July 31, 2015

Attn: U.S. Department of Transportation Docket Operations West Building Ground Floor, Room w12-140 1200 New Jersey Ave, SE Washington, DC 20590

RE: DRONE ZONE VIDS LLC REQUEST EXEMPTION FROM THE REQUIREMENTS OF 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.1139(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 Inspire 1 UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 PUBLIC LAW 112-95

Richard Rollins Chief Executive Officer Drone Zone Vids LLC 17716 Fruited Plain Ln Edmond, Ok 73012 dronezonevids.com Tim Fannin Chief Operations Officer Drone Zone Vids LLC 17717 Fruited Plain Ln Edmond, Ok 73012 dronezonevids.com



### Page of 1 22TABLE OF CONTENTS

PAGE

GLOSSARY OF ABREVIATIONS..................................................................................................................3

SUMMARY....................................................................................................................................................4

INTRODUCTION & INTREST OF PETITIONER ........................................................................................4

CAPABILITIES............................................................................................................................................4

. BASIS FOR PETITION................................................................................................................................5

NAME AND ADDRESS OF PETITIONER....................................................................................................6

SPECIFIC SECTIONS OF TITLE 14 CFR FROM WHICH DRONE ZONE VIDS SEEKS EXEMPTION.....6

THE EXTENT AND REASON DRONE ZONE VIDS SEEKS RELIEF ..........................................................9

THE REASON WHY GRANTING DRONE ZONE VIDS LLC REQUEST WOULD BE IN THE PUBLIC INTEREST.................................................................................................................................................10

WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY.............................12

SUMMARY ...............................................................................................................................................21

APPENDECIES..........................................................................................................................................22



### Page of 2 22GLOSSARY OF ABBREVIATIONS

AGL Above Ground level AMA Aeronautical Modelers Association AOI Area of Interest ATC Air Traffic Control AV Aerial Vehicle CFR Code of Federal Regulations COA Certificate of Authorization FAA Federal Aviation Administration FAR Federal Aviation Regulations GCS Ground Control Station GPS Global Positioning System IAW In Accordance With LOL Loss of Link NAS National Airspace System NOTAM Notice to Airman PIC Pilot in Command Section 333 (FRMA) FAA Modernization and Reform Act of 2012 SO Safety Observer SOP Standard Operating Procedures UAS Unmanned Aircraft System VFR Visual Flight Rules VLOS Visual Line of Site VMC Visual Meterological Conditions VTOL Vertical Takeoff and Landing



### Page of 3 22SUMMARY

Drone Zone Vids seeks exemption for the requirements of 14 CFR 61.113(a)(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (a)(2), and 91.417(a)(b), to operate a UAS (DJI Inspire 1) pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). The exemption will permit Drone Zone Vids to operate its UAS for the commercial purpose of conduction aerial video and photography of residential and commercial real-estate, insurance investigation/survey of property, construction sites, inspection of roofs after damage, UAS Safety and Flight Training, and special events over certain areas of the United States.

INTRODUCTION & INTEREST OF THE PETITIONER

Drone Zone Vids is a start up company but, with over 45 years in the Aerospace Industry, Drone Zone Vids plans to capitalize on new technology in order to provide a new and unique service to its customers. Drone Zone Vids objective is to provide a safe and affordable alternative to high cost production and data collection. Utilizing the DJI’s Inspire 1 UAS we will target commercial, public, and residential uses such as:

Appraisals Marketing Development Before and after Sales Special Events UAS Safety and Flight Training

My partner and I have a cumulative 45 years experience in aircraft flight, safety, and maintenance. We also have over 12 years experience in RC Aircraft operations and flight without incident and are a member of the Aeronautical Modelers Association (AMA).

CAPABILITIES

DJI’s UAS Inspire 1 will be utilized as a for hire high quality video platform providing a unique and cost effective service within the NAS as granted by the exemption. The Inspire 1 is a quad copter vertical takeoff and landing (VTOL) unmanned aircraft (UA) with a ground control station (GCS) utilizing electronic tablet or smart phone systems. The Inspire 1 Model T600

specifications are: Dimensions................................438x451x301mm Weight .......................................6.47lbs Speed.........................................25 Mph Altitude.....................................500 Feet Flight Time...............................25 min. Battery......................................Intelligent Flight Battery 22Volts Motor x 4....................................Electric Model DJI 3510

The DJI Inspire 1 will be operated by Drone Zone Vids and will be registered in accordance with 49 USC 44103, Registration of Aircraft, and 14 CFR Part 45, Identification and Registration Marking.



### Page of 4 22BASIS FOR PETITION

Drone Zone Vids (Petitioner) pursuant to the provisions of the Federal Aviation Regulations (14CFR 11.61) and FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, herby petition the Administrator to commercially operate the DJI Inspire1 UAS in the National Airspace System (NAS), and for an exemption from the requirements of 14 CFR 61.113(a)(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (a)(2), 91.417(a)(b).

Due to the size, weight, speed, and limited operating area of the DJI Inspire 1 and its associated operations, Drone Zone Vids Inspire 1 meets the condition of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 CFR Part 21, Subpart H.

Drone Zone Vids request relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2) and 91.417(a)(b), due to the fact that these regulations set forth the requirements for maintenance that only apply to aircraft having airworthiness certificate.

The requested relief is proper since an equivalent level of safety will be ensured. Drone Zone Vids operators and maintenance personnel are highly experienced aircraft professionals holding commercial rating and Airframe and Power Plant ratings with 45 years of experience in aviation safety. Furthermore the DJI Inspire 1 will be maintained, inspected, and flown in accordance with (IAW) methods and practices prescribed in the operating documents and Inspire 1 Instruction Manual. Drone Zone Vids will maintain a flight log and maintenance log for the Inspire 1 UAS.

Drone Zone Vids request relief from certain requirements of Section 61.113(a) and (b), entitled Private Pilot Privileges and Limitations: Pilot in Command, to the extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an airman medical certificate, and who has demonstrated, by meeting minimum flight hour and currency requirements, that the PIC is able to safely operate the DJI Inspire 1 UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, and vehicles and structures.

Relief from Section 91.7(a), entitled Civil Aircraft Airworthiness, is also requested by Drone Zone Vids because, the Inspire 1 UAS does not require an airworthiness certificate in accordance with 14CFR Part 21, Subpart H. However Drone Zone Vids will ensure that the DJI Inspire 1 UAS is maintained and operated in an airworthy condition. This will be accomplished by determining that the UAS is in compliance and conforms to operating documents, (i.e., Flight logs, Maintenance logs, and DJI Inspire 1 Instruction Manual) thus ensuring the UAS is in a safe for flight condition.

Drone Zone Vids seeks exemption from the requirements of Section 91.121, entitled Altimeter Settings, as the DJI Inspire 1 UAS will not have a typical barometric altimeter on board. However, altitude information will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight altitude and path. This information, combined with Drone Zone’s operation of the DJI Inspire 1 UAS within visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121.

Drone Zone Vids also seeks exemption from the requirements of Section 91.151(b), entitled Fuel Requirements for Flight in VFR Conditions. Drone Zone Vids submits that safety will not be affected by operation of the UAS during daylight hours in visual meteorological conditions



### Page of 5 22(VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration of approximately 25 minutes. Battery power is actively monitored by PIC via data link and a low battery warning sound and illumination on tablet or smart phones provides additional level of safety.

IAW 14 CFR 11.81, Drone Zone Vids 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:

Richard Rollins Chief Executive Officer Drone Zone Vids LLC 17716 Fruited Plain Ln Edmond, Ok 73012 dronezonevids.com

B. The Specific Sections Of 14 CFR From Which Drone Zone Vids LLC Seeks Exemption

1. Drone Zone Vids LLC Seeks Exemption from The Requirements of Section 61.113(a) and (b).

Section 61.113, entitled Private Pilot Privileges and Limitations: Pilot In Command, subsections (a) and (b) prescribe the following, in relevant part:

(a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PIC of an aircraft.

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business employment if—

(1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire.

2. Drone Zone Vids LLC 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 less it is in an airworthy condition.

3. Drone Zone Vids LLC 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, by reference to an altimeter that is set, when operating—

(1) Below 18,000 feet MSL, to—



### Page of 6 22(i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure.

4. Drone Zone Vids LLC 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 an 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. Drone Zone Vids LLC Seeks Exemption from The Requirements of Section 91.405(a).

Section 91.405(a), 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. Drone Zone Vids LLC Seeks Exemption from The Requirements of Section 91.407(a)(1)

Section 91.407, entitled Operation After Maintenance, Preventive Maintenance, Rebuilding, or Alteration, subsection (a)(1), states the following:

(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless—

(1) It has been approved for return to service by a person authorized under 43.7 of this chapter.

7. Drone Zone Vids LLC Seeks Exemption from The Requirements of Section 91.409(a)(1) and 91.409(a)(2)

Section 91.409, entitled Inspection, subsection (a) states the following:

(a) except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had—

(1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person 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.



### Page of 7 228. Drone Zone Vids LLC 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 of 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 inspection, 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 work performed; and (ii) The date of completion of the work performed; and (iii) The signature, and certificate number of the person approving the aircraft for return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor. (ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The 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 safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms prescribed by 43.9(b) of this chapter for each major alteration to the airframe and currently installed engines, propellers, propellers, and appliances.

(b) The owner of 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 by other work or for 1 year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred 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 repaired and the aircraft is approved for return to service.



### Page of 8 22C. The Extent Of Relief Drone Zone Vids Seeks and The Reason Drone Zone Vids Seeks Relief.

1. Extent Of Relief Drone Zone Vids Seeks and The Reason Drone Vids Seeks Relief From Section 61.113(a) and (b).

Relief from Section 61.113(a) and (b) entitled Private Pilot Privileges and Limitations: Pilot in Command, is requested to the extent necessary to allow a PIC holding a private pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met certain flight-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) sate 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 not carry passengers or property for compensation or hire.

As set forth more fully below, Drone Zone Vids submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the DJI Inspire 1 UAS unless that PIC has met certain flight-hour and currency requirements, demonstrating that the PIC is able to safely operate the DJI Inspire 1 UAS in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures.

Further, Drone Zone Vids submits that all flight of the DJI Inspire 1 UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to Drone Zone Vids business; and (2) will not carry passengers or property for compensation hire.

2. Extent Of Relief Drone Zone Vids Seeks and The Reason Drone Zone Vids 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 Drone Zone Vids to determine that the DJI Inspire 1 UAS are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., Drone Zone Vids Aerial Operations Manual, Maintenance and Flight Logs, and DJI Inspire 1 Instruction Manual).

Drone Zone Vids seeks the requested relief because the DJI Inspire 1 UAS does not require an airworthiness certificate in accordance with 14 CFR Part 21, Subpart H. Therefore, Drone Zone Vids will ensure that the DJI Inspire 1 UAS are maintained and operated in airworthy conditions based upon its compliance with eh operating documents (i.e., Maintenance log, flight log, and DJI Inspire 1 Instruction Manual) prior to every flight, and further, determine that the aircraft are in condition for safe flight, as sad in the conditions and limitations below.

3. Extent Of Relief Drone Zone Vids Seeks and The Reason Drone Zone Vids Seeks Relief from Section 91.121.

Relief from Section 91.121, entitled Altimeter Settings, may be required to allow flight operations of the DJI Inspire 1 UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), Drone Zone Vids seeks relief because the DJI Inspire 1 UA’s



### Page of 9 22altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure offend altitude, before each flight.

Considering the limited altitude of the proposed operation, 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 herein, and equivalent level of safety will be maintained since the DJI Inspire 1 UAS are equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the PIC with altitude information of the UA on the heads-up display of the GCS.

4. Extent Of Relief Drone Zone Vids Seeks and The Reason Drone Zone Vids 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 flight of the battery powered DJI Inspire 1 UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 23 minutes. Drone Zone Vids seeks relief because without an exemption form Section 91.151(b), the flight time duration of the battery powered DJI Inspire 1 UAS will severely constrain the practicality of aerial video or still photo flight operations that Drone Zone Vids proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the DJI Inspire 1 UAS, the DJI Inspire 1 operating documents, and Drone Zone Vids proposed operating limitation, ensure that Drone Zone Vids will safely operate the battery powered DJI Inspire 1 UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total duration of 23 minutes.

5. Extent Of Relief Drone Zone Vids Seeks and The Reason Drone Zone Vids Seeks Relief from Section 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, Drone Zone Vids request relief from these Sections because the DJI Inspire 1 UAS do not require airworthiness certificates. As set forth more fully below, the DJI Inspire 1 UAS meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, Drone Zone Vids will use trained technicians to prom maintenance, alteration, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., Drone Zone Aerial Operations Manual, Maintenance Log, and DJI Inspire Instruction Manual). Furthermore, Drone Zone Vids will document and maintain all maintenance records for the DJI Inspire 1 UAS.

D. The Reasons Why Granting Drone Zone Vids 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 by allowing Drone Zone to safely, efficiently, and economically perform aerial video and photography of real estate, landscapes, construction sites over certain areas of the United Sates.

Additionally, use of the DJI Inspire 1 UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of Drone Zone Vids proposed operation of the DJI Inspire 1 UAS will be realized without implicating any privacy issues.



### Page of 10 221. The Public Will Benefit From Decreased Congestion of The NAS.

The DJI Inspire 1 UAS are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the of manned aircraft needed to perform aerial acquisitions, and exemption allowing the use of DJI Inspire 1 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground.

Utilizing DJI’s Inspire 1 will reduce the amount of areal photography aircraft departing and arriving at congested airports. This will also reduce the workload of areal vehicles handled by air traffic control personnel.

2. The Public Will Benefit From The Safety and Efficiency of The DJI Inspire 1 UAS

Conducting aerial photography with the DJI Inspire 1 UAS, will greatly benefit the public y drastically reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operation. By using battery power and electric motors, the DJI Inspire 1 UAS produce no air pollution, and is the most viable environmentally conscious alternative to the general aviation aircraft utilizing noisy piston driven aircraft that typically are used for aerial video and photography, while burning several gallons per hour of leaded aviation fuel. This also helps in the efforts to reduce the amount of low lead aviation fule used in general aviation operations. The DJI Inspire 1 UAS utilizes electric motors that drive a propeller rather than a gas fueled engine.

Utilizing the DJI Inspire 1 UAS to perform aerial work, the substantial risk to life and property in the air and on the ground, which is usually reserved for traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. The DJI Inspire 1’s weight and cross section being significantly light and small further reduce the risk of physical or collateral damage to life and property as compared to manned general aviation type aircraft.

3. Performing Aerial Video and Photography Operation Utilizing the DJI Inspire 1 UAS Will Benefit The Economy.

In Addition to being safe and efficient, the DJI Inspire 1 UAS are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Inspire 1 UAS will allow United States used companies, like Drone Zone Vids to remain competitive and contribute to the growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (EPA) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery powered DJI Inspire 1 UAS in one such technology that non only allows companies greater operational flexibility, but provides such flexibility without the high operational cost of traditional manned aircraft.

By operating the DJI Inspire 1 UAS companies such as Drone Zone Vids, can be competitive and profitable, and therefore, proved greater job stability to employees and contractors, which will ultimately contribute to the 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, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the United States and abroad.



### Page of 11 224. No Privacy Issues

Just like the manned aerial photography flight operations that have been conducted for decades, Drone Zone Vids proposed operation of the DJI Inspire 1 UAS will not implicate any privacy issues. Specifically, the DJI Inspire 1 UAS will be operated only in compliance with operating documents (i.e., Drone Zone Aerial Operations Manual, Maintenance log, and DJI Inspire 1 Instruction Manual) which requires property owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 CFR 91.119.

E. The Reason Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which Drone Zone Vids Seeks Exemption.

1. Reasons Why DJI Inspire 1 UAS Meets The Conditions of The FAA Modernization and Reform Act of 2012 (FMRA) section 333.

In consideration of the size, weight speed, limited operating area, and time associated with the DJI Inspire 1 UAS, Drone Zone Vids operation of the UAS meets the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 CFR Part 21, Subpart H.

Section 333 provides authority for 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 security. Specifically, FMRA Section 333 sates the following, in part:

(a) In General.—Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the plan and rule making required by section 332 of this Act or 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 sited not crate a hazard to users of the national airspace system or the public or pose a treat to national security; and (2) Whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1)

(c) Requirements for Safe Operation.—If the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system.

In seeking this exemption, Drone Zone Vids submits that the DJI Inspire 1 UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI Inspire 1 UAS; (b) the pilot certification requirement; and (c) the specific operating limitations.



### Page of 12 22a. The Specifications Of The DJI Inspire 1 UAS Demonstrate Its Safe Characteristics

The DJI Inspire 1 UAS does not pose nor create a hazard to users of the NAS or to the public, or to national security considering its size, wight, speed, and operational capability.

(1) Technical Specifications Of The DJI Inspire 1 UAS.

The technical specifications of the DJI Inspire 1 UAS are set forth by the DJI Inspire 1 User Manual, see attached Appendix A.

(a) The DJI Inspire 1 UAS Global Positioning Modes Enables The UAS to Remain Within A defined Operational Area.

The DJI Inspire 1 UAS may be operated in both manual and global positioning flight modes. A complete description of the flight and navigation modes of the DJI Inspire 1 UAS is provided at pages 12-15 of the DJI Inspire 1 User Manual attached as Appendix A.

(b) The DJI 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 Control Link is lost, the DJI Inspire 1 UAS will remain stationary, in flight, for approximately 3 seconds. If, after 3 seconds, the DJI Inspire UAS does not reacher control link data from the GCS, the UAS will assume that the Control Link is lost and will return to home position (fail safe mode) via GPS, and will descend to the takeoff position and shutdown.

A complete description of the Failsafe Function of the DJI Inspirer 1 UAS are set forth at pages 12-15 of the DJI Inspire 1 User Manual, attached as Appendix A.

(c) The DJI Inspire 1 UAS And Its Operation.

A complete description of the operation and specifications of the DJI Inspire 1 GCS and flight control software is provided at pages 24-33 of the DJI Inspire 1 User Manual, as attached as Appendix A.

b. Flight Operations Of DJI Inspire 1 UAS Is Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer.

Drone Zone Vids staff will be the only persons to act as a pilot in command (PIC) of the DJI Inspire 1 UAS. Additionally, a safety observer will assist him or her at all times during flight time.

c. Flights Of DJI Inspire 1 UAS Will Be Conducted Pursuant To Specific Operating Limitations.

In seeking this exemption, Drone Zone Vids proposed to commercially operate DjI Inspire 1 UAS for the special purpose of conduction aerial video and photography over certain areas of the United States, pursuant to the following specific operating limitations.

1. Operation authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UAS weighing less than 55 pounds



### Page of 13 22maximum gross weight: DJI Inspire 1 UAS. Proposed operations of any other aircraft will require anew petition or a petition to amend this grant.

2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photography.

3. The UAS may not be flown at an indicted airspeed exceeding 20 knots.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and proved by ATC. All altitudes reported to ATC must be in feet AGL.

5. The UAS must be operated within visual line of sight (VLOS) of the PIC at all time. 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.

6. The use of first person view (FPV) by the PIC o or safety observer (SO) is not permitted.

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirements as long as the PIC always maintains VLOS capability. The SO and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer or delegate his or her designation for the duration of the flight. The PIC must ensure that the SO can perform the functions prescribed in the operating documents.

8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and ground based obstacles/obstructions.

9. The operating documents and the grant of exemption must be accessible during UAS operations and available to the Administrator upon request. Should a discrepancy exist between the conditions and limitations contained in the grant of exemption and the procedures outlined in the operating document, the conditions and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and reversed documented if it petitions for extensions amendment to its grant of exemption. If the operator determines that any update or vision 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 questionnaires reading updates or revisions to the operating documents.

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records.



### Page of 14 2211. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraft records.

12. The pre-flight inspection must account for all potential discrepancies, not already 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, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhauls component parts must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature of the authorized person returning the UAS to service.

15. Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins.

16. The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections.

17. The PIC must possess at least a private pilot certificate and at least a current third-class medical certificate.

18. The operator 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 will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification fight hours must be logged in a manner consistent with 14 CFR 61.51(b). Flight for the purposes of training the operator’s PIC’s 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 flight, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from non participants in accordance with 14 CFR 91.119.

19. UAS operations may not be conducted during night, as defined in 14 CFR 1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, special request will be made at the FAA office closest to proposed area of operations. Flights under special visual fight rules (SVFR) are not authorized.

20. The UA may not operate within 5 nautical miles of an airport reference point as denoted on a current FAA published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request.

21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

22. If the UA loses communications or loses its GPS signal, it must return to predetermined location within the planed operating area and land or be recovered in accordance with the operating documents.



### Page of 15 2223. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents.

24. The PIC is prohibited from beginning a flight unless (considering wind and forecasted 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 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 operations. All operations shall be conducted in accordance with airspace requirement 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 IAW 14 CFR Part 47, and have identification (N number) markings IAW 14 CFR Part 45, Subpart C. Markings must be as large as practicable.

27. Before conducting operations, the radio frequency spectrum used for operations 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 CFR 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 available to the Administrator or any law enforcement official upon request.

29. The UA must remain clear and yield the right of way to all manned aviation operations and activities at all times.

30. The UAS may not be operated by the PIC from any moving device or vehicle.

31. Flight operations must be conducted at least 500 feet from all nonparticipating persons, 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 remain under such protection. If a situation arises where nonparticipating persons leave such protection and are whig 500 feet of the UA, flight operations must cease immediately and or; b. The aircraft is operated near vessels, vehicles or structures where the owner/ controller of such vessels, vehicles obstructers has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, and;

c. Operations near to the PIC, SO, operator trainees or essential persons do not present an undue hazard to those persons per 14 CFR Part 91.119(a),

32. All operations shall be conducted over private or controlled access property with permission from the land owner or controller or authorized representative Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted.

33. Any incident, accident, or flight operation tat transgresses the literal or vertical boundaries of the operational area as defined by the applicable COA must be reported to



### Page of 16 22the FAA’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

.

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) and (b) Would Not Adversely Affect Safety.

Drone Zone Vids submits that the equivalent level of safety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight hour and currency requirements, that the PIC is able to safely operate the DJI Inspire 1 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

Considering Drone Zone Vids 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 safely operate the DJI Inspire 1 UAS, Drone Zone Vids submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for Drone Zone Vids specific proposed flight operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

Drone Zone Vids will not allow any PIC to operate the DJI Inspire 1 UAS unless the PIC has demonstrated, by meeting minimum flight hour and currency requirements, that the PIC is able to safely operate the DJI Inspire 1 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

Specifically, 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 (with a minimum of 5 hours of those hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purpose).

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during Drone Zone Vids 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 operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive other



### Page of 17 22than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi rotor time and 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight hour requirements in Exemption No. 11062 are appropriated to practice and build proficiency in the skills necessary to safely conduct the petitioner’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience building flights can also be conducted under the grant of exemption to accomplish the required flight time. During training, proficiency, and experience building flights the PIC is required to operate the UAS with appropriate distances in accordance with 14 CFR 91.119.

Exemption No. 11138 at page 15.

Accordingly, Drone Zone Vids will ensure safe operations by not allowing any PIC to operate the DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight hour and currency requirements, that the PIC is able to safely operate the DJI Inspire 1 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles, and structures.

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.7(a) will be maintained because prior to every flight, Drone Zone Vids will ensure that DJI Inspire 1 UAS is in an airworthy condition based upon the UAS’s compliance with its operating documents and as stated in the conditions and limitations herein.

Additionally, the FAA has previously granted relief from Section 91.7(a) 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).

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained because the altitude information of the DJI Inspire 1 UAS will be provided to the PIC via GPS equipment and a radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path and altitude. This altitude information, combined with Drone Zone Vids operation of the DJI Inspire 1 UAS within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically established by the UAS at ground level.

The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).



### Page of 18 225. 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 CFR Section 91.151(b) as a result of (1) the technical specifications of the DJI Inspire 1 UAS; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, Drone Zone Vids will ensure that it will safely operate the battery powered DJI Inspire 1 UAS during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 23 minutes.

Here, as in Exemption No. 11109, the technical specifications of the DJI Inspire 1 UAS; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safety established by 14 CFR Section 91.151(b). Furthermore, safety will be ensured as the DJI inspire 1 UAS provide audible and visual warnings to the PIC 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 critically low battery level, the DJI Inspire UAS will descend and land automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 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, Drone Zone Vids submits that the equivalent level of safety with regard to the regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because Drone Zone Vids will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., Drone Zone Vids Aerial Operations Manual, Maintenance log, and DJI Inspire 1 Instruction Manual). Furthermore, Drone Zone Vids will document and maintain all maintenance records for the DJI Inspire 1 UAS.

Since the DJI Inspire 1 UAS will be inspected as prescribed by the operating documents, Drone Zone Vids will maintain the equivalent 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 User Manual is attached as Appendix A.

The exemption sought will not adversely affect safety because Drone Zone Vids will use trained technicians to perform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed by the operating documents.

Also, the exemption sought would maintain an equivalent level of safety established by Sections 91.407, 91.417(a), and 91.417(b), because all maintenance o the DJI Inspire 1 will be performed buy trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log.



### Page of 19 22Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) established that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered.

In consideration of Drone Zone Vids proposed operating limitations, the operating documents, and the technical aspects of the DJI Inspire 1 UAS, Drone Zone Vids submits that safety will not be adversely affected by granting exemption from 14 CFR Sections 91.405(a), 91.407(a) (1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) . The FAA has previously granted relief specific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

7. The FAA May Prescribe Any Other Conditions For Safe Operation.

IAW Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 CFR 21.16 entitled Special Conditions, Drone Zone Vids request that the FAA prescribe special conditions for the intended operation of the DJI Inspire 1 UAS, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 CFR Part 21, Subpart H, and 14 CFR 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAS for the limited purpose of conducting aerial video and photography over certain areas of the United States for compensation or hire. FMRA Section 333 sets forth the requirements for considering whereto a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification in accordance with any requirements that must be established for the safe operation of the UAS in the NAS.

The Administrator may prescribe special conditions pursuant to 14 CFR 21.16, for operation of the DJI Inspire 1 UAS, since the airworthiness regulations of 14 CFR 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 safety standards for and aircraft, aircraft engine, or propeller because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, that prescribes special conditions and amendments thermo for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety standards for the aircraft, aircraft engine, or propeller as the FAA finds necessary to establish a level of safety equivalent to that established in the regulations.

SEE 14 CFR 21.16

In accordance with FMRA Section 333 and 14 CFR 21.16, the FAA may prescribe special condition for Drone Zone Vids intended operation of the DJI Inspire 1 UAS, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 CFR Part 21, Subpart H, and 14 CFR Sections61.113(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).



### Page of 20 22Summary That Can Be Published In The Federal Register, Stating: The Rules From Which Drone Zone Vids Seeks Exemption:

Drone Zone Vids seeks exemption from the requirements of 14 CFR 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).

Brief Description Of The Nature Of The Exemption Drone Zone Vids Seeks:

This exemption will permit Drone Zone Vids to commercially operate a Unmanned Aircraft System (UAS) for the purpose of conduction aerial video and photography over certain areas of the United States.

Additional Information, views, Or Arguments Available To Support Drone Zone Vids 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, Drone Zone Vids request for exemption may be granted pursuant tooth authority of FMRA Section 333 and 14 CFR Part 11, as set forth above.

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification.

Drone Zone Vids will operate the DJI Inspire 1 UAS safely in the NAS, without creating a hazard to users of the NAS, or the public or otherwise pose a threat to national security.

CONCLUSION

As set forth herein, Drone Zone Vids seeks an exemption pursuant to 14 CFR 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI Inspire 1 UAS commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography over certain areas of the United Sates. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interest of the public, by allowing Drone Zone Vids LLC to safely, efficiently, and economically operate the DJI Inspire 1 UAS commercially within the NAS.

Wherefore, in accordance with the Federal Aviation Regulation and the FAA Modernization and Reform Act of 2012, Section 333, Drone Zone Vids LLC respectfully request that the Administrator grant this Petition for an exemption from the requirements of 14 CFR 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 Drone Zone Vids LLC to operate the DJI Inspire 1 UAS commercially for the purpose of conduction aerial video and photography over certain areas of the United States.



### Page of 21 22Dated: July 31, 2015

Respectfully submitted,

Richard Rollins Chief Executive Officer Drone Zone Vids LLC 17716 Fruited Plain Ln Edmond, Ok 73012 dronezonevids.com Tim Fannin Chief Operations Officer Drone Zone Vids LLC 17717 Fruited Plain Ln Edmond, Ok 73012 dronezonevids.com

Appendices:

A — Link to DJI Inspire 1 User Manual, Safety Guidelines, and Maintenance Manual: Click links below

http://download.dji-innovations.com/downloads/inspire_1/en/ Inspire_1_User_Manual_v1.4_en.pdf

http://download.dji-innovations.com/downloads/inspire_1/en/ Inspire_1_Safety_Guidelines_en.pdf

http://download.dji-innovations.com/downloads/inspire_1/en/ Inspire_1_Maintenance_ManualV1.0_en.pdf



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