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UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: HUQA LIVE LLC

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 3 UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFO RM ACT OF 2012 (PUBLIC LAW 112

- 95)

Submitted on February 25, 2016
Huqa Live, LLC Attn. Raakin Iqbal 590 15 th ST S #400 Arlington, VA 22202 202

- 527

- 9342 riqbal@huqalive.com

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TABLE OF CONTENTS
Page

GLOSSARY OF ABBREVIATIONS



### ................................ ................................ .................... ...... 3

SUMMARY



### ................................ ................................ ................................ ............................ ... 4

INTRODUCTION AND INTERESTS OF PETITIONER



### ................................ ....................... ....... 4

BACKGROUND.......................................................................................................................4

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

NAME AND ADDRESS OF PETITIONER...............................................................................6
THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH HUQA LIVE, LLC SEEKS EXEMPTION ...................................................................................................7 THE EXTENT OF RELIEF HUQA LIVE, LLC SEEKS AND THE REASON HUQA LIVE LLC SEEKS THE RELIEF......................................................................... ............................................10 THE REASONS WHY GRANTING HUQA LIVE, LLC ’S REQUEST WOULD BE IN THE
PUBLIC INTEREST .........................................................................................13
THE REASONS WHY GRANTING THE EXEMPTIO N WOULD NOT ADVERSELY AFFECT SAFETY......................................................................................................16

SUMMARY THAT CAN BE PUBLISHED IN THE FE DERAL REGISTER.................28 ANY ADDITIONAL INFORMATION, VIEWS, OR ARG UMENTS AVAILABLE TO SUPPORT HUQA LIVE, LLC REQUEST....................................................... ......28
CONCLUSION........................................................................................................................ 29

APPENDICES .......................................................................................................3 0

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GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level AOI Area of Interest ATC Air Traffic Control ATO Air Traffic Organization AV Aerial Vehicle CFR Code of Federal Regulations

COA Certificate of Authorization
FAA Federal Aviation Administration FAR Federal Aviation Regulation

GCS Ground Con trol Station

GPS Global Positioning System LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing

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SUMMARY
HUQA LIVE, LLC seeks exemption from the requirements o f 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exem ption will permit HUQA LIVE, LLC to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography of real estate, weddings, music videos, online short films/trailers and landscape over certain areas of the United
States.

INTRODUCTION AND INTERESTS OF THE PETITIONER
HUQA LIVE, LLC provides its clients with photography and video recording services. The scope of work includes real estate, commercial events, private events (i.e. weddings, non

- profit galas),
and music /short /motion picture film / videos

. The obje ctive of HUQA LIVE, LLC, and it ’ s aerial operations is to provide high quality imaging for a variety of commercial, public, and residential uses, specifically targeting:

• Residential Construction

• Real

- estate marketing



### • Resort property marketing



### • Wedding Videos



### • Music Videos



### • Corporate Videos



### • O nline Short Videos/Films

BACKGROUND
Unmanned Aircraft Systems: DJI Phantom 3 UAS
HUQA LIVE, LLC seeks an exemption to operate DJI systems for compensation or hire within
the NAS. The DJI Phantom 3 UAS is a vertical takeoff and landing (VTOL) Unmanned Ai rcraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems.

The DJI Phantom 3 UAS has a maximum gross weight of 6 pounds 7.5 ounces, a length of

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17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maxim um speed of approximately 42
knots. The DJI Phantom 3 UA S is equipped with four main rotors; driven by Lithium Polymer battery powered electric motors.
BASIS FOR PETITION
Petitioner, HUQA LIVE, LLC . (HUQA) , pursuant to the provisions of the Federal
Aviati on Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereby petitions the Administrator to commercially operate the DJI Phantom 3 UAS in the National A irspace System (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 limited oper ating area associated with the unmanned aircraft and its operation, HUQA’s proposed operation of DJI Phantom 3 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, S ubpart H.

Accordingly, HUQA r equests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate.

HUQA su bmits that the requested relief is proper since an equivalent level of safety will be ensured. HUQA will use experienced personnel or technicians to perform maintenance, alterations, or

pr eventive maintenance on the UAS using the methods, techniques, and p ractices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual). Furthermore, HUQA will document and maintain all maintenance r ecords for the DJI Phantom 3 UAS.

Relief from certain requirements of Secti on 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command , is requested by HUQA 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 cert ificate, and who has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

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HUQA seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness , because the DJI Phantom 3 UAS do not require an airworthiness certificate in accordance
with 14 C.F.R. Par t 21, Subpart H. As such, HUQA submits that it will ensure that the DJI
Phantom 3 UAS is in airworthy condition, prior to every flight, by determining that the
UAS is in compliance with the operating documents (i.e., Monthly Maintenance Log, and
DJI Phanto m 3 Instruction Ma nual), and that the aircraft is in a condition for safe flight. He will utilize the preflight instructions provided by DJI to ensure airworthiness checks prior to each flight.
HUQA also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , as the DJI Phantom 3 UA S will not have a typical barometric altimeter onboard. However, altitude information of the DJI Phantom 3 UA S will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA S to the GCS for active monitoring of the flight path. This altitude information, combined with HUQA’s operation of the DJI Phantom 3 UAS within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121.
Additionally, HUQA seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions . HUQA submits that safety will not be affected by operati on of the DJI Phantom 3 UA S during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration of approximately 14.5 minutes to the first point of intended landing and, ass uming normal cruising speed, to fly after that for
at least 4.5 minutes.
In accordance with 14 C.F.R. § 11.81, HUQA provides the following information in support of its petition for exemption:

A. Name And Address Of The Petitioner.

The name and addres s of the Petitioner and point of contact is:
HUQA LIVE, LLC ATTN: Raakin Iqbal 590 15 th ST S Arlington, VA 22202 202

- 527

- 9342 riqbal@huqalive.com

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B. The Specific Sections Of 14 C.F.R. From Which HUQA LIVE, LLC Seeks Exemption.
1. HUQA LIVE, LLC Seeks E xemption 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 certi ficate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PIC of an aircraft. (b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if

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

2. HUQA LIVE, LLC Seeks Exemption From The R equirements 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. HUQA LIVE, LLC Seeks Exemption From The Requirem ents 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 referen ce to an altimeter that is set, when operating

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

-- (i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; (ii) If there is no station within the area prescribed in parag raph (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 befor e departure.

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4. HUQA LIVE, 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 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. HUQA LIVE, LLC Seeks Exe mption 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 a nd 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. HUQA LIVE, 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 alterat ion unless

-- (1) It has been approved for return to service by a person authorized under § 43.7 of this chapter [.]
7. HUQA LIVE, LLC Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2). Section 91.409, entitled Inspections , s ubsection (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

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(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.
8. HUQA LIVE, LLC Seeks Exemption From The Requir ements 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 th e 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 appropr iate, 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 compl etion 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 direc tives 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.

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(vi) Copies of the forms prescribed by § 43.9 (d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed: (1) The records 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 ti me the aircraft is
sold. (3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.

C. The Extent Of Relief HUQA LIVE, LLC , INC. Seeks And The Reason HUQA LIVE, LLC Seeks The Relief.

1. Extent Of Relief HUQA LIVE, LLC Seeks And The Reason HUQA LIVE, LLC 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 requirement s, to conduct the proposed UAS flight operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in

connect ion 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, HUQA submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the DJI Phantom 3 UAS

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unless that PIC has met certain flight

- hour and currency requirements, demonstrating that the PIC is able to safely operate either the DJI Phantom 3 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, HUQA submits that all fli ghts of the DJI Phantom 3 UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to HUQA’s business; and (2) will not carry passengers or property for compensation or hire.

2. Extent Of Relief HUQA LIVE, LLC Seeks And The Reason HUQA LIVE,
LLC 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 HUQA to determine that the DJI Phantom 3 UAS is in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., the HUQA Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual).



### HUQA seeks the requested relief because the DJI Phantom 3 UAS do es not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, HUQA will ensure that the DJI Phantom 3 UAS is in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, a nd DJI Phantom 3 Instruction Manual) prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated in the conditions and limitations below.

3. Extent Of Relief HUQA LIVE, LLC Seeks And The Reason HUQA LIVE,
L LC Seeks Relief From Section 91.121. Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the DJI Phantom 3 UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemet ry data link to downlink altitude information from the UAS 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 (A GL), HUQA seeks the requested relief because the DJI Phantom 3 UAS altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight.

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Considering the limited altitude of the proposed ope rations, 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, an equivalent level of safety will be
maintained since the DJI Phantom 3 UA S are equ ipped 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 S on the heads

- up display of the G CS.

4. Extent Of Relief HUQA LIVE, LLC Seeks And The Reason HUQA LIVE,
LLC 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 powered DJI Phantom 3 UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 14.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. HUQA seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered DJI Phantom 3 UAS will severely constrain the practicality of any aerial video or sti ll photo flight operations that HUQA proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the DJI Phantom 3 UAS, the DJI Phantom 3 operating documents, and HUQA’s proposed operating limitations, ensure that HUQA will safely operate the battery powered DJI Phantom 3 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 14.5 minutes to the
first point of intended landing and, assuming normal cruising speed, to fly after that for at
least 4.5 minutes.

5. Extent Of Relief HUQA LIVE, LLC Seeks And The Reason HUQA LIVE, LLC Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, HUQA requests relief from these Sections because the DJI Phantom 3 UAS does not require an ai rworthiness

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certificate. As set forth more fully below, the DJI Phantom 3 UAS meets the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, HUQA will use trained technicians to perform maintenance, alterations, o r preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the HUQA Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual). Furthermore, HUQA will
docu ment and maintain all maintenance records for the DJI Phantom 3 UAS.

D. The Reasons Why Granting HUQA LIVE, LLC 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 p ublic interest by allowing HUQA to safely, efficiently, and economically perform aerial video and photography of real estate, wedding/engagement shoots, music videos, online short films, and landscape over certain
areas of the United States.

Additionally, use of the DJI Phantom 3 UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of HUQA’s proposed operation of the DJI Phantom 3 UAS will be realized without implicating any priva cy issues.

1. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 3 UAS.
Conducting aerial acquisitions with the DJI Phantom 3 UAS, instead of manned aircraft, will greatly benefit the public by drastically reducing the leve ls of air and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, the DJI Phantom 3 UAS produces no air pollution, and is the most viable environmentally conscious a lternative to the cabin class, six cylinder internal combustion engine aircraft that are typically utilized for aerial video and photography, while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The DJI Phantom 3 UAS, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAS is propelled by battery powered electric motors, rather than an internal combustion engine.

By using the DJI Phantom 3 UAS to perform aerial acquisitions, the substan tial risk to life and property in the air and on the ground, which is usually associated with

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traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI Phantom 3 UAS (weighing approximately 6 pounds 7.5 ounces at its maximum gross weight with a length of 17.3 inches, width of 17.7 inches, (and with no fuel on board), has less physical potential for collateral damage to life and prope rty on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

2. The Public Will Benefit From Decreased Congestion Of The NAS

.

The D JI Phantom 3 UAS is battery powered and serve s as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By r educing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJI Phantom 3 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.

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The
DJI Phantom 3 UA S do es not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video 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.

3. Perfo rming Aerial Video and Photography Operations With The DJI Phantom 3 UAS Will Benefit The Economy. In addition to being safe and efficient, the DJI Phantom 3 UA S is also an economical alternative to using manned aircraft to conduct similar aerial operation s. As such, ope ration of the DJI Phantom 3 UA S will allow United States based companies, like HUQA to remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agen cy (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies

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must adopt new and alternative technology in order to remain competitive. Operating the battery powered DJI Phantom 3 UAS is one such technology that not onl y allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft.

By operating the DJI Phantom 3 UAS, companies such as HUQA can remain competi tive and profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through commercial use of the DJI Phantom 3
UA S, 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.

4. There Are No Privacy Issues.
Similar to the manned aerial acquisition flight operations that have been conducted for many years, HUQA ’s proposed operation of the DJI Phantom 3 UAS will not implicate any privacy issues. Specifically, the DJI Phantom 3 UAS will be o perated only in compliance with operating documents (i.e., the HUQA Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual) which requires property owner involvement and permission to videotape/photograph as well as local l aw 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 HUQA LIVE, LLC Seeks Exemption.

i. Reasons Why The DJI Phantom 3 UA S Meet s The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333.

In consideratio n of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, HUQA ’s operation of the DJI Phantom 3 UAS

meet s the conditions of FMRA Section 333, and will not require an airworthiness
certificate in accor dance with 14 C.F.R. Part 21, Subpart H.

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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 otherwis e pose a threat to national security. Specifically, FMRA Section 333 states the following, in part: (a) In General.

-- Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act. (b) As sessment 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, prox imity 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 autho rization, 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 th is 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, H UQA submits that the DJI Phantom 3 UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI Phantom 3 UAS; 

### (b) the pilot certification requirement; and (c) the specific operating limitations.

a . The Specifications Of The DJI Phantom 3 UAS Demonstrate Its Safe
Characteristics.

The DJI Phantom 3 UAS do es not create a hazard to users of the NAS or the

### 17

public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability. Technical Specifications Of The DJI Phantom 3 UAS.

The technical specifications of the DJI Phantom 3 UA S are set forth by the DJI Phantom 3 User Manuals, attached hereto as Appendix A.

ii. The DJI Phantom 3 UAS Autonomous Flight And Navigation Modes Enable The UA S To Remain Within A Defined Operational Area.

The DJI Phantom 3 UA S may be operated in both manual and fully autonomous flight modes. A complete description of the flight and navigational modes of the DJI
Phantom 3 UAS i s provided at pages 45

- 50 of the DJI Phantom 3 User Manuals, attached hereto as Appendix A.

iii. The DJI Phantom 3 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 Link is lost, the DJI Phantom 3 UA S will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 3 UA S do es not reacquire control link data from the GCS, the UA S will assume that the Control Link is lost
and the UA S will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown. A complete description of the Failsafe Functions of the DJI Phantom 3 at pages 13 through 15 of the DJI Phantom 3 User Manuals,
attached hereto as Appendix A.

iv. The DJI Phantom 3 GCS And Its Operation.

A complete description of the operation and specifications of the DJI Phantom 3 GCS and flight control software is provided at pages 40 through 47 of the DJI Phantom 3
User Manual. DJI Phantom 3 User Manuals are attached hereto as Appendix A.

b. Flight Operations Of THE DJI Phantom 3 UAS Is Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer. RAAKIN IQBAL will be the only person to act as a pilot in command (P IC) of the
DJI Phantom 3 UA S . Additionally, a safety observer will assist in flights.

### 18

c. Flights Of DJI Phantom 3 UAS Will Be Conducted Pursuant To Specific Operating Limitations. In seeking this exemption, HUQA proposes to commercially operate DJI Phanto m 3 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 air craft described in the operating documents, rotorcraft UA S weighing less than 55 pounds maximum gross weight: DJI Phantom 3 Unmanned Aircraft Systems. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant.

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

3. The UA S may not be flown at an indicated airspeed exceeding 20 knots.

4. The UA must be operated at an alti tude of no more than 500 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved by ATC. All altitudes reported to ATC must be in feet AGL.

5. The UA S 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.

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

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

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

### 19

obstructions and is not permitted to operat e the camera or other instruments.

9. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, the operator must 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 revised documents if it petitions for extension or amendment to the grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendme nt to its grant of exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a

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

11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or fli ght characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make a n entry in the aircraft record.

### 20

12. The pre

- flight inspection must account for all potentia l discrepancies, e.g. inoperable components, items, or equipment, 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/overhaul 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 Sa fety 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 th e 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 pur poses of training 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 esse ntial for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119.

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1 .1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized.

20. The UAS 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

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

22. If the UAS 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 accordan ce with the operating documents.

23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents.

24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather co nditions) 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 operation. All operations shall be con ducted 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, registere d 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 a nd 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 any time the UAS is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

29. The UAS must remain clear and yield the right of way to all manned aviation operations and activit ies at all times.

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

31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than the PIC, SO, operator trainees or essential 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 within 500 feet of the UA, flight operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures where the

### 22

owner/contro ller of such vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, and;

c. Operations nearer to the PIC, SO, op erator 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.

33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by th e applicable COA must be reported to the FAA's UAS Integration Office (AFS

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

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

HUQA 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 P hantom 3 UA S unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and m aintaining appropriate distances from people, vessels,
vehicles and structures.

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

above; the parallel nature of private pilot aeronautical knowledge requirements to thos e of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI Phantom 3 UAS, HUQA LIVE, LLC submits that the additional manned airmanship experience of a commercially certificated pilot would no t correlate to the airmanship skills necessary for HUQA ’s 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 he rein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153,

### 23

11156, 11158, 11159, 11160, 11161).

HUQA will not allow any PIC to operate the DJI Phantom 3 UAS unless that PIC has demonstrated, by meeting minimum flight

- hour requirements or the DJI Phantom 3 UAS training and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 UAS in a manner consistent with this 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 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency pur poses).

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 HUQA ’s proposed operations. The Administrator has held th at 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 pict ure 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 minim um hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi

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

- hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills nece ssary to safely conduct the petitioner’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in

### 24

compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience

- build ing flights can also be conducted under the grant of exemption to accomplish the required flight time. During training, proficiency, and experience

- building flights the PIC is required to operate the UA with appropriate distances in accordance with 14 C.F. R 91.119.

Exemption No. 11138 at page 15.

Accordingly, HUQA LIVE, LLC will ensure safe operations by not allowing any PIC to operate the DJI Phantom 3 UAS unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that th e PIC is able to safely operate the DJI Phantom 3 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 Fro m 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, HUQA LIVE, LLC will ensure that the DJI Phantom 3 UAS is in an airwort hy 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 ma terial 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).

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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 Phantom 3 UA S will be provided to the PIC via GPS equipment and a
radio comm unications 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 HUQA ’s operation of the DJI Phantom 3 UA S within visual line of sight, at or below 500 fe et 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 UA S a t 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, 11112, 11 136, 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 establish ed by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJI Phantom 3 UA S ; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, HUQA will ensure that it will safely operate the battery powered DJI Phantom 3 UAS during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 14.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly aft er that for at least 4.5 minutes. Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 3 UAS; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of sa fety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Phantom 3 UAS provides audible and visual warnings to the PIC at the GCS when the UAS experiences low battery voltage, the first warning occurring at approximat ely 33% remaining battery power, and again at approximately 10% remaining battery power. At the critically low battery level, the Phantom 3 UAS will descend and land automatically.

### 26

Significantly, previous exemptions granted by the FAA concerning Section 9 1.151 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, inc luding Exempt ion Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 6. Reasons Why An Exemption From The 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, HUQA submits that the equivalent level of safety with regard to the regulatory maintenance and alteration requirements est ablished by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because HUQA will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and prac tices prescribed in the operating documents (i.e., the HUQA Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual). Furthermore, HUQA will document and maintain all maintenance records for the DJI Phantom 3
UAS.
Since the DJI Phantom 3 UAS will be inspected as prescribed by the operating documents, HUQA LIVE, LLC 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 Phantom 3 User Manuals is attache d hereto as Appendix A; a copy of the DJI Phantom 3 UAS Maintenance LOG is attached hereto as Appendix B.

Likewise, the exemption sought will not adversely affect safety because HUQA LIVE, LLC will use trained technicians to perform maintenance, alteratio ns or preventive maintenance on the UAS using the methods, techniques, and practices prescribed by the operating documents.

Furthermore, the exemption sought would maintain an equivalent level of safety established by Sections 91.407, 91.417(a) and 91.417 (b), because all maintenance of the DJI Phantom 3 UAS will be performed by trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log.

### 27

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

In consideration of HUQA ’s proposed operating limit ations, the operating documents, and the technical aspects of the DJI Phantom 3 UAS, HUQA LIVE, LLC submits that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2),
and 91.41 7(a) and (b). The FAA has previously granted relief specific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150 , 11153, 11156, 11157, 11158, 11159, 11160, 11161).

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

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions , HUQA requests that the FAA prescribe special conditions for the intended operation of the DJI Phantom 3 UAS, which contain s such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14
C .F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAS for the limited purpose of conducting aerial video and photography over certain areas of the United States for compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a
threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification in accordance with any requirements that must be established for the safe operation of the UAS in the NAS.
Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of the DJI Phantom 3 UAS, 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 featur es 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

### 28

or appropriate safety standards for an aircraft, aircraft engine, or prope ller because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and conta in 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 an d 14 C.F.R. § 21.16, the FAA may prescribe special conditions for Leading Edge’s intended operation of the Phantom 3 UAS, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that establish ed 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).

• A Summary That Can Be Published In The Federal Register, stating: The Rules From Which HUQA LIVE, LLC Seeks Exemption:

HUQA LIVE, LLC 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 HUQA LIVE, LLC Seeks:

This exemption will permit HUQA LIVE, LLC to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States.

• Any Additional Information, Views, Or Arguments Available To Support HUQA LIVE,
LLC ’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 cer tain UAS may operate safely in the NAS. As such, HUQA ’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.

### 29

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. As discussed in detail above, HUQA will operate the DJI Phantom 3 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, HUQA LIVE, LLC seeks an exemption pursuant to 14 C.F.R. § 11.61 and
Sectio n 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI Phantom 3 UAS commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography over certain area s of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing HUQA LIVE, LLC to safely, e fficiently, and economically operate the DJI Phantom 3 UAS commercially within the NAS.

WHEREFORE , in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, HUQA LIVE LLC 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 Leading Edge to operate the DJI P hantom 3 UAS commercially for the purpose of conducting aerial video and photography over certain areas of the United States.

Respectfully submitted on February 25, 2016
HUQA LIVE, LLC Attn. Raakin Iqbal 590 15 th ST S #400 Arlington, VA 22202

202

- 527

- 9342
riqbal@huqalive.com

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Appendices :

A

– DJI Phantom 3 Specifications Data Sheet

B

– Monthly Maintenance Log

D

- DJI Phantom Users Guide

APPENDIX

– A

DJI Phantom 3 TECHNICAL SPECIFICATIONS

HUQA LIVE, LLC only utilizes a safe and reliable UAS. DJI is an industry leader i n small UAS production. The DJI UAS is loaded with ground breaking software enabling the use r to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJI software p rovides real

- time altitude and location information to the PIC via the linked monitor (smart phone/tablet devices)

2.2 DJI Inspire 1

2.2.1 Aircraft

2.2.1.1 Model

– Phantom 3

2.2.1.2 Weight (Battery Included)

– 1280 grams

2.2.1.3 Hovering Accuracy (GPS Mode)

– Vertical: +/

- 10cm; Ho rizontal: +/

- 1m 2.2.1.4 Max Angular Velocity

– Yaw: 200 0 /s 2.2.1.5 Max Tilt Angle

- 35 2.2.1.6 Max Ascent Speed

– 5m/s
2.2.1.7 Max Descent Speed

– 3m/s

2.2.1.8 Max Speed

– 16m/s (ATTI mode, no wind

– NOT RECOMMENDED)

2.2.1.9 Max Flight Altitude

– 6000m

2.2.1.10 Max Flight Time

– Approximately 23 minutes

2.2.1.12 Motor Model

– DJI 3510

2.2.1.13 Propeller Model

– DJI 13 45 2.2.1.14 Operating Temperature Range

– 14 F to 104 F (

- 10 C to 40 C) 2.2.1.15 Dimensions

– 17 1⁄4 ” x 17 3⁄4 ” x 12”

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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 2.2.2.5 Mounting

– Detachable 2.2.2.6 Controllable Range

– Pitch:

- 90 to +30 ; Pan: ±320 2.2.2.7 Mechanical Range

– Pitch:

- 125 to 45 ; Pan: ±330 2.2.2.8 Max Controllable Speed

– Pitch: 120 /s; Pan: 180 /s
2.2.3 Camera

2.2.3.1 Name

– Sony EXMOR

2.2.3.2 Model

– 12.4M Pixel

2.2.3.3 Total Pixels

– 12.4M

2.2.3.4 Effective Pixels

– 12.76M

2.2.3.5 Image Max Size

– 4000x3000

2.2.3.6 ISO Range

– 100

- 3200 2.2.3.7 Field of View

- 94 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 F

- 104 F (0 C

- 40 C)
2.2.4 Transmitter

2.2.4.1 Name

– C1

2.2.4.2 Operating Frequency

– 5.728

- 5.850GHz; 2.400

- 2.483GHz

2.2.4.3 Communicating Distance (unobstructed)

– 2000m

2.2.4.4 Output Power

– 9W 2.2.4.5 Operating Temperature Range

- 14 F to 104 F (

- 10 C to 40 C) 2.2.4.6 Battery

– 600mAh LiPo 2S