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: MICHAEL E. OLSEN 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 DJI Inspire 1 and DJI Phantom 3 UNMANNED AIRCRAFT SYSTEMS and a BLANKET EXEMPTION FOR UAS OPERATION LESS THAN 55 POUNDS, DAYLIGHT OPERATION, VLOS,

VFR AND BELOW 200 FEET AGL.

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112

- 95)

Submitted on MAY 21, 2015

MICHAEL E. OLSEN

14 O LD TOWN LANE HALESITE, NY 11743

516

- 317

- 6222 MEOLSEN@YAHOO.COM2 TABLE OF CONTENTS

GLOSSARY OF ABBREVIATIONS 4

SUMMARY 5

INTRODUCTION AND INT ERESTS OF THE PETITI ONER 5

BACKGROUND 5
Unmanned Aircraft Systems: DJI Inspire 1, DJI Phantom 3 (Herafter the DJI UAS Aircraft) 5

BASIS FOR PETITION 6

Name And Address Of The Petitioner. 7

THE SPECIFIC SECTION S OF 14 C.F.R. FROM WHICH MICHAEL E. OLS EN SEEKS EXEMPTION. 7

MICHAEL E. OLSEN Seeks Exemption From The Requirements Of Section 61.113(a) And (b). 7
MICHAEL E. OLSEN Seeks Exemption From The Requirements Of Section 91.7(a). 8
MICHAEL E. OLSEN Seeks Exemption From The Requirements Of Section 91.121. 8

MICHAEL E. OLSE N Seeks Exemption From The Requirements Of Section 91.151(b). 8
MICHAEL E. OLSEN Seeks Exemption From The Requirement Of Section 91.405(a). 8
MICHAEL E. OLSEN Seeks Exemption From The Requirements Of Section 91.407(a)(1) 9
MICHAEL E. OLSEN Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2). 9
MICHAEL E. OLSEN Seeks Exemption From The Requi rements Of Sections 91.417(a) And 91.417(b). 9

THE EXTENT OF RELIEF MICHAEL E. OLSEN SEE KS AND THE REASON MI CHAEL E. OLSEN

SEEKS THE RELIEF. 10

Extent Of Relief MICHAEL E. OLSEN Seeks And The Reason MICHAEL E. OLSEN Seeks Relief From Section 61.113(a) And (b). 11

Extent Of Relief MICHAEL E. OLSEN Seeks And The Reason MICHAEL E. OLSEN Seeks Relief From Section 91.7(a). 11

Extent Of Relief MICHAEL E. OLSEN Seeks And The Reason MICHAEL E. OLSEN Seeks
Relief From Section 91.121. 12

Extent Of Relief MICHAEL E. OLSEN Seeks And The Reason MICHAEL E. OLSEN Seeks Relief From Section 91.151(b). 12

Extent Of Relief MICHAEL E. OLSEN Seeks And The Reason MICHAEL E. OLSEN Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b). 13
The Reasons Why Granting MICHAEL E. OLSEN Request Would Be In The Public Interest; That Is,
How It Would Benefit The Public As A Whole. 13

T he Public Will Benefit From Decreased Congestion Of The NAS. 13
The Public Will Benefit From The Safety And Efficiency Of The DJI UAS Aircraft 14
Performing Aeri al Video and Photography Operations With The DJI UAS Aircraft will Benefit The Economy. 14
There Are No Privacy Issues. 15
The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From
Which MICHAEL E. OLSEN Se eks Exemption. 153 Reasons Why The DJI UAS Aircraft Meet The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333. 15
The Specifications Of The DJI UAS Aircraft Demonstrate Its Safe Characteristics. 16
Technical Specifications of DJI UAS Aircraft. 16
DJI UAS Aircraft GCS Operation. 17
Flight Operations Of DJI UAS Aircraft are Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer. 17
Flights Of DJI UAS Aircraft will Be Conducted Pursuant To Specific Operating

Limitations. 17
Reasons Why An Exemption From The R equirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety. 21
Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety. 23
Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety. 23
Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely Affect Safety. 24
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. 24
The FAA May Prescribe Any Other Conditions For Safe Operation. 25
A Summary That Can Be Published In The Federal Register, stating: The Rules From Which MICHAEL E. OLSEN Seeks Exemption: 26
A Brief Description Of The Nature Of The Exemption MICHAEL E. OLSEN Seeks: 27
Any Additional Information, Views, Or Arguments Ava ilable To Support MICHAEL E. OLSEN Request. 27

