1 UNITED	STATES	OF	AMERICA	DEPARTMENT	OF	TRANSPORTATION

FEDERAL	AVIATION	ADMINISTRATION	WASHINGTON,	DC

Regulatory	Docket	No.	_______________

IN	THE	MATTER	OF	THE	PETITION	FOR	EXEMPTION	OF: Alexander	Lange

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,	DJI	PHANTOM	2	VISION+,	A ND	DJI
INSPIRE	1	UNMANNED	AIRCRAFT	SYSTEMS	PURSUANT	TO	SECTION	333	OF	THE	FAA MODERNIZATION	AND	REFORM	ACT	OF	2012	(PUBLIC	LAW	112

- 95)

Submitted	on February 11 ,	2016

Alexander	Lange
Hover	With	Us |	Aerial	Imagery
13597	Tiverton	Road San	Diego,	CA	92130 (760) 473

- 4546 alexander@hover withus.com

www. hoverwithus .com2 

## TABLE OF CONTENTS

TABLE OF CONTENTS 2

GLOSSARY OF ABBREVIA TIONS 3

SUMMARY 4

I NTRODUCTION AND I NTEREST OF THE P ETITIONER 4

B ACKGROUND : DJI P HANTOM 3 5

BASIS FOR PETITION 6

SUPPORT OF PETITION 8

N AME & A DDRESS OF THE P ETITIONER

. 8

S PECIFIC S ECTION E XEMPTIONS R EQUESTS 8

R ECORD K EEPING 11

E XTENT OF R ELIEF 11

P UBLIC I NTEREST 15

S AFETY C ONSIDERATION 17

CONCLUSION 29

APPENDICES 303 

## Glossary of Abbreviations

AGL Above	Ground	Level

AOI Area	of	Interest

ATC Air	Traffic	Control

ATO Air	Traffic	Organization

AV Aerial	Vehicle

CFR Code	of	Federal	Regulations

COA Certificate	of	Authorization

FAA Federal	Aviation	Administration

FAR Federal	Aviation	Regulation

GCS Ground	Control	Station

GPS Global	Positioning	System

LOL Loss	of	Link

NAS National	Airspace	System

NOTAM Notice	to	Airman

PIC Pilot	In	Command

Section	333 FAA	Modernizatio n	and	Reform	Act	of	2012	(FMRA)

SO Safety	Observer

SOP Standard	Operating	Procedure s UA Unmanned	Aircraft

UAS Unmanned	Aircraft	System

VFR Visual	Flight	Rules

VLOS Visual	Line	of	Site

VMC Visual	Meteorological	Conditions

VTOL Vertical	Takeoff	and	Landing4 

## Summary

Alexander	Lange of Hover	With	Us hereafter	referred	to	as Alexander	Lange seeks	exemption from	the	requirements	of	14	C.F.R	§§	61.113(a)	&	(b),	91.7(a),	91.121,	91.151(b),	91.405(a), 91.407(a)(1),	91.409(a)(1)	&	(a)(2),	and	91.417(a)	&	(b),	to	operate	an	Unmanned	Aircraft System ( DJI	Pha ntom	3) pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act of	 2012	 (FMRA).	 This	 exemption	 will	 permit Alexander	 Lange to	 operate	 an	 Unmanned Aircraft	 System	 (UAS)	 for	 the	 commercial	 purpose	 of	 conducting	 aerial	 video	 and photography	of	constru ction	sites, residential	and	commercial real	estate, civil landscape s and	events over	certain	areas	of	the	United	States.



### Introduction and Interest of the Petitioner

Alexander	 Lange with	 his	 part	 time	 staff	 collectively	 have over 16	 years	 of	 aviation experience and	 five	 years’ experience	 providing	 clients with	 expertise	 and	 knowledge	in

multi media	marketing

, advertising

, events	and public	relations

. Alexander	Lange has	worked

dozens of commercial productions in the	past	in a	variety of	location s with a perfe ct client and	 employee safety	 record

. In	 the	 pas t we	 have	 suppl ied o u r	 clients aerial	 video	 and photography using	 commercial	 aircraft .	 The	 objective	 of Alexander	 Lange and our Unmanned	Aircraft	System	( DJI	Phantom	3) aerial	operations	is	to	provide a more	affordable

, high

- quality production	 system for	 a	 variety	 of governmental, commercial,	 public,	 and residential	uses,	specifically	targeting :

• Construction	sites	before	and	after

• Appraisals

• Real

- estate	marketing

• Economic	development

• Civic landmarks

• Speci al event	coverage

• Private	and	governmental	training

• Live	event	video	for	concerts	and	events

• Surf and	dive conditions5 

### Background : DJI Phantom 3

Alexander	Lange seeks an	exemption	to	operate	DJI Phantom	3 system for	compensation	or hire	within	the	NAS.	The	DJI	Phantom 3 is vertical	takeoff	and	landing	(VTOL)	Unmanned Aircraft	(UA)	with	a	Ground	Control	Station	(GCS)	utilizing	electronic	tablet	or	smart	phone systems.	 The	DJI	 Phantom 3 has	a	maximum	gross	weight	 of	approximately 2.8 lb. while having	a diagonal	 dimension	 of	 2 3.2” ,	a	maximum	 speed	 of	approximately 16.4’fps and	a

maximum flying height of	400'

. The	DJI	Phantom	3	is equipped with	four	main	rotors;	driven by	Lithium	Polymer	battery	powered	electric	motors.

The	DJI	Phantom 3 that	will	be	operated	by Alexander	Lange will	be	registered	in	accordance with	49	U.S.C.	44103, Registration	of	Aircraft ,	as	well	as	14	C.F.R	Part	47, Aircraft	Registration

, and	marked	in	accordance	with	14	C.F.R.	Part	45, Identification	and	Registration	Marking

.6 

## Basis for Petition

Petitioner, Alexander	Lange ,	pursuant	to	the	provisions	of	the	Federal	Aviation	Regulations (14	C.F.R.	§	11.61)	and	the	FAA	Modernization	and	Reform	Act	of	2012	(FMRA),	Section	333, Special	Rules	for	Certain	Unmanned	Aircraft	Systems ,	hereby	petitions	the Administrator	to commercially	operate	the	DJI	Phantom 3

, UAS in	the	National	Airspace	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	9 1.417(a)	&	(b).

In	consideration	of	the	speed,	weight,	size,	and	limited	operating	area	associated	with	the unmanned	aircraft	and	its	operation, Alexander	Lange operation	of	DJI	Phantom 3 UAS meets the	 conditions	 of	 FMRA	 Section	 333	 and	 therefore,	 will	 no t	 require	 an	 airworthiness certificate	in	accordance	with	14	C.F.R.	Part	21,	Subpart	H.

Accordingly, Alexander	 Lange requests	 relief	 from	 Sections	 91.405(a),	 91.407(a)(1), 91.409(a)(1)	 &	 (a)(2),	 and	 91.417(a)	 &	 (b),	 as	 these	 sections	 set	 forth	 requirement s	 for maintenance	that	only	apply	to	aircraft	with	an	airworthiness	certificate.

Alexander	 Lange submits	 that	 the	 requested	 relief	 is	 proper	 since	 an	 equivalent	 level	 of safety	will	be	ensured. Alexander	 Lange will	use	experienced	personnel	 or	 technicians	 to perform	maintenance,	alterations,	or	preventive	maintenance	on	the	UAS	using	the	methods, techniques,	and	practices	prescribed	in	the	operating	documents	(i.e.,	Monthly	Maintenance Log,	and	DJI	Phantom 3 Ins truction	Manual).	Furthermore, Alexander	Lange will	document and	maintain	all	maintenance	records	for	the	DJI	Phantom 3 UAS.

Relief	from	certain	requirements	of	Section	61.113(a)	and	(b),	entitled Private	pilot	privileges

and	limitations:	Pilot	in	command ,	is	requested	by Alexander	Lange 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	ab le	to	safely	operate	the	DJI	Phantom	UAS in	a	manner	consistent	with	 this	exemption,	including	evasive	and	emergency	maneuvers and	maintaining	appropriate	distances	from	people,	vessels,	vehicles	and	structures.

Alexander	 Lange seeks	 relief	 from	 Section	 9 1.7(a),	 entitled Civil	 aircraft	 airworthiness

, because	 the DJI	Phantom	3	UAS do	not	require	an	airworthiness	certificate	in	accordance with	14	C.F.R.	Part	21,	Subpart	H.	As	such, Alexander	Lange submits	that	they will	ensure that	the	DJI	Pha ntom	3 UAS is i n	an	airworthy	condition,	prior	to	every	flight,	by	determining

that	the UAS are	in	compliance	with	the	operating	documents	(i.e.,	Monthly	Maintenance	Log, and	DJI	Phantom 3 Instruction	Manual),	and	that	the	aircraft	are	in	a	condition	for	safe	flight.

Al exander	Lange also	seeks	an	exemption	from	the	requirements	of	Section	91.121,	entitled Altimeter	Settings ,	as	 the	DJI	Phantom 3 UAS will	not	have	a	 typical	 barometric	altimeter onboard.	However,	altitude	information	of	the	DJI	Phantom 3 UAS will	be	provid ed	to	the	PIC via	Global	Positioning	System	(GPS)	equipment	and	radio	communications	telemetry	data7 link,	which	downlinks	from	the	UA	to	the	GCS	for	active	monitoring	of	the	flight	path.	This altitude	information,	combined	with Alexander	Lange ’s	operation of	the DJI	Phantom	3	UAS within	visual	line	of	sight,	at	or	below 4 00	feet	AGL,	will	ensure	a	level	of	safety	equivalent

to	Section	91.121.

Additionally, Alexander	 Lange seeks	 an	 exemption	 from	 the	 requirements	 of	 Section 91.151(b),	entitled Fuel	requirem ents	for	flight	in	VFR	conditions

. Alexander	Lange submits that	safety	will	not	be	affected	by	operation	of	the	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	 approximately 23 minutes .	 	 Battery	 power indicators	are	also	able	to	show	exactly	how	much	battery	po wer	is	left,	as	well	as	how	much time	is	needed	to	return	safely	back	to	point	of	take	off.8 

## Support of Petition

In	accordance	with	14	C.F.R.	§	11.81, Alexander	Lange provides	the	following	information in	support	of	its	petition	for	exemption:



### Name & Address of the Petitioner.

Alexander	Lange

Owner
Hover	With	Us |	Aerial	Imagery

13597	Tiverton	Road San	Diego,	CA	92130

760

- 473

- 4546
alexander@hover withus.com



### Specific Section Exemptions Requests

1. Alexander	Lange 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

connec tion	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. Alexander	Lange Seeks	Exemption from The	Requirements of Section	91.7(a).

Section	91.7,	entitled Civil	aircraft	airworthiness ,	subsection	(a),	states	the	following:

(a)	No	person	may	operate	a	civil	aircraft	unless	it	is	in	an	airworthy	condition.

3. Alexander	Lange Seeks	Exemption from The	Requirements of S ection	91.121.

Section	91.121,	entitled Altimeter	settings ,	subsection	(a),	states	the	following,	in	part:9 (a)	Each	person	operating	an	aircraft	shall	maintain	the	cruising	altitude	or	flight level	of	that	aircraft,	as	the	case	may	be,	by	reference	to	an altimeter	that	is	set, when	operating

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

--
(i)	The	current	reported	altimeter	setting	of	a	station	along	the	route	and within	100	nautical	miles	of	the	aircraft;

(ii)	If	there	is	no	station	within	the	area	prescribed	in	par agraph	(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	availab le	before departure.

4. Alexander	Lange 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. Alexander	Lange Seeks	Exemption from The	Requirement of Section	91.405(a).

Section	91.405,	entitled Maintenance	 required ,	 subsection	 (a),	 states	 the	 following: Each	owner	or	operator	of	an	aircraft

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

6. Alexande r	Lange 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[.]10 7. Alexander	Lange Seeks	Exemption from The	Requirements of Sections	91.409(a)(1) And	91.409(a)(2).

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

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

--
(1)	An	annual	inspection	in	accordance	with	part	43	of	this	chapter	and	has been	approved	for	return	to	service	by	a	person	authorized	by	§	43.7	of	this chapter;	or

(2)	An	inspection	for	the	issuance	of	an	airworthiness	certificate	in	accordance with	part	21	of	this	chapter.

8. Alexander	Lange Seeks	Exemption from The	Requirements of Sections	91.417(a) And	91.417(b).

Section	 91.417,	 entitled Maintenance	 records ,	 su bsections	 (a)	 and	 (b),	 state	 the following:

(a)	Except	 for	work	performed	in	accordance	with	 §§	91.411	and	91.413,	each registered	 owner	 or	 operator	 shall	 keep	 the	 following	 records	 for	 the	 periods specified	in	paragraph	(b)	of	this	section:

(1)	Records of	the	maintenance,	preventive	maintenance,	and	alteration	and

records	of	the	100

- hour,	annual,	progressive,	and	other	required	or	approved inspections,	as	appropriate,	for	each	aircraft	(including	the	airframe)	and	each engine,	 propeller,	 rotor,	 and	 appli ance	 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)	 Th e	 current	 status	 of	 life

- limited	 parts	 of	 each	 airframe,	 engine, propeller,	rotor,	and	appliance.11 (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	in spection	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	dire ctives	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(d)	of	this	chapter	for	each major	alteration	 to	 the	airframe	and	currently	installed	engines,	rotors, propellers,	and	appliances.



### Record Keeping

The	 owner	 or	 operator	 shall	 retain	 the	 following	 records	 for	 t he	 periods prescribed:

1. The	records	specified	in the	above 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 the	above section	shall	be	retained	and	t ransferred

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	servi ce.



### Extent of Relief

1.	 Extent of Relief Alexander	 Lange Seeks and The	 Reason Alexander	 Lange 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	met12 certain	 flight

- hour	 and	 currency	 requirements,	 to	 conduct	 the	 proposed	 UAS flight operations	for	compensation	or	hire.

This	relief	is	requested	since	the	limitations	set	forth	in	Section	61.113(a)	and	(b)	state	that a	private	pilot	may,	for	compensation	or	hire,	act	as	PIC	of	an	aircraft	in	connection	with	any business	or	emplo yment	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, Alexander	Lange submits	that	an	equivalent	level	of	safety	will be	maintained	because	no	PIC	will	be	allowed	to	operate	the	DJI	Phantom 3 UAS	unless	that PIC	has	met	certain	 flight

- hour	and	currency	requirements,	demonstrating	 that	 the	PIC	is able	 to	 safely	 operate	 either	 the	 DJI	 Phantom 3 UAS	 in	 a	 manner	 consistent	 w ith	 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, Alexander	Lange submits	that	all	flights	of	th e	DJI	Phantom 3 UAS ,	conducted	by	the PIC	 pursuant	 to	 the	 grant	 of	 this	 Petition:	 (1)	 will	 be	 incidental	 to Alexander	 Lange ’s business;	and	(2)	will	not	carry	passengers	or	property	for	compensation	or	hire.

2.	 Extent of Relief Alexander	 Lange Seeks and The	 Reason Alexander	 Lange 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 Alexander	Lange to	determine	that	the DJI	Phantom	3	UAS are	in	airworthy

conditi on	prior	to	every	flight	by	ensuring	that	the	UAS	is	in	compliance	with	the	operating documents	(i.e., the Hover	With	Us Aerial	Operations	Manual,	Monthly	Maintenance	Log,	and DJI	Phantom 3 Instruction	Manual).

Alexander	Lange seeks	the	requested	relief	b ecause	the DJI	Phantom	3	UAS do	not	require an	 airworthiness	 certificate	 in	 accordance	 with	 14	 C.F.R.	 Part	 21,	 Subpart	 H.	 Therefore, Alexander	Lange will	ensure	that	the DJI	Phantom	3	UAS are	in	airworthy	condition	based upon	its	compliance	with	the	operating	documents	(i.e.,	Monthly	Maintenance	Log,	and	DJI

Phantom 3 )	prior	to	every	flight,	and	further,	determine	that	the	aircraft	are	in	condition	for safe	flight,	as	stated	in	the	conditio ns	and	limitations	below.

3.	 Extent of Relief Alexander	 Lange Seeks and The	 Reason Alexander	 Lange 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	 telemetry	 data	 link	 to	 downlink	 altitude information	 from	 the	 UA	 to	 the	 PIC	 at	 the	 ground	 control	 station	 (GCS).	 Since	 the	 FAA13 requires	that	any	altitude	information concerning	UAS	operations	be	reported	to	air	traffic control	(ATC)	in	feet	above	ground	level	(AGL), Alexander	Lange seeks	the	requested	relief

because	the DJI	Phantom	3 UA’s	altimeter	may	be	set	on	the	ground	to	zero	feet	AGL,	rather than	the	local	barometric	pressure	or	field	altitude,	before	each	flight.

Considering	 the	limited	altitude	of	 the	proposed	operations,	 relief	 from	14	CFR	91.121	is sought	 to	 the	 extent	 neces sary	 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 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 Alexander	 Lange Seeks and The	 Reason Al exander	 Lange 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 23 minutes. Alexander	Lange 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 still	 photo	 flight	 operations	 that Alexander	 Lange proposes	 to	 conduct	 pursuant	 to	 this

Petition.

Significantly,	as	set	forth	below,	the	technical	spe cifications	of	the DJI	Phantom	3	UAS ,	the DJI	Phantom	3 operating	documents,	and Alexander	Lange ’s	proposed	operating	limitations,

ensure	 that Alexander	 Lange will	safely	 operate	 the	battery	powered DJI	Phantom	3 UAS during	daylight	hours	in	visual	meteoro logical	conditions	 (VMC),	under	visual	 flight	rules (VFR),	with	enough	battery	power	to	fly	for	a	total	duration	of 23 minutes

.

5.	 Extent of Relief Alexander	 Lange Seeks and The	 Reason Alexander	 Lange 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, Alexander	 Lange requests	 relief	 fro m these	Sections	because	the DJI	Phantom	3	UAS do	not	require	airworthiness	certificates.	As set	forth	more	fully	below,	the DJI	Phantom	3	UAS meet	the	conditions	of	FMRA	Section	333 for	 operation	without	an	airworthiness	 certificate.	Accordingly, Alexande r	 Lange will	 use trained	technicians	to	perform	maintenance,	alterations,	or	preventive	maintenance	on	the

UAS using	 the	 methods,	 techniques,	 and	 practices	 prescribed	 in	 the	 UAS	 operating14 documents	(i.e.,	the Alexander	Lange Aerial	Operations	Manual,	Monthly	Maintenance	Log,

and DJI	Phantom	3 Instruction	Manual).	Furthermore, Alexander	Lange will	document	and

maintain	all	maintenance	records	for	the DJI	Phantom	3 UAS

.15 

### Public Interest

Granting	the	present	Petition	will	furt her	the	public	interest	by	allowing Alexander	Lange to safely,	efficiently,	and	economically	perform	aerial	video	and	photography	of	construction sites,	real	estate, events and civic 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 Alexander Lange ’s	proposed	operation	of	the DJI	Phantom	3	UAS will	be	realized	without	implicating

any	pr ivacy	issues.

1.	The	Public	Will	Benefit from Decreased	Congestion of The	NAS.

The DJI	Phantom	3 UAS are	battery	powered	and	serve	as	a	safe,	efficient,	and	economical alternative	to	the	manned	aircraft	traditionally	utilized	to	obtain	aerial	imagery.	By	reducing the	amount	of	manned	aircraft	needed	to	perform	aerial	acquisitions,	an	exemption	allowing

t he	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	o perating	in	the	NAS,	congestion around	airports	caused	by	arriving	and	departing	aircraft	will	be	reduced.	The DJI	Phantom

3 UAS do	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.

2.	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	 levels	 of	 air	 and	 noise	 pollution generated	during	traditional	aerial	video	and	still	photography	 flight	o perations.	By	using battery	power	and	electric	motors,	the DJI	Phantom	3	UAS produce	no	air	pollution,	and	is the	 most	 viable	 environmentally	 conscious	 alternative	 to	 the	 cabin	 class, six

- cylinder internal	 combustion	 engine	 aircraft	 that	 are	 typically	 utilized	 for	 aerial	 video	 and photography,	while	burning	approximately	20

- 30	gallons	per	hour	of	leaded	aviation	fuel.

The DJI	 Phantom	 3 UAS ,	 while	 reducing	 the	 carbon	 footprint	 of	 aerial	 acquisitions ,	 also eliminates	 noise	 pollution,	 as	 the UAS are	 propelled	 by	 battery	 powered	 electric	motors, rather	than	an	internal	combustion	engine.16 By	using	the DJI	Phantom	3	UAS to	perform	aerial	acquisitions,	the	substantial	risk	to	life	and property	in	the	air and	on	the	ground,	which	is	usually	associated	with	traditional	manned aircraft	flight	operations,	will	be	substantially	reduced	or	completely	eliminated.	Aside	from the	 lack	 of	 flight	 crew	 members	 located	 onboard	 the	 aircraft,	 the DJI	 Phantom	 3 UAS (weigh ing	 approximately	 2 .8 pounds at	 their	 maximum	 gross	 weight with diagonal

dimension	of	23.2	inches ,	and	with	no	fuel	on	board),	has	less	physical	potential	for	collateral damage	to	life	and	property	on	the	ground,	and	in	the	air,	compared	to	the	manned	airc raft 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).

3.	Performing	Aerial	Video	and	Photography	Operations with The DJI	Phan tom	3	UAS
Will	Benefit the Economy.

In	 addition	 to	 being	 safe	 and	 efficient,	 the DJI	 Phantom	 3	 UAS are	 also	 an	 economical alternative	to	using	manned	aircraft	to	conduct	similar	aerial	operations.	As	such,	operation

of	the DJI	Phantom	3	UAS will	allow	United	States	based	companies,	like Alexander	Lange ,	to remain	competitive	and	contribute	to	growth	of	the	U.S.	economy.	Specifically,	with	the	rising cost	of	aviation	 fuel	and	 the	Environmental	Protection	Agency	 (“EPA”)	regulatory	actions phasi ng	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
Phantom	3	UAS is	one	such	technology	that	not	only	allows	companies	greater	operatio nal 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 Alexander	 Lange ,	 can	 remain competitive	 and	 profitable,	 an d	 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 UAS, provides	a	stable	wo rkforce	 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 decades, Alexander	Lange ’s	proposed	operation	of	the DJI	Phantom	3	UAS will	not	implicate any	privacy	issues.	Specifically,	the DJI	Phantom	3	UAS will	be	operated	only in	compliance with	 operating	 documents	 (i.e.,	 the Hover	 With	 Us Aerial	 Operations	 Manual,	 Monthly Maintenance	Log,	and DJI	Phantom	3 Instruction	Manual)	which	requires	property	owner involvement	 as	 well	 as	 local	 law	 enforcement	 notification,	 and	 in	 accorda nce	 with	 the Federal	Aviation	Regulations,	including	 the	minimum	altitude	requirements	of	14	C.F.R.	§

91.119.17 

### Safety Consideration

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

In	consideration	of	the	size,	weight,	speed,	and	limited	operating	area	associated	with	the unmanned	aircraft	and	its	operation, Alexander	Lange ’s	operation	of	the DJI	Phantom	3	UAS

meet	th e	conditions	of	FMRA	Section	333,	and	will	not	require	an	airworthiness	certificate in	accordance	with	14	C.F.R.	Part	21,	Subpart	H.

Section	333	provides	authority	for	a	UAS	to	operate	without	airworthiness	certification	and sets	forth	requirements	for	co nsidering	whether	a	UAS	will	create	a	hazard	to	users	of	the NAS	or	the	public,	or	otherwise	pose	a	threat	to	national	security.	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	sy stem	before	completion	of	the	plan	and	rulemaking required	by	section	332	of	this	Act	or	the	guidance	required	by	section	334	of	this

Act.

(b)	Assessment	of	Unmanned	Aircraft Systems.

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

--
(1)	which	types	of	unmanned	aircraft	systems,	if	any,	as	a	result	of	their	size, weight,	 speed,	 operational	capability,	 proximity	 to	 airports	 and	 populated areas,	 and	 operation	 within	 visual	line	 of	 sight	 do	 not	 create	 a	 hazard to users	 of	 the	 national	 airspace	 system	 or	 the	 public	 or	 pose	 a	 threat	 to national	security;	and

(2)	 whether	 a	 certificate	 of	 waiver,	 certificate	 of	 authorization,	 or airworthiness	 certification	 under	 section	 44704	 of	 title	 49,	 United	 States Code,	is	requ ired	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

sy stem,	 the	 Secretary	 shall	 establish	 requirements	for	 the	 safe	 operation	 of	 such aircraft	systems	in	the	national	airspace	system.

In	seeking	this	exemption, Alexander	Lange 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.18 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	 public,	 or otherwise	 pose	 a	 threat	 to	 national	 security	 considering	 its	 size,	 weight,	 speed,	 and operational	capability.

i.	Technical	Specifications of The DJI	Phantom	3 UAS

.

The	t echnical	specifications	of	the DJI	Phantom	3	UAS are	set	forth	by	the DJI	Phantom	3 Use r Manual ,	att ached	hereto	as	Appendix	A

.

ii.	The DJI	Phantom	3	UAS Global	Positioning	Modes	Enable	The	UAS to Remain
Within a Defined	Operational	Area.

The DJI	Phantom 3	UAS may	be	operated	in	both	manual	and global	positioning flight	modes. A	 complete	 description	 of	 the	 flight	and	 navigational	modes	 of	 the DJI	 Phantom	 3	UAS is provided	at	pages 11	of	the	DJI	Phantom	3 User	Manual att ached	hereto	as	Appendix	A

.

iii.	The DJI	Phantom	3	UAS Are	Designed for Automatic	Return to Home	Point

or Hover in The	Event of Loss of the Control	Link or Navigation.

When	the	Control	Link	is	lost,	the DJI	Phantom	3 UAS will	remain	stationary,	in	flight,	for	3 seconds	or	more.	If, after	3	seconds,	the DJI	Phantom	3 UAS do es not	reacquire	control link data	from	the	GCS,	the	UAS will	assume	that	the Control	Link	is	lost	and	the 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	Failsaf e	Functions	of	the	DJI	Phantom	3 UAS	are	set	forth	at

pages 12 through 14 of	the DJI	Phantom	3 Use r	Manual,	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 23 through 29	of	the	DJI	Phantom	3 U ser Manual. DJI	Phantom	3 User	Manual is att ached	hereto	as	Appendix	A

. b.	Flight	Operations of DJI	Phantom	3	UAS Is Limited to The	Line of Sight of a Certificated	Pilot	in	Command with A	Safety	Observer.

Alexander	 Lange ’s video	 production	 staff will be	 the	 only	 person s to	 act	 as	 a	 pilot	 in command	(PIC)	of	the DJI	Phantom	3 UAS .	Additionally,	a	safety	observer	will	assist	him at
all	times during	flight	time.

c.	Flights of DJI	Phantom	3	UAS Will	Be	Conducted	Pursuant to Specific	Operating

Limitations.

In	seeking	this	exemption, Alexander	Lange proposes	to	commercially	operate DJI	Phantom

3	UAS for	the	special	purpose	of	conducting	aerial	video	and	photography	over	certain areas	of	United	States,	pursuant	to	the	followin g	specific	operating	limitations

.19 1.	Operations	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’ maximum	gross	weight: DJI	Phantom	3 Unmanned	A ircraft	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	altitude	of	no	more	than 4 00	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 UAS must	 be	 operated	within	 visual	line	 o f	 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	communicate	verball y	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	t he	functions	prescribed	in	the operating	documents.

8.	The	SO	must	not	perform	any	other	duties	beyond	assisting	the	PIC	with	seeing and	avoiding	other	air	traffic	and	other	ground	based	obstacles/obstructions	and is	not	permitted	to	operate	the	camera	or other	instruments.

9.	The	operating	documents	and	the	grant	of	exemption	must	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	 do cuments.	 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	 for20 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	 amendment	 to	 its	 gra nt	 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

condition	for	safe	fl ight.	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	Contr ol	Station	must	be	included	in	the	preflight	inspection.	All maintenance	 and	 alterations	 must	 be	 properly	 documented	 in	 the	 aircraft

records.

11.	Any	UAS	that	has	undergone	maintenance	or	alterations	that	affect	the	UAS operation	or	flight	characteristics ,	e.g.	replacement	of	a	flight	critical	component, 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	 discrepancie s,	 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	l imit	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 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	 unde r	 the exemption,	 including	 evasive	 and	 emergency	 maneuvers	 and	 maintaining appropriate	 distances	 from	 persons,	 vessels,	 vehicles	 and	 structures.	 PIC21 qualification	flight	hours	must	be	logged	in	a	manner	consistent	with	14	C.F.R.	§ 61.51(b).	Flights	 for	 the purposes	of	 training	 the	operator’s	PICs	are	permitted under	 the	 terms	 of	 the	 exemption.	 However,	 training	 operations	 may	 only	 be conducted	 during	 dedicated	 training	 sessions.	During	 training,	 proficiency,	and experience

- building	 flights,	 all	 persons	 not essential	 for	 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 (S VFR)	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	 i s 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	a	pre

determined	location	within	the	planned	operating	area	and	land	or	be	reco vered in	accordance	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	win d	and forecast	 weather	 conditions)	 there	 is	 enough	 power	 to	 fly	 at	 normal	 cruising speed	 to	 the	intended	landing	 point	 and	land	 the	UA	with	 25%	 battery	 power remaining.

25.	The	operator	must	obtain	an	Air	Traffic	Organization	(ATO)	issued	Certificate

of	W aiver	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	 conducted	 in	 accordance	 with airspace	requirements	in	the	ATO	issued	COA	including	class	of	airspace,	altitude level	and	potential	transponder	requirements.22 26.	All	aircraft	operated	in	accordance	with	the	exemption	must	be	ident ified	by serial	 number,	 registered	 in	 accordance	 with	 14	 C.F.R.	 part	 47,	 and	 have identification	(N

- Number)	markings	in	accordance	with	14	C.F.R.	part	45,	Subpart C.	Markings	must	be	as	large	as	practicable.

27.	 Before	 conducting	 operations,	 the	 radio	 fr equency	 spectrum	 used	 for operation	and	control	of	the	UA	must	comply	with	the	Federal	Communications Commission	 (FCC)	 or	 other	 appropriate	 government	 oversight	 agency requirements.

28.	 The	 documents	 required	 fewer	 than	 14	 C.F.R.	 91.9	 and	 91.203	 must	 be available	to	the	PIC	at	the	Ground	Control	Station	of	the	UAS	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	(persons	other	than	the	PIC,	SO,	operator	trainees	or	essential	persons), vessels,	vehicles,	and	structures	unless:

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

c.	Operations	nearer	to	the	PIC,	SO,	operator	trainees	or	essential	persons do	not	present	an	undue	hazard	to	those	pe rsons	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	the	applicable	COA	must23 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 Exemption from The	Requirements of Section	61.113(a)	And	(b)

Would	Not Adversely	Affect	Safety.

Alexander	Lange 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	Phantom	3	UAS unless	 that	 PIC	 has	 demonstrated,	 by	 meeting	 m inimum	 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 maintaining	appropriate	distances	from	people,	vessels,	vehi cles	and	structures.

Considering Alexander	Lange ’s	proposed	area	of	operations,	and	the	operating	limitations

set	forth

- above;	the	parallel	nature	of	private	pilot	aeronautical	knowledge	requirements	to those	 of	 commercial	 pilot	 requirements	 ( See Exemptio n	No.	 11062);	 and	 the	 airmanship skills	necessary	to	safely	operate	the	DJI	Phantom 3 UAS, Alexander	Lange submits	that	the additional	manned	 airmanship	 experience	 of	 a	 commercially	 certificated	 pilot	 would	 not correlate	to	the	airmanship	skills	necessary	for Alexander	Lange ’s	specific	proposed	flight operations.

The	 FAA	 has	 previously	granted	 relief	 from	Sect ion	 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).

Alexander	Lange 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	safe ly	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	log ged,	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	 add ition	 to	 the	 hour	 requirements,	 the	 PIC	 must accomplish	3	takeoffs	and	landings	in	the	preceding	90	days	(for	currency	purposes).

As	in	Exemption	Nos.	11062,	11138,	and	11153,	prior	documented	flight	experience	that	was obtained	in	compliance	with	applica ble	regulations	will	ensure	an	equivalent	level	of	safety during Alexander	 Lange ’s	 proposed	 operations.	 The	 Administrator	 has	 held	 that	 prior24 documented	flight	experience	that	was	obtained	in	compliance	with	applicable	regulations would	ensure	safe	operati ons,	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	ope rating	the same	make	and	model	 of	UAS	 to	be	used	 for	 operations	under	 the	exemption.	For clarification,	 the	 FAA	 considers	 these	minimum	 hour	 requirements	 to	 be	inclusive rather	 than	additive;	i.e.	 5	 hours	make	and	model	 time	may	 be	included	in	 the	 10

hours of	multi

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

that	 a t	 a	 minimum,	 the	 flight

- hour	 requirements	 in	 Exemption	 No.	 11062	 are appropriate	to	practice	and	build	proficiency	in	the	skills	necessary	to	safely	conduct the	petitioner’s	proposed	operations.	The	FAA	also	finds	that	prior	documented	flight experience	th at	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,	 pro ficiency,	 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, Alexander	Lange 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	the	PIC	is	able	to	safely	operate	the	DJI	Phantom 3 UAS	in	a

manner	 consis tent	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, Alexander	Lange will	ensure	that	the	DJI	Phantom 3 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

circumstanc es	 similar,	in	all	material	 respects,	 to	 those	 presented	 herein	 (e.g.	 Exemption25 Nos.	 11062,	 11063,	 11064,	 11065,	 11066,	 11067,	 11080,	 11109,	 11110,	 11112,	 11136, 11138,	11150,	11153,	11156,	11157,	11158,	11159,	11160,	11161).

4.	Reasons	Why an Exemption from The	Requirements of Section	91.121	Would	Not Adversely	Affect	Safety.

The	equivalent	level	of	safety	established	by	Section	91.121	will	be	maintained	because	the

altitude	information	of	the DJI	Phantom	3 UAS will	be	provided	to	the	PIC	via	GPS	equipme nt 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 Alexander	Lange ’s	operation	of	the DJI	Phantom	3 UAS within	visual	lin e	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	automati cally	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,	11112,	11136,	11138,	11150,	11153, 11156,	11157,	11158,	11159,	11160,	11161).

5.	Reasons	Why an Exemption from The	Requirements of Section	91.151(b)	Would	Not Adversely	Affect	Safety.

A	grant	of	this	exemption	would	ensure	an	equivalent	level	of	safety	established	by	14	C.F.R. Section	91.151(b)	as	a	result	of	(1)	the	technical	specifications	of	the DJI	Phantom	3 UAS ;	(2) the	limitations	on	the	proposed	flight	operations;	and	(3)	the	loc ation	of	the	proposed	flight operations.	Accordingly, Alexander	Lange 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 23 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	 safety	 established	 by	 14	 C.F.R.	 Se ction	 91.151(b). Furthermore,	safety	will	be	ensured	as	the DJI	Phantom	3	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

Phantom 3 UAS	will	descend	and	land	automatically.

Significantly,	previous	exemptions	granted	by	the	FAA	concerning	Section	91.151	establish that	 safety	 i s	 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.	 2689,26 5 745,	 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,	 1 1066, 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, Alexander	Lange 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 Alexander	 Lange 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. ,	 the Hover	 With	 Us Aerial	 Operations	 Manual,	 Monthly Maintenance	Log,	and DJI	Phantom	3 Instruction	Manual).	Furthermore, Alexander	Lange

will	document	and	maintain	all	maintenance	records	for	the DJI	Phantom	3 UAS.

Since	the DJI	Phantom	3	UAS will	be	in spected	as	prescribed	by	the	operating	documents, Alexander	 Lange 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	are attached	hereto	as	Appendix	A	and B;	a	copy	of	the DJI	Phantom	3 UAS	Maintenance	LOG	is attached	hereto	as	Appendix	C.

Likewise,	the	exemption	sought	will	not	adversely	affect	safety	because Alexander	Lange will use	trained	technicians	to	perform	maintenance,	alterations	or	preventive	ma intenance	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	ma intenance	of	the DJI	Phantom	3

UAS will	 be	 performed	 by	 trained	 technicians.	 Maintenance	 will	 be	 documented	 and maintained	utilizing	the	monthly	maintenance	log.

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

are	considered.

In	 consideration	 of Alexander	 Lange ’s	 proposed	 operating	 limitations,	 the	 operating documents,	and	the	technical	aspects	of	the DJI	Phantom	3 UAS

, Alexander	Lange submits that	 safety	 will	 not	 be	 adversely	 affected	 by	 granting	 exemption	 from	 14	 C.F.R.	 Sections 91.405(a),	 91.407(a)(1)	 and	 (a)(2),	 91.409(a)(2),	 and	 91.417(a)	 and	 (b).	 The	 FAA	 has27 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 f or 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

, Alexander	 Lange requests	 that	 the	 FAA prescribe	 special	 conditions	 for	 the	intended	 operation	 of	 th e DJI	 Phantom	 3 UAS ,	which contain	such	safety	standards	that	the	Administrator	finds	necessary	to	establish	a	level	of safety	 equivalent	 to	 that	 established	 by	 14	 C.F.R.	 Part	 21,	 Subpart	 H,	 and	 14	 C.F.R	 §§ 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	 h ire.	 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	 air worthiness	 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	Phanto m	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	features	of	the	aircraft.	Section	21.16,	entitled Special	Conditions ,	states	the following:

If	th e	FAA	finds	that	the	airworthiness	regulations	of	this	subchapter	do	not	contain adequate	or	appropriate	safety	standards	for	an	aircraft,	aircraft	engine,	or	propeller because	 of	 a	 novel	 or	 unusual	 design	 feature	 of	 the	 aircraft,	 aircraft	 engine	 or propel ler,	he	prescribes	special	conditions	and	amendments	thereto	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	 nec essary	 to	 establish	 a	 level	 of	 safety	 equivalent	 to	 that	 established	 in	 the regulations.

See 14	C.F.R.	§	21.16.

Therefore,	 in	 accordance	 with	 FMRA	 Section	 333	 and	 14	 C.F.R.	 §	 21.16,	 the	 FAA	 may prescribe	special	conditions	for	Leading	Edge’s	intended	oper ation	of	the DJI	Phantom	3 UAS

, which	contain	such	safety	standards	 that	 the	Administrator	 finds	necessary	 to	establish	a level	of	safety	equivalent	 to	 that	established	by	14	C.F.R.	Part	21,	Subpart	H,	and	14	C.F.R Sections	61.113(a)	&	(b),	91.7(a),	91.121 ,	91.151(b),	91.405(a),	91.407(a)(1),	91.409(a)(1) &	(a)(2),	and	91.417(a)	&	(b).28 A	Summary	That	Can	Be	Published in The	Federal	Register,	stating:	The	Rules from

Which Alexander	Lange Seeks	Exemption:

Alexander	 Lange 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 Alexander	Lange Seeks:

This	 exem ption	 will	 permit Alexander	 Lange 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 Alexander Lange ’s Request.

This	Petition	is	made	pursuant	to	the	FAA	Modernization	and	Reform	Act	of	2012

(FMRA)	Section	333,	which	directs	the	Secretary	of	Transportation	to	determine	if	certain UAS	may	operate	safely	in	the	NAS.	As	such, Alexander	Lange ’s	request	for	exemption	may be	granted	pursuant	to	the	authority	of	FMRA	Section	333	and	14	C.F.R.	Part	11,	as	set	forth

above.

FMRA	Section	333	sets	forth	the	requirements	for	considering	whether	a	UAS	will	create	a

hazard	to	users	of	the NAS	or	the	public,	or	otherwise	pose	a	threat	to	national	security;	and further,	provides	the	authority	for	such	UAS	to	operate	without	airworthiness	certification.

As	discussed	in	detail	above, Alexander	Lange will	operate	the DJI	Phantom	3	UAS safely	i n the	NAS,	without	creating	a	hazard	to	users	of	the	NAS,	or	the	public,	or	otherwise	pose	a threat	to	national	security.29 

## CONCLUSION

As	set	forth	herein, Alexander	Lange seeks	an	exemption	pursuant	to	14	C.F.R.	§	11.61	and

Section	333	of	the	FAA	Modern ization	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	areas	of	the

United	 States. By	 granting	 this	 Petition,	 the	 FAA	 Administrator	 will	 be	 fulfilling	 the Congressional	 mandate	 of	 the	 FAA	 Modernization	 and	 Reform	 Act	 of	 2012,	 while	 also advancing	the	interests	of	the	public,	by	allowing Alexander	Lange to	safely,	efficiently,	and

econom ically	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, Alexander	Lange 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	Phantom	3	UAS

comme rcially	for	the	purpose	of	conducting	aerial	video	and	photography	over	certain	areas

of	the	United	States.

Dated: August	19,	2015

Respectfully	submitted,

Alexander	Lange

Owner
Hover	With	Us |	Aerial	Imagery

13597	Tiverton	Road San	Diego,	CA	92130

760

- 473

- 4546
alexander@hover withus.com30 

## Appendices

1. Link	to DJI	Phantom	3 Manual :

http:// download.dji innovations.com/downloads/phantom_3/en/Phantom_3_Professional_ User_Manual_v1.2_en.pdf