UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

WASHI NGTON, DC

Regulatory Docket No.

**IN THE**  **MATTER OF**  **THE PETITION**  **FOR EXEMPTION**  **OF :** 

**Droneography 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),**  **91.119, 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 OP** **ERATION OF**  **DJI PHANTOM 3 PROFESSIONAL UNMANNED**  **AIRCRAFT S** **Y STEMS**  **PURSUANT TO**  **SECTION 333**  **OF THE**  **FAA MODERNIZATION**  **AND REFORM**  **ACT OF**  **2012**

**(PUBLIC LAW**  **11 2** **- 95)** 

Submitted on March 31, 2015 Christopher L Parrish ATP CFI CFII Droneography LLC 6776 S. Ivy St. #A3 Centennial CO, 80112 Tel: (303) 521
-3611 Email : 

### Chris@Droneography360.com2 **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.

................................ ........................... 7 THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH DRONEOGRAPHY LLC SEEKS EXEMPTION

................................ ................................ 8 THE EXTENT OF RELIEF DRONEOGRAPHY LLC SEEKS AND THE REASON DRONEOGRAPHY LLC SEEKS THE RELIEF
... .. ... ... ... . ............. 11 THE REASONS WHY GRANTING DRONEOGRAPHY LLC’S REQUEST WOULD BE IN THE PUBLIC INTEREST ...

...... . ................................ .............. 1 5 THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY

................................ ................................ ......... 19 SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER.

.... 34 ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT DRONEOGRAPHY LLC’S REQUEST

... . ........ 34 CONCLUSION

................................ ................................ ................................ ................... 35 APPENDICES

....................................................................................... .373 **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 ofAuthorization FAA Federal Aviation Administration FAR Federal Aviation Regulation GCS Ground Control Station GPS Global Positioning System LOL Loss of Link NAS National Airspace System NOTAM Notice to Airman PIC Pilot In Command Section 333 FAA Modernization and Reform Act of 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 Landing4 **SUMMARY** Christopher L. Parrish ATP, CFICFII 3331167, seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.119, 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Droneography LLC to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography of construction sites, real estate, special events, film sets, farm & agriculture, insurance and natural disaster surveys as well as landscape over the United States its territories and possessions

.5 **INTRODUCTION AND**  **INTERESTS OF**  **THE PETITIONER**  Droneography LLC seeks to provide its clients with the highest quality digital content for use in their commercial, personal, and non-profit multimedia projects. Christopher Parrish ATP, CFII, CFI has over 5 years aircraft based aerial photography experience, in all aspects of aerial video and aerial photography. The objective of Droneography LLC, is to provide high quality imaging that includes both digital photography and filming for a variety of commercial, public, and residential uses, specifically targeting:

• Special event’s

• Safety inspections

• Land and property surveying and scouting

• Real Estate appraisal and advertisement

• Commercial Real Estate appraisal and advertisement

• Ongoing construction progress surveys

• Farm & Agriculture survey

• Natural disaster surveys

• Insurance claim surveys

**BACKGROUND** Unmanned Aircraft Systems: DJI Phantom 3 Professional UAS Droneography LLC seeks an exemption to operate the DJIPhantom 3 Professional UAS for compensation or hire within the NAS. The DJI Phantom 3 Professional is a 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 Professional has a maximum gross weight of approximately 2.82 lbs., while having a6

length of 1 9 1/4 inches width of 1 9 1/4 inches, height of 8 inches, and a maximum speed of approximately 40 knots. The DJI Phantom 3 Professional UA is equipped with four main rotors; driven by Lithium Poly mer (LiPo 4S) battery powered electric motors. The DJI Phantom 3 Professional UA that will be operated by Droneography LLC and will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking

. **BASIS FOR**  **PETITION** Petitioner, Droneography LLC, 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 Rulesfor Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate the DJI Phantom 3 Professional 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 91.417(a) & (b). In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, Droneography LLC operation of DJI Phantom 3 Professional UAS meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingly, Droneography LLC requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate. Droneography LLC submits that the requested relief is proper since an equivalent7

level of safety will be ensured. Droneography LLC will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., Maintenance Log, and DJIPhantom 3 Professional Instruction Manual). Furthermore, Droneography LLC will document and maintain all maintenance records for the DJI Phantom 3 Professional UAS

. Relief from certain requirements of Section 61.113(a) and (b), entitled Privatepilot privileges and limitations: Pilot in command, is requested by Droneography LLC to the extent necessary to allow a Pilot in Command (PIC), holding a pilot’s license that would usually require a Commercial pilots license or better to operate for hire. Any pilot fly ing for Droneography LLC and acting as PIC of the UAS is able to safely operate the DJI Phantom 3 Professional UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Droneography LLC seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the DJI Phantom 3 Professional UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Droneography LLC submits that it will ensure that the DJIPhantom 3 Professional UAS is in an airworthy

condition, prior to every flight, by determining that the UASs are in compliance with the operating documents (i.e., Maintenance Log, and DJI Phantom 3 Professional Instruction Manual), and that the UAS aircraft are in a condition that permits for safe flight. Droneography LLC also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings, as the DJI Phantom 3 Professional UA will not have a8

ty pical barometric altimeter onboard. However, altitude information ofthe DJIPhantom 3 Professional UA will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring ofthe flight path and altitude

. This altitude information combined with Droneography LLC’s operation of the DJIPhantom 3 Professional UAS within visual line of sight or an observer in constant contact with the PIC, at or below 200 feet AGL, will ensure a level of safety equivalent to Section 91.121. Additionally, Droneography LLC seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirementsforflight in VFR conditions

. Droneography LLC submits that safety will not be affected by operation of the DJI Phantom 3 Professional UA 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 18 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 5 minutes. In accordance with 14 C.F.R. § 11.81, Droneography provides the following information in support of its petition for exemption: **A. Name**  **And Address**  **Of The**  **Petitioner.** The name and address of the Petitioner and point of contact is: Christopher LParrish Droneography LLC 6776 S. Ivy

St. # A3 Centennial CO, 80112 Tel: (303) 521

-3611 Email: 

### Chris@

Droneography360.com **B. The**  **Specific Sections**  **Of 14**  **C.F.R. From**  **Wh ic** **h Droneography**  **LLC Seeks**  **E x** **emption. 1.**  **Droneography LLC**  **Seeks E** **x emption**  **from The**  **Requirements of**  **Section**9 **61.113(a) And (b).** Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections (a) and (b) prescribe the following, in relevant part: (a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PIC of an aircraft. (b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employ ment if

— (1) The flight is only incidental to that business or employ ment; and (2) The aircraft does not carry passengers or property for compensation or hire.
**2. Droneography**  **LLC Seeks**  **E x** **emption 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. Droneography LLC Seeks Exemption From the Requirements of**  **Section 91.119**

. Sec. 91.119

— Minimum safe altitudes: General. Except when necessary

for takeoff or landing, no person may operate an aircraft below the following altitudes: (a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface. (b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft. (c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may

not be operated closer than 500 feet to any person, vessel, vehicle, or structure. (d) Helicopters, powered parachutes, and weight

-shift

-control aircraft. If the operation is conducted without hazard to persons or property on the surface

—10 (1) A helicopter may

be operated at less than the minimums prescribed in paragraph (b) or (c) of this section, provided each person operating the helicopter complies with any

routes or altitudes specifically prescribed for helicopters by the FAA; and (2) A powered parachute or weight

-shift

-control aircraft may be operated at less than the minimums prescribed in paragraph (c) of this section. **4. Droneography**  **LLC E** **x emption**  **from The**  **Requirements of**  **Section 91.121.**  Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

-- (1) Below 18,000 feet MSL, to
-- (i) The current reported altimeter setting of a station along the route and within 100 nautical miles ofthe aircraft; (ii) there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or (iii) the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure. **5. Droneography**  **LLC E** **x emption**  **from The**  **Requirements of**  **Section 91.151(b).**  Section 91.151, entitled Fuel requirementsforflight in VFR conditions, subsection (b), states the following: (b ) No person may begin aflight in a rotorcraft under VFR conditions unless (considering wind andforecast weather conditions) there is enoughfuel tofly to thefirstpoint ofintended landing and, assuming normal cruising speed, to fly after thatfor at least 20 minutes. **6. Droneography**  **LLC Seeks**  **E x** **emption from**  **The Requirement**  **of Section 91.405(a).**  Section 91.405, entitled Maintenance required, subsection (a), states the following:11