CONCLUSION 274 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
DJI UAS Aircraft DJI Inspire 1 and Phantom 3 subject of this Petition.
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 Mod and Reform Act of 2012 (FMRA) Section 333
SO Safety Observer
SOP Standard Operating Procedures
UAV Unmanned Aircraft Vehicle
UAS Unmanned Aircraft System
VFR Visual Flight Ru les
VLOS Visual Line of Site
VMC Visual Meteorological Conditions
VTOL Vertical Takeoff and Landing5 SUMMARY

MICHAEL E. OLSEN 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 pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit MICHAEL E.

OLSEN to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography in support of small business, community and
charitable activities in and around the State of New York.

INTRODUCTION AND INTERESTS OF THE PETITIONER

MICHAEL E. OLSEN ’s primary occupation is a senior executive in a media company but has hundreds of hours as a UAS hobbyist. From time to time he is asked to support local community, small business, and charitable activities by providing commercial aerial photography or videography. In the absence of the exemption, MICHAEL E OLSEN must decline to support these interests. The objective of MICHAEL E. OLSEN and his aerial operations is to provide high quality imaging for a variety of commer cial, public, and residential uses, that are incidental to his primary occupation, specifically targeting

• Marketing

• Construction sites before and after

• Appraisals

• Motion Picture Filming

• Aerial acquisitions for inspections of public and private structures.

• Building Inspection operations

BACKGROUND

Unmanned Aircraft Systems: DJI Inspire 1 , DJI Phantom 3 ( Hereafter the DJI UAS Aircraft)

MICHAEL E. OLSEN seeks an exemption to operate DJI Inspire 1 and DJI Phantom 3 UAS systems for compensation or hire withi n the NAS. The DJI Inspire 1, Phantom 3 are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems.

The DJI Inspire 1 has a maximum gross weight of approximately 7 pounds, with a length of 17 inches and a width of 18 inches and a height of 10 inches and a maximum speed of approximately 30 knots.6 DJI Phantom 3 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of approximately
30 knots. The DJI Inspire 1 and Phantom 3 are equipped with four main rotors; driven by Lithium Polymer battery powered electric motors.

The DJI Inspire 1 and DJI Phantom 3 will be operated by MICHAEL E. O LSEN 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

Pet itioner, MICHAEL E. OLSEN , 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

A dministrator to commercially operate the DJI UAS Aircraft 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, MICHAEL E. OLSEN operation DJI UAS Aircraft meets the conditions of FMRA Section 333 and therefo re, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, MICHAEL E. OLSEN 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.

MICHAEL E. OLSEN submits that the requested relief is proper since an equivalent level of safety will be ensured. MICHAEL E. OLSEN 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.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private p ilot privileges and limitations: Pilot in command , is requested by MICHAEL E. OLSEN to the extent necessary to allow a Pilot in Command (PIC) with significant experience in the field of UAV’s, and who has demonstra ted, by meeting minimum flight

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

MIC HAEL E. OLSEN seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness,
because the DJI UAS Aircraft do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, MICHAEL E. OLSEN submits that he will ensure the DJI7 UAS Aircraft are in an airworthy condition, prior to every flight, by determining that the UASs are in compliance with the operating documents and that the aircraft are in a condition for safe flight.

MICHAEL E. OLSEN also seeks an exempti on from the requirements of Section 91.121, entitled Altimeter Settings, DJI UAS aircraft will not have a typical barometric altimeter onboard. However, altitude information of the DJI UAS Aircraft will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with MICHAEL E. OLSEN operation of the DJI UAS Aircraft
within visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent

to Section 91.121.

Additionally, MICHAEL E. OLSEN seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. MICHAEL E. OLSEN submits that safety will not be affected by operation of the DJI UAS Aircraft 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 15 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least

5minutes.

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

Name And Address Of The Petitioner.

The name and address of the Petitioner and point of contact is:

MICHAEL E. OLSEN
14 Old Town Lane Halesite, NY 11743

516

- 317

- 6222 (Mobile) meolsen@yahoo.com

The Specific Sections Of 14 C.F.R. From Which MICHAEL E. OLSEN Seeks Exemption.

