight to no higher than a predetermined and set altitude as well as limit f l ight to a predetermined and set distance. In addition, DJ I software provides real

- time altitude and location information to the PI C via the linked monitor (smart phone/tablet devices) 2.2 DJI Inspire 1
2.2.1 Aircraft 2.2.1.1 Model

– T600 2.2.1.2 Weight (Battery Included)

– 6lbs 7.5291oz (2935g) 2.2.1.3 Hovering Accuracy (GPS Mode)

– Vertical: 0.5m; Horizontal: 2.5m 2.2.1.4 Max Angular Velocity

– Pitch: 300 0 /s; Yaw: 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 2.2.1.1 1 Max Flight Time

– Approximately 18 minutes 2.2.1.12 Motor Model

– DJI 3510 2.2.1.13 Propeller Model

– DJI 1345 2.2.1.14 Operating Temperature Range

– 14 0F to 1040F (

- 10 0C to 400C) 2.2.1.15 Dimensions

– 17 1⁄4” x 17 3⁄4” x 12”
2.2.2 Gimbal 2.2.2.1 Model

– ZENMUSE X3 2.2.2.2 Output Power (with camera)

– Static: 9W; In Motion: 11W 2.2.2.3 Operating Current

– Static: 750mA; In Motion: 900mA 2.2.2.4 Angular Vibration Range

- ±0.03 0 2.2.2.5 Mounting

– Detachable 2.2.2.6 Controllable Range

– Pitch:

- 90 0 to +300; Pan: ±320 0 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
2.2.3 Camera 2.2.3.1 Name

– X3 2.2.3.2 Model

– FC35036 2.2.3.3 Total Pixels

– 12.76M 2.2.3.4 Effective Pixels

– 12.4M 2.2.3.5 I mage Max Size

– 4000x3000 2.2.3.6 ISO Range

– 100

- 3200 2.2.3.7 Field of View

- 94 0 2.2.3.8 CMOS

– Sony EXMOR 1/2.3” 2.2.3.9 HD Video Recording

– UHD(4K): 4096x2160p24/25, 3840x2160p24/25/30; FHD: 1920x1080p24/25/30/48/50/60; HD: 1280x720p24/25/30/48/50/60 2.2.3.10 Operating Temperature Range

- 32 0F

- 104 0F (00C

- 40 0C)
2.2.4 Transmitter 2.2.4.1 Name

– C1 2.2.4.2 Operating Frequency

– 5.728

- 5.850GHz; 2.400

- 2.483GHz 2.2.4.3 Communicating Distance (unobstructed)

– 2000m 2.2.4.4 Output Power

– 9W 2.2.4.5 Operating Temperature Range

- 14 0F to 1040F (

- 10 0C to 400C) 2.2.4.6 Battery

– 600mAh LiPo 2S37 APPENDIX

– B
DJI I nspire 1 Manufacturer’s User Manual38 APPENDIX

– C

m o n t h :

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