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 ofthis chapter[.] **7. Droneography**  **LLC Seeks Exemption**  **from The**  **Requirements of**  **Section 91.407(a)(1)**  Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration, subsection (a)(1), states the following: (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

-- (1) It has been approved for return to service by a person authorized under § 43.7 of this chapter[.] **8. Droneography**  **LLC Seeks**  **E x** **emption 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 ofthis 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. **9. Droneography**  **LLC Seeks**  **E x** **emption from**  **The Requirements**  **of Sections 91.417(a) And 91.417(b).**  Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following: (a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records ofthe maintenance, preventive maintenance, and alteration and records ofthe 100

-hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each12 engine, propeller, rotor, and appliance of an aircraft. The records must include

-- (i) description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of completion ofthe work performed; and (iii) The signature, and certificate number ofthe person approving the aircraft for return to service. (2) Records containing the following information: (i) The total time in service ofthe 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 ofthe aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms prescribed by § 43.9(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 time the aircraft is sold. (3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.13

**C. The**  **E x** **tent of**  **Relief ;**  **Droneography LLC**  **Reason s**  **for The**  **Relief. 1.**  **E x** **tent of**  **Relief ;**  **Droneography LLC**  **Seeks Relief**  **from Section**  **61.113(a) And**  **(b).** Relief from Section 61.113(a) and (b) entitled Privatepilotprivileges and limitations: Pilot in command, is requested to the extent necessary to allow a PIC holding an appropriate pilots license which includes any of the following: Sport Pilot, Recreational Pilot or Private Pilot or any license able to conduct commercial operations such as Commercial Pilot or ATP, 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 employ ment if: (1) The flight is only incidental to that business or employ

ment; and (2) The aircraft does not carry passengers or property for compensation or hire. As set forth more fully below, Droneography LLC submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the DJIPhantom 3 Professional UAS UA unless that PIC has met certain flight

-hour and currency requirements, demonstrating that the PIC is able to safely operate either the DJIPhantom 3 Professional 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, Droneography LLC submits that all flights of the DJI Phantom 3 Professional UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to Droneography LLC business; and (2) will not carry passengers or property for14

compensation or hire. **2. E** **x tent**  **of Relief** **; Droneography**  **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 Droneography LLC to determine that the DJI Phantom 3 Professional UAS are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., the Droneography LLC Aerial Operations Manual, Maintenance Log, and DJI Phantom 3 Professional Instruction Manual). Droneography LLC seeks the requested reliefbecause the DJI Phantom 3 Professional UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Droneography LLC will ensure that the DJI Phantom 3 Professional UAS are in airworthy condition based upon its compliance with the operating documents (i.e., Maintenance Log, and DJI Phantom 3 Professional Instruction Manual) prior to every flight, and further, determine that the aircraft is in condition for a safe flight,
as stated in the conditions and limitations below. **3. Extent of Relief; Droneography LLC**  **Seeks relief from Section 91.119.** Relief from Section 91.119, entitled Minimum Safe Altitudes: General, will be required in order to capture high quality digital images below 1,000 feet in congested areas and 500 feet in other than congested areas. Due to the nature of the operations the light weight nature of the DJI Phantom 3 Professional, and the low risk for damage or injury to persons, vessels, vehicles or structures in private or public areas and considering the low potential for personal injury to the general public, workers and bystanders as well as damage to property, Droneography LLC seeks relief of 91.119 to the extent necessary to complete the operations while utilizing the PIC to exercise good judgment in determining that the UAS does not pose an undue risk to those in close proximity to the operations of15

the UAS. Furthermore, Droneography LLC will have adequate warning signs placed in and around the area of operations to alert the general public, workers and bystanders of the operations being conducted. It is Droneography LLC’s belief that information and public awareness and dialog will contribute to public safety and understanding. **4. E** **x tent**  **of Relief** **; Droneography**  **LLC Seeks**  **Relief from**  **Section 91.121.**  Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations ofthe DJIPhantom 3 Professional UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), Droneography LLC seeks the requested reliefbecause the DJI Phantom 3 Professional 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 ofthe proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply with the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level of safety will be maintained since the DJIPhantom 3 Professional 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. **5. E** **x tent**  **of Relief** **; Droneography**  **LLC Seeks**  **Relief from**  **Section 91.151(b).**  Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR16

conditions, is requested to the extent required to allow flights ofthe battery powered DJI Phantom 3 Professional UAs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 18 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 5 minutes. Droneography LLC seeks the requested reliefbecause without an exemption from Section 91.151(b), the flight time duration of the battery powered DJI Phantom 3 Professional UA will severely constrain the practicality of any aerial video or still photo flight operations that Droneography proposes to conduct pursuant to this Petition. Significantly, as set forth below, the technical specifications of the DJI Phantom 3 Professional UAS, the DJIPhantom 3 Professional operating documents, and Droneography LLC’s proposed operating limitations, ensure that Droneography LLC will safely operate the battery powered DJI Phantom 3 Professional 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 18 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 5 minutes. **6. E** **x tent**  **of Relief** **; Droneography**  **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, Droneography LLC requests relief from these Sections because the DJI Phantom 3 Professional UAS does not require airworthiness certificates. As set forth more fully below, the DJI Phantom 3 Professional UAS meets the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, Droneography LLC will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the Maintenance17

Log, and DJI Phantom 3 Professional Instruction Manual). Furthermore, Droneography will document and maintain all maintenance records for the DJI Phantom 3 Professional UAS

. **D. The**  **Reasons Why**  **Granting Droneography**  **LLC Request**  **Would Be**  **in The**  **Public Interest;**  Granting the present Petition will further the public interest by allowing Droneography LLC to safely, efficiently, and economically perform aerial video and photography of special events, film sets, real estate, safety inspections, farm & agriculture survey, insurance surveys, natural disaster surveys and landscape photography over the United States its territories and possessions

. Additionally, use of the DJIPhantom 3 Professional UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy by expanding who can take advantage of lower cost aerial filming & photography

. **The Public**  **Will Benefit**  **from Decreased**  **Congestion of**  **The NAS** **.** The DJI Phantom 3 Professional UA 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 ofmanned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJIPhantom 3 Professional UAS would reduce the amount ofmanned 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 ofmanned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The DJIPhantom 3 Professional UAS do not require an airport to takeoff or land. Likewise, a reduction ofmanned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handled by air traffic control during the ground,18

takeoff, departure, arrival, and landing phases of flight operations. **1. The**  **Public Will**  **Benefit from**  **The Safety**  **and Efficiency**  **of The**  **DJI Phantom 3 Professional**  **UA S** **.** Conducting aerial photography and surveying with the DJI Phantom 3 Professional UAS, instead of manned aircraft, will benefit the public by reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, the DJIPhantom 3 Professional UAS produce no air pollution. The DJI Phantom 3 Professional UA, while reducing the carbon footprint of aerial film & photography acquisitions, also reduce noise

. By using the DJI Phantom 3 Professional UAS to perform aerial film & photography acquisitions, the risk to life and property in the air and on the ground can be further mitigated. Aside from the lack of flight crew members located onboard the aircraft, the DJI Phantom 3 Professional UAS, has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that ty pically conduct similar operations. **2. Performing**  **Aerial Video**  **and Photography**  **Operations with**  **The DJI**  **Phantom 3 Professional UAS**  **Will Benefit**  **the Economy.**  In addition to being safe and efficient, the DJI Phantom 3 Professional is also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom 3 Professional UAS will allow United States based companies, like Droneography LLC, to remain competitive and contribute to the growth of the U.S. economy. Operating the battery powered DJI Phantom 3 Professional UAS allows companies greater operational flexibility in conjunction with traditional manned aircraft. **3. There**  **Are No**  **Privacy Issues.** 19

Similar to the manned aerial acquisition photography flight operations that have been conducted for decades, Droneography LLC proposed operation of the DJI Phantom 3 Professional UAS would not create any privacy issues. Specifically, the DJI Phantom 3 Professional UAS will be operated only in compliance with operating, which would be at the instruction or discretion ofproperty owners, lessee’s or their agents.
**4. Reasons**  **Why The**  **DJI Phantom 3 Professional UA**  **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, Droneography LLC operation ofthe DJI Phantom 3 Professional UAS meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part: (a ) In General.

--Notwithstanding any other requirement ofthis subtitle, and not later than 180 days after the date ofenactment ofthis Act, the Secretary of Transportation shall determine ifcertain unmanned aircraft systems may operate safely in the national airspace system before completion oftheplan and rulemaking required by section 332 ofthis Act or the guidance required by section 334 ofthis Act. (b ) Assessment of Unmanned Aircraft Systems.

--In making the determination under subsection (a

), the Secretary shall determine, at a minimum

-- (1 ) which types ofunmanned aircraft systems, ifany, as a result oftheir size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line ofsight do not create a hazard to users ofthe national airspace system or the public orpose a threat to national security; and (2 ) whether a certificate ofwaiver, certificate ofauthorization, or airworthiness certification under section 44704 oftitle 49, United States Code, is required for the operation ofunmanned aircraft systems20 identified underparagraph (1). (c) Requirementsfor Safe Operation.

--Ifthe Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirementsfor the safe operation ofsuch aircraft systems in the national airspace system. In seeking this exemption, Droneography LLC submits that the DJI Phantom 3 Professional UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI Phantom 3 Professional UAS; (b) the pilot certification requirement; and (c) the specific operating limitations.

**a. The**  **Specifications of**  **The DJI Phantom 3 Professional**  **UAS Demonstrate**  **Its Safe Characteristics.**  The DJI Phantom 3 Professional UAS does 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 Professional**  **UA S** **.** The technical specifications of the DJIPhantom 3 Professional UAS is set forth by the DJI Phantom 3 Professional Specifications and Data Sheet, attached hereto as Exhibit A. **ii. T** **he DJI Phantom 3 Professional**  **UAS Autonomous**  **Flight And** 

**Navigation Modes Enable**  **The UAS**  **To Remain**  **Within A**  **Defined Operational Area.**  The DJI Phantom 3 Professional UAS may be operated in both manual and fully autonomous flight modes. A complete description ofthe flight and navigational modes of the DJIPhantom 3 Professional UAS is provided in the DJI Phantom 3 Professional User Manual, attached hereto as Exhibit B.

**iii. e**  **DJI Phantom 3 Professional 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 DJIPhantom 3 Professional UA will remain21

stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 3 Professional UA does not reacquire control link data from the GCS, the UA will assume that the Control Link is lost and the UA will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoffposition and shutdown. A complete description ofthe Failsafe Functions of the DJI Phantom 3 Professional UAS are set forth at pages 12 through 14 of the DJI Phantom 3 Professional User Manual, attached hereto as B. **iv. The**  **DJI Phantom 3 Professional GCS**  **and Its**  **Operation.** A complete description of the operation and specifications of the DJI Phantom 3 Professional GCS and flight control software is provided at pages 22 through 29 of the DJIPhantom 3 Professional User Manual. DJI Phantom 3 Professional User Manual is attached hereto as Exhibit B.

**b. Flight**  **Operations of**  **DJI Phantom 3 Professional U** **A S**  **Are Limited**  **to The**  **Line Of**  **Sight Of**  **A Certificated**  **Pilot in**  **Command Or**  **With A**  **Safety Observer As Necessary** **.** Where the UAS will not be out of the direct line of sight of the PIC a safety observer would be optional. However, a safety observer will be utilized to assist the PIC during flight operations that the UAS potentially or will be out of site of the operator.
**c. Flights**  **of DJI Phantom 3 Professional**  **UAS Will**  **Be Conducted**  **Pursuant To**  **Specific Operating**  **Limitations.** In seeking this exemption, proposes to commercially operate DJI Phantom 3 Professional UAS for the special purpose of conducting aerial digital video and photography over the United States its Territories and Possessions, pursuant to the following specific operating limitations: 1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UASs weighing less than 55 pounds’ maximum gross weight: DJI Phantom 3 Professional Unmanned Aircraft System. Proposed operations of any other aircraft will require a new22 petition or a petition to amend this grant. 2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photography. 3. The UAs may not be flown at an indicated airspeed exceeding 100 MPH
. 4. The UA must be operated at an altitude 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 UAs 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

. 6. The sole use of first person view (FPV) by the PIC or safety observer (SO) is not permitted. 7. When operations are conducted out of view of the PIC, all operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC or SO maintains VLOS capability

. The SO and PIC must be able to communicate verbally at all times via phone or handheld radio’s

. 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/obstructions with an emphasis on safety for persons and property 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 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. Ifthe operator determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS

-80) may be contacted if questions arise regarding updates or revisions to the operating documents.23

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records. 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 discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections ofthe 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 ofreplacement/overhaul component parts must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature ofthe authorized person returning the UAS to service. 15. Each UASs operated under this exemption must comply with all manufacturer Safety Bulletins. 16. The authorized person must make an entry in the aircraft record ofthe corrective action taken against discrepancies discovered between inspections. 17. The PIC must possess an appropriate pilots license as deemed by the FAA

. (Sport Pilot, Recreational Pilot, Private Pilot, Commercial Pilot or ATP) 18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification 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 ofthe 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. § 91.119.24

19. UAS operations may not be conducted during night (Official sunset to sunrise), as defined in 14 C.F.R. unless a special request is made and approved by the FAA. § 19.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will be made to the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized. 20. The UAS may not be operated less than than 3 statute miles visibility as seen from the PIC’s location

. 21. If the UAS loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in accordance with the operating documents. 22. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents. 23. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with at least 15% battery power remaining. 24. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (N

- Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable. 25. Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 26. No Operations are allowed in Class A (18,000 feet & above)

. Operation in Class B, C, D and E Airspace are allowed with the permission of the controlling ATC Facility. Operations in Class G airspace are allowed without ATC permission. 27. At all times the small unmanned aircraft must remain close enough to the operator for the operator to be capable of seeing the aircraft with vision unaided by any device other than corrective lenses, except when using a Visual Observer in constant contact with the PIC. 28. The UAV must remain clear and yield the right of way to all manned aviation operations and activities at all times. 29. The UAS may not be operated by the PIC from any moving device or vehicle. 30. Flight operations must not be conducted directly over non-participating persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless:25 a. 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; b. Operations nearer to the PIC, SO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a). 31. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries ofthe operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS

-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. **2. Reasons**  **Why an**  **E x** **emption F** **rom The**  **Requirements Of**  **Section 61.113(a)**  **And (b)**  **Would Not**  **Adversely Affect**  **Safety.** Droneography LLC 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 DJIPhantom 3 Professional 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 Professional UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering Droneography LLC proposed area of operations, and the operating limitations set forth

-above; the parallel nature ofprivate pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI Phantom 3 Professional UAS, Droneography LLC submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for Droneography LLC specific proposed flight operations. The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g.26

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). Droneography LLC will not allow any PIC to operate the DJI Phantom 3 Professional UAS unless that PIC has demonstrated, by meeting minimum flight

-hour requirements or the DJI Phantom 3 Professional UAS training and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 Professional 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), 10 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). 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 Droneography LLC proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows: In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi

-rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model ofUAS 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 at a minimum, the flight

-hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the27 skills necessary to safely conduct the petitioner’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience

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

-building flights the PIC is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15. Accordingly, Droneography will ensure safe operations by not allowing any PIC to operate the DJI Phantom 3 Professional 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 Professional 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**  **E x** **emption 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, Droneography LLC will ensure that the DJI Phantom 3 Professional UAS is in an airworthy condition based upon the UAS’s compliance with its operating documents and as stated in the conditions and limitations herein. Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). **4. Reasons**  **Why An**  **E x** **emption 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 Professional UA will be provided to the PIC via GPS equipment and a radio communications telemetry data link, which28

downlinks from the UA to the GCS for active monitoring of the flight path and altitude. This altitude information, combined with Droneography LLC’s operation of the DJI Phantom 3 Professional UA within visual line of sight, at or below 500 feet AGL, will
ensure a level of safety equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically established by the UASs at ground level. The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 1 1159, 11160, 11161). **5. Reasons**  **Why An**  **E x** **emption From**  **The Requirements**  **Of Section**  **91.151(b) Would**  **Not Adversely**  **Affect Safety.**  A grant ofthis 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 Professional UAs; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, Droneography will ensure that it will safely operate the battery powered DJI Phantom 3 Professional UA during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 18 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 5 minutes. Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 3 Professional 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. Section 91.151(b). Furthermore, safety will be ensured as the DJI Phantom 3 Professional UAS provide audible and visual warnings to the PIC at the GCS when the UAs experiences29

low battery voltage, the first warning occurring at approximately 25% remaining battery power, and again at approximately 10% remaining battery power. At the critically low battery level, the DJI Phantom Vision+ UAS will descend and land automatically

. Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations ofthe UAS are considered. Reliefhas been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 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**  **E x** **emption 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, Droneography LLC 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 Droneography LLC will use licensed pilots and 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 Maintenance Log, and DJI Phantom 3 Professional Instruction Manual). Furthermore, Droneography LLC will document and maintain all maintenance records for the DJI Phantom 3 Professional UAS. Since the DJI Phantom 3 Professional UAS will be inspected as prescribed by the operating documents, Droneography 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 DJI30

Phantom 3 Professional User Manuals are attached hereto as Exhibit B
. Likewise, the exemption sought will not adversely affect safety because Droneography LLC will use trained technicians to perform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed by the operating documents. 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 DJIPhantom 3 Professional UAS will be performed by trained technicians. Maintenance will be documented and maintained utilizing a standard aircraft 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 ofthe UAS are considered. In consideration of Droneography LLC proposed operating limitations, the operating documents, and the technical aspects of the DJI Phantom 3 Professional UAS, Droneography 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 91.417(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, Droneography LLC requests31

that the FAA prescribe special conditions for the intended operation of the DJIPhantom 3 Professional UAS, which contain such safety standards that the Administrator finds necessary 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 the United States its territories and possessions 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 DJIPhantom 3 Professional 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 the 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 ofthe 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 contain such safety standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent to that established in the regulations. See 14 C.F.R. § 21.16. Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for Droneography LLC intended operation ofthe DJI32

Phantom 3 Professional 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). **E. A**  **Summary That**  **Can Be**  **Published In**  **The Federal**  **Register, stating:**  **The Rules**  **From Which**  **Droneography LLC**  **Seeks E** **x emption:**  Droneography LLC seeks exemptionfrom the requirements of14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.119, 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**  **E x** **emption Droneography**  **LLC Seeks:**  This exemption willpermit Droneography LLC to commercially operate an Unmanned Aircraft System (UAS)for thepurpose ofconducting aerial video and photography over the United States its territories and possessions

. **F. Any**  **Additional Information,**  **Views, Or**  **Arguments Available**  **to Support**  **Droneography LLC**  **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, Droneography LLC 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, Droneography LLC will operate the DJI Phantom 3 Professional UASs safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security

.3334 **CONCLUSION** As set forth herein, Droneography LLC seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI Phantom 3 Professional UAS commercially, without an airworthiness certificate, for the purpose of conducting aerial video and photography over the United States its territories and possessions

. Respectfully submitted, Christopher LParrish
Christopher LParrish Droneography LLC 6776 S. Ivy

St. #A3 Centennial, CO 80112 Tel: (303) 521

-3611 Email: Chris@Droneography360.com35

Appendices: A

– DJI Phantom 3 Professional Specifications Data Sheet B

– DJI Phantom 3 Professional Manufacturer’s User Manual36 APPENDIX

– A **DJI PHANTOM 3 PROFESSIONAL TECHNICAL**  **SPECIFICATIONS** Droneography LLC only utilizes safe and reliable UASs. DJI is an industry leader in small UAS production. DJI UASs are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJI software provides real

time altitude and location information to the PIC via the linked monitor (smart phone/tablet devices) DJI Phantom 2 Vision+ Aircraft Supported Battery

– DJI PH3

-4480 mAh

- 15.2 V (LiPo 4S) Battery Weight (Battery & Propellers Included)

– 2.822lbs (1280g) Max Ascent Speed

– 5m/s Max Descent Speed

– 3m/s Max Flight Speed

– 1 6m/s (No Wind) Transmitter Operating Frequency

– 2.400GHz

– 2.483GHz Transmitting Distance

– 1.25 Miles (Outdoor and unobstructed)37 APPENDIX

– B DJIPhantom 3 Professional Manufacturer’s User Manual