MICHAEL E. OLSEN Seeks Exemption From The Requirements Of Section 61.113(a) And (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command,
subs ections (a) and (b) prescribe the following, in relevant part:8 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 co mpensation or hire, act as PIC of an aircraft. A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if

— The flight is only incidental to that business or employment; and
The aircraft does no t carry passengers or property for compensation or hire.

MICHAEL E. OLSEN 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 ci vil aircraft unless it is in an airworthy condition.

MICHAEL E. OLSEN Seeks Exemption From The Requirements Of Section 91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in
part:

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

— Below 18,000 feet MSL, to

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

MICHAEL E. OLSEN 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.

MICHAEL E. OLSEN Seeks Exemption From The Requirement Of Section 91.405(a).

Section 91.405, entitled Maintenance required , subsection (a), states the following:9 Each owner or operator of an a ircraft

—

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[.]

MICHA EL E. OLSEN 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: No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

-- It has been approved for return to service by a person authorized under § 43.7 of this chapter[.]

MICHAEL E. OLSEN 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:

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

--

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

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

MICHAEL E. OLSEN Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b).

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

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:

Records of the maintenance, preventive maintenance, and alteration and records of
the 100

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

--10 A description (or reference to data acceptable to t he Administrator) of the work performed; and

The date of completion of the work performed; and

The signature and certificate number of the person approving the aircraft for return

to service.

Records containing the following information:

The total time in service of the airframe, each engine, each propeller, and each

rotor.

The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance.

The time since last overhaul of all items installed on the aircraft which are re quired to be overhauled on a specified time basis.

The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained.

The current stat us 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 nex t action is required.

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

The records specified in paragraph (a)(2) of this sectio n shall be retained and
transferred with the aircraft at the time the aircraft is sold. 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.

The Extent of Relief MICHAEL E. OLSEN Seeks and The Reason MICHAEL E. OLSEN Seeks the Relief.11 Extent of Relief MICHAEL E. OLSEN Seeks and The Reason MICHAEL E. OLSEN 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
certificat e, and who has met certain flight

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

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire.

A s set forth more fully below, MICHAEL E. OLSEN submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the DJI Inspire 1,DJI Phantom 2 UAS or 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 Inspire 1, DJI Phantom 2 or DJI Phantom 3 UAS in a manner consistent with the operations specifications as described in this exemption, including evasive and emergen cy maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures.

Further, MICHAEL E. OLSEN submits that all flights of DJI UAS aircraft , conducted by the PIC pursuant to the grant of this Petition: (1) will be inc idental to MICHAEL E.

OLSEN business; and (2) will not carry passengers or property for compensation or
hire.

Extent of Relief MICHAEL E. OLSEN Seeks and The Reason MICHAEL E. OLSEN 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 MICHAEL E. OLSEN to determine that the DJI UAS Aircraft are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e. , the MICHAEL E. OLSEN Aerial Operations Manual, Monthly Maintenance Log, and DJI UAS Aircraft Instruction Manual).

MICHAEL E. OLSEN seeks the requested relief because the DJI UAS Aircraft do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, MICHAEL E. OLSEN will ensure that the DJI UAS Aircraft are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly12 Maintenance Log, and DJI UAS Aircraft Instruction Manual) prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated in the
conditions and limitations below.

Extent of Relief MICHAEL E. OLSEN Seeks and The Reason MICHAEL E. OLSEN Seeks
Relief from Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the DJI UAS Aircraft , which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink
altitude info rmation 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), MICHAEL E

OLSEN seeks the requeste d relief because the DJI UAS Aircraft 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 necessary to comply with the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level of safety will be maintained since the DJI UAS Aircraft are equipped with a barometric

pressur e 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.

Extent of Relief MICHAEL E. OLSEN Seeks and The Reason MICHAEL E. OLSEN 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 UAS

Ai rcraft during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 15 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 5

minutes

. MICHAEL E. OLSEN seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered
DJI UAS Aircraft will severely constrain the practicality of any aerial video or still photo flight operation s that MICHAEL E. OLSEN proposes to conduct pursuant to
this Petition.

Significantly, as set forth below, the technical specifications of the DJI UAS Aircraft operating documents, and MICHAEL E. OLSEN proposed operating limitations,
ensure that MICHAEL E. OLSEN will safely operate the battery powered DJI UAS
Aircraft during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total duration of 1513 minutes to the first point of inte nded landing and, assuming normal cruising speed, to fly after that for at least 5 minutes.

Extent of Relief MICHAEL E. OLSEN Seeks and The Reason MICHAEL E. OLSEN 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, MICHAEL E. OLSEN requests relief from these

Sections because the DJI UAS Aircraft do not require airworthiness certificates. As set forth more fully below, DJI UAS Aircraft meet the conditions of FMRA Section 333 for operation without an airworthiness certificate.

Accordingly, MICHAEL E. OLSEN 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 MICHAEL E. OLSEN Aerial Operations Manual, Monthly Maintenance Log,
and DJI UAS Aircraft Instr uction Manual). Furthermore, MICHAEL E. OLSEN will
document and maintain all maintenance records for the DJI UAS Aircraft

.

The Reasons Why Granting MICHAEL E. OLSEN Request Would Be in The Public Interest; That Is, How It Would Benefit the Public as A Who le.

Granting the present Petition will further the public interest by allowing MICHAEL E.

OLSEN to safely, efficiently, and economically perform aerial video and photography of construction sites, real estate, and landscape over certain areas of the Unite d

States.

Additionally, use of the DJI UAS Aircraft will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of

MICHAEL E. OLSEN proposed operation of the DJI UAS Aircraft will be realiz ed without implicating any privacy issues.

The Public Will Benefit from Decreased Congestion of The NAS.

DJI UAS Aircraft are battery powered and serve as a safe, efficient, and economical
alternative to the manned aircraft traditionally utilized to obta in aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJI UAS Aircraft would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increa se the safety of life and property in the air and on the ground.14 Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be
reduced. The DJI UAS Aircraft 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.

The Public Will Benefit from The Safety and Efficiency of The DJI UAS Aircraft

Conducting aerial acquisitions with the DJI UAS Aircraft , instead of manned aircraft, will greatly benefit the public by drastically redu cing 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 DJI UAS Aircraft 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 UAS aircraft , 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.

By using the DJI UAS Aircraft to perform aerial acquisitions, t he 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 locate d onboard the aircraft, the DJI UAS Aircraft (weighing approximately 2 pounds 11 ounces and 6 pounds 7.5 ounces respectively, at their maximum gross weights with lengths of 16 inches and 17.3 inches respectively, widths of 16 inches and 17.7 inches respecti vely, 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 aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wi ngspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

Performing Aerial Video and Photography Operations with The DJI UAS Aircraft Will
Benefit the Economy.

In addition to being safe and efficient, the DJI UAS Aircraft are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI UAS Aircraft will allow United States based companies, like

MICHAEL E OLSEN , to remain competitive and contribute to gr owth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S.15 owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery powered DJI UAS Aircraft is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cos t of a traditional manned aircraft.

By operating the DJI UAS aircraft

, petitioners such as MICHAEL E. OLSEN can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through commercial
use of the DJI UAS Aircraft , provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows compa nies to invest in research and development in order to remain competitive both in the
United States and abroad.

There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for decades, MICHAEL E. OLSEN proposed operation of the DJI UAS Aircraft will not implicate any privacy issues. Specifically, the DJI UAS Aircraft will be operated only in compliance with operating documents (i.e., the MICHAEL E. OLSEN Aerial Operations Manual, Monthly Maintenance Log , and DJI UAS Aircraft Instruction Manual) which requires property owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.

The Reasons Why Granting the Exemption Would Not Adversely Affect Safety, Or

How the Exemption Would Provide a Level of Safety at Least Equal to That Provided by The Rule from Which MICHAEL E. OLSEN Seeks Exemption.

Reasons Why The DJI UAS Aircraft 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, MICHAEL E. OLSEN operation of the

DJI UAS A ircraft 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 req uirements 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:16 In General.

-- Notwithstanding any other requirem ent of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by
section 334 of this Act.

Assessment of Unmanned Aircraft Systems.

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

—

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 whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1). Requirements for Safe Operation.

—

If the Secretary determines under this section that certain u ), nmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements fo r the safe operation of such aircraft systems in the national airspace system.

In seeking this exemption, MICHAEL E. OLSEN submits that the DJI UAS Aircraft can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a)
the characteri stics of the DJI UAS aircraft ; (b) the pilot certification requirement; and (c) the specific operating limitations.

The Specifications of The DJI UAS Aircraft Demonstrate Its Safe Characteristics.

The DJI UAS Aircraft do not create a hazard to users of t he NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability.

Technical Specifications of DJI UAS Aircraft

.

The technical specifications of the DJI UAS Aircraft are set forth by the DJI UAS
aircraft User Manual s, attached hereto as Appendix A and B.

The DJI UAS Aircraft Autonomous Flight and Navigation Modes Enable The UASs to
Remain Within a Defined Operational Area.

The DJI UAS Aircraft may be operated in bot h manual and fully autonomous flight17 modes. A complete description of the flight and navigational modes of the DJI UAS
Aircraft provided in the User Manuals, attached hereto as Appendix A and B.

The DJI UAS Aircraft Are Designed for Automatic Return to Ho me Point or Hover in
The Event of Loss of the Control Link or Navigation.

When the Control Link is lost, the DJI UAS Aircraft will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI UAS Aircraft do not reacquire control link data from the GCS, the UAs will assume that the Control Link is lost and the UAs will return to the home position (i.e., failsafe mode) via GPS, and will
descend to the takeoff position and shutdown

.

A complete description o f the Failsafe Functions of the DJI UAS aircraft are
described in the User Manuals, attached hereto as Appendix A and B.

DJI UAS Aircraft GCS Operation.

Phantom 3 GCS and flight control software is provided in the User Manual for the
DJI UAS aircraft att ached hereto as Appendix A and B.

Flight Operations of DJI UAS Aircraft are Limited to The Line of Sight of a Certificated Pilot in Command with A Safety Observer.

MICHAEL E. OLSEN will be the only person to act as a pilot in command (PIC) of DJI

UAS Aircraft

.

Flights of DJI UAS Aircraft Will Be Conducted Pursuant to Specific Operating

Limitations.

In seeking this exemption, MICHAEL E. OLSEN proposes to commercially operate DJI
UAS Aircraft for the special purpose of conducting aerial video and pho tography over certain areas of United States, pursuant to the following specific operating
limitations:

1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UASs weighi ng less than 55 pounds maximum gross weight: DJI UAS AIRCRAFT . 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 pur pose of aerial video and photography.

3. The UAs may not be flown at an indicated airspeed exceeding 45 knots.18 4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and 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 un aided 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 verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC mu st 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 and is not permitted to operate the camera or other instruments. T

9. he 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 conta ined 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 t o track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. If the operator determine s 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.

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 prohib ited 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 the19 preflight inspection. All maintenance and alterations must be properly
docu mented 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 of the operating docume nts.

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 w ith 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 authori zed 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 ai rcraft record of the

corrective action taken against discrepancies discov ered between inspection s. 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

ex emption, 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 purpose s 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 essentia l 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.

17. UAS operations may not be conducted during night, as defined in 14 C.F.R.

18. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized.

19. The UAV may not operate within 5 nautical miles of an airport reference point20 as denoted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is
conducted in accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request.

20. The UAV may not be operated less than 500 feet below or less than 2,000 feet
horizontal ly from a cloud or when visibility is less than 3 statute miles from the

PIC.

21. If the UAV loses communications or loses its GPS signal, it must return to a pre

determined location within the planned operating area and land or be
recovered in accordance wit h 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 UAV with 25% battery power remaining.

24. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted i n accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requirements.

25. All aircraft operated in accordance with the exemption must be identified by serial number, registered in acco rdance 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.

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

27. 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.

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

29. The UAV may not be operated by the PIC from any moving device or vehicle.21 30. 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, veh icles, and structures unless:

31. Barriers or structures are present that sufficiently protect nonparticipating persons from the UAV 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;

32. 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;

33. Operations nearer to the PIC, SO, operator train ees or essential persons do not present an undue hazard to those persons per § 91.119(a).

34. 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.

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

- 80) within 24 hours.

36. A ccidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.nt sb.gov.

Reasons Why an Exemption from The Requirements of Section 61.113(a) And (b) Would Not Adversely Affect Safety.

MICHAEL E. OLSEN 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 UAS Aircraft unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI UAS Aircraft in a manner consistent with the exemption, including

ev asive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

Considering MICHAEL E. OLSEN proposed area of operations, and the operating
limitations set forth

- above; the parallel nature of private pilo t aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI
UAS aircraft

, MICHAEL E. OLSEN submits that the training, preparation, practice,
and ex perience of the Petitioner is sufficient to meet the requirements of the22 proposed use

.

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

MICHAEL E. OLSEN will not allow any PIC to operate the DJI UAS Aircraft unless the PIC has demonstrated, by meeting minimum flight

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

Specifically, the PIC must have accumulated and logged, in a manner consistent
with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a
minimum of 5 hours of those hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purpo ses).

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 MICHAEL E. OLSEN 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 mot ion 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. P rior to operations under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption. For clarification, the FAA considers the se 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 r equirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight

- hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the ski lls necessary to safely conduct the petitioner’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with23 applicable regulations would satisfy this requirement. Training, proficiency, and experien ce

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

building flights the PIC is required to operate the UAS with appropriate distances in
accordance wit h 14 C.F.R 91.119.

Exemption No. 11138 at page 15.

Accordingly, MICHAEL E. OLSEN will ensure safe operations by not allowing any PIC
to operate DJI UAS Aircraft unless that PIC has demonstrated, by meeting minimum flight

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

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, MICHAEL E. OLSEN will ensure that DJI UAS Aircraft 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 reli ef 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, 1115 8, 11159, 11160, 11161).

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 UAS A ircraft will be provided to the PIC via GPS equipment and a radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path and altitude. This altitude information, combined with MICHAEL E. OLSEN op eration of
the DJI UAS Aircraft within visual line of sight, at or below 400 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 fli ght, 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, in24 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).

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
UAS Aircraft ; (2) the limitations on the proposed flight operations; and (3) the
locati on of the proposed flight operations. Accordingly, MICHAEL E. OLSEN will ensure that it will safely operate the battery powered DJI UAS Aircraft during daylight hours in VFR conditions, with enough battery power to fly for a total
duration of 15 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 UAS Aircraft UASs; the limitations on the proposed flight operatio ns; 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 UAS Aircraft provide audible and visual warnings to the PIC at the GCS whe n 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 Vision+ and DJI Phantom

3 UASs will descend and land automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered. R elief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in circumstan ces 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).

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, MICHAEL E. OLSEN 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)25 & (b) will be met because MICHAEL E. OLSEN will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., the

MICHAEL E. OLSEN Aerial Operations Manual, Monthly Maintenance Log, and DJI
UAS Aircraft Instruction Manual).

Furthermore, MICHAEL E. OLSEN will document and maintain all maintenance
records for the DJI UAS Aircraft UASs.

Since the DJI UAS Aircraft will be inspected as prescribed by the operating documents, MICHAEL E. OLSEN will maintain the equivalent level of safety
establi shed by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI
UAS Aircraft User Manuals are attached hereto as Appendix A and B; a copy of the
DJI UAS Aircraft Maintenance LOG is attached hereto as Appendix C.

Likewise, the exemption sough t will not adversely affect safety because MICHAEL E.

OLSEN 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 DJI UAS Aircraft 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 t echnical characteristics and operating
limitations of the UAS are considered.

In consideration of MICHAEL E. OLSEN proposed operating limitations, the operating documents, and the technical aspects of the DJI UAS Aircraft

, MICHAEL E.

OLSEN submits that sa fety 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 respe cts, 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).

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, MICHAEL E. OLSEN26 requests that the FAA prescribe special conditions for the intended operation of the
DJI UAS Aircraf t UASs, which contain such safety standards t hat 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),

91.4 07(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAs for the limited purpose of conducting aerial video and photography over certain areas of the United States for compensation or hire.

FMRA Se ction 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 c ertification 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 UAS Aircraft UASs, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special Conditions, states the following:

If the FAA fi nds 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 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 t o 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 operation of the DJI UAS
Aircraft , 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).

A Summary That Can Be Published in The Federal Register, stating: The Rules from
Which MICHAEL E. OLSEN Seeks Exemption:

MICHAEL E. OLSEN 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).27 A Brief Description of the Nature of the Exemption MICHAEL E. OLSEN Seeks:

This ex emption will permit MICHAEL E. OLSEN 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 MICHAEL E. OLSEN 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, MICHAE L E. OLSEN 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, MICHAEL E. OLSEN will operate DJI UAS aircraft safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.

CONCLUSION

As set forth herein, MICHAEL E. OLSEN 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 UAS Aircraft 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 MICHAEL E. OLSEN to safely, efficiently, and economically

opera te the DJI UAS Aircraft commercially within the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, MICHAEL E. OLSEN respectfully requests that the Administrator grant this Pet ition 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 UAS Aircraft commercially for the purpose of28 conducting aerial video and photography over certain areas of the United States.

Dated: May 10, 2015

Attachments to this submission :

DJI Inspire 1 Manual
DJI Phantom 3 Manual

Very respectfully,

Michael E Olsen

14 Old Town Lane
Halest , NY 11743

516

- 317

- 6222 meolsen@yahoo.com

DJI Inspire 1 Manual

http://download.dji

innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.2_en.pdf

DJI Phantom 3 Manual

http://download.dji

innovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manu al_v1.0_e n.pdf

# DJI Inspire 1 specifications

Aircraft Model

T600 Weight (Battery Included) 2935 g Hovering Accuracy (Gps Mode)
Vertical: 0.5 m
Horizontal: 2.5 m Max Angular Velocity
Pitch: 300°/s
Yaw: 150°/s Max Tilt Angle
35° Max Ascent Speed
5 m/s Max Descent Speed

4 m/s Max Speed 22 m/s (ATTI mode, no wind) Max Flight Altitude
4500 m Max Wind Speed Resistance

10 m/s Max Flight Time Approximately 18 minutes
Motor Model
DJI 3510 Propeller Model
DJI 1345 Indoor Hovering Enabled by default Operating Temperature Range

- 10° to 40° C Diag onal Distance
559 to 581 mm Dimensions
438x451x301 mm

## Gimbal Model

ZENMUSE X3 Output Power (With Camera)
Static: 9 W
In Motion: 11 W Operating Current
Station: 750 mA
Motion: 900 mA Angular Vibration Range

±0.03° Mounting
Detachable Controllable Range

Pitch:

- 90° to +30°
Pan: ±320° Mechanical Range
Pitch:

- 125° to +45°
Pan: ±330° Max Controllable Speed
Pitch: 120°/s
Pan: 180°/s 

## Camera Name
X3 Model
FC350 Total Pixels

12.76M Effective Pixels

12.4M Image Max Size

4000x3000 Iso Range
100

- 3200 (video)
100

- 1600 (photo) Electronic Shutter Speed

8s

- 1/8000s Fov (Field Of View)

94°
Cmos

### Sony EXMOR 1/2.3”
Lens 20mm (35mm format equivalent)f/2.8 focus at ∞ 9 Elements in 9 groups
Anti

- distortion Still Photography Modes Single shoot Burst shooting: 3/5/7 frame s Auto Exposure Bracketing (AEB): 3/5 bracketed frames at 0.7EV Bias
Time

- lapse Video Recording Modes UHD (4K): 4096x2160p24/25, 3840x2160p24/25/30 FHD: 1920x1080p24/25/30/48/50/60 HD: 1280x720p24/25/30/48/50/60 Max Bitrate Of Video Storage 60 Mbps Support ed File Formats

FAT32/exFAT Photo: JPEG, DNG Video: MP4/MOV (MPEG

- 4 AVC/H.264) Supported Sd Card Types

Micro SD Max capacity: 64 GB. Class 10 or UHS

- 1 rating required. Operating Temperature Range

0° to 40° C 

## Remote Controller Name
C1 Operating Frequency 922.7~927.7 MHz (Japan Only)
5.725~5.825 GHz
2.400~2.483 GHz Transmitting Distance (Outdoor And Unobstructed)

2 km Eirp 10dBm@900m, 13dBm@5.8G, 20dBm@2.4G Video Output Port USB, mini

- HDMI Power Supply

Built

- in battery Charging

### DJI charger Dual User Capability

Host

- and

- Slave connection
Mobile Device Holder
Tablet or Phone Max Mobile Device Width

170mm Output Power
9 W Operating Temperature Range

- 10° to 40° C Storage Temperature Range
Less than 3 months:

- 20° to 45° C
More than 3 months: 22° to 28° C Charging Temperature Range

0

- 40° C Battery
6000 mAh LiPo 2S 

## Charger Model

A14

- 100P1A Voltage

26.3 V
Rated Power

100 W 

## Battery (Standard) Name Intelligent Flight Battery Model

TB47 Capacity
4500 mAh Voltage

22.2 V Battery Type LiPo 6S High voltage battery Energy
99.9 Wh Net Weight 570 g Operating Temperature Range

### - 10° to 40° C Storage Temperature Range
Less than 3 months:

- 20° to 45° C
More than 3 months: 22° C to 28° C Charging Temperature Range

0° to 40° C Max Charging Power

180 W 

## Battery (Optional) Name Intelligent Flight Battery
Model

TB48 Capacity
5700 mAh Voltage

22.8 V Battery Type
LiPo 6S Energy
129.96 Wh Net Weight 670 g Operating Temperature Range

- 10° to 40° C Storage Temperature Range
Less than 3 months:

- 20 to 45° C
More than 3 months: 22° to 28° C Charging Temperature Range

0° to 40° C Max Charging Power

180 W 

## Vision Positioning Velocity Range Below 8 m/s (2 m above ground) Altitude Range
5

- 500 cm Operating Environment Brightly lit (lux > 15) patterned surfaces Operating Range

0

- 250 cm

## DJI Pilot App Mobile Device System Requirements
iOS 8.0 or later
Android 4.1.2 or later Supported Mobile Devices * Compatible with iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air Wi

- Fi + Cellular, iPad mini 2, iPad mini 2 W i

- Fi + Cellular, iPad Air 2, iPad Air 2 Wi

- Fi + Cellular, iPad mini 3, and iPad mini 3 Wi

- Fi + Cellular. This app is optimized for iPhone 5s, iPhone 6, and iPhone 6 Plus. * Samsung S5, Note 3, Sony Xperia Z3, Google Nexus 7 II, Google Nexus 9, Mi 3, Nubia Z7 mini *Support for additional Android devices available as testing and development continues1 

# Phantom 3 Professional

Phantom 3 Professional

Battery 6000 mAh LiPo 2S

Phantom 3
Professional Weight 1280g (with battery & propellers)

Hover Accuracy (Ready to Fly) Vertical: +/

- 0.1 m (when Vision Positioning is active) or +/

- 0.5 m Horizontal:1.5m

Max Ascent / Descent Speed Ascent: 5m/s Descent: 3m/s Max Flight Speed 16m/s((ATTI mode, no wind)

Diagonal Length 590mm

Controllable Range of Gimbal Pitch

- 90°to +30°

The Phantom 3 Professional’s flight controller features several important upgrades, including a new flight mode. Safety modes include Failsafe and Return

- to

- Home. These features ensure the safe return of your aircraft if the control signal is lost. The flight controller can also save critical flight data from each flig ht to the on

- board storage device. The new flight controller also provides increased stability and a new air braking
feature.

GENERAL FEATURES

▪ Epic Aerial Video

▪ Live HD View

▪ Complete Control

▪ Powerful Mobile App2 ▪ Vision Positioning

▪ Easy to Fly

▪ Worry

- free Autopilot

▪ Intelligent Battery

▪ Supports Adobe DNG RAW

▪ Unmatched Propulsion

▪ SDK Development

VISION POSITIONING

▪ Max Velocity: Less than 8 m/s (when 2 m above ground)

▪ Altitude Range: 30 cm

- 300 cm

▪ Operating Range: 30 cm

- 300 cm</td></tr>

▪ Transmitter Power:CE: 25mw; FCC: 100mw

▪ Operating Environment: Surface with clear pattern and adequate lighting (Lux > 15)

CAMERA

▪ Sensor: Sony EXMOR 1/2.3” Effective pixels: 12.4 M (total pixels: 12.76 M)

▪ Lens: FOV 94° 20 mm (35 mm format equivalent) f/2.8, focus at ∞

▪ ISO Rang e : 100

- 3200 (video) 100

- 1600 (photo)

▪ Max Bitrate Of Video Storage: 60 Mbps

▪ Operating Temperature: 0°C to 40°C

REMOTE CONTROLLER

▪ Operating Frequency: 2.400 GHz

- 2.483 GHz

▪ Max Distance: 2000m (outdoors and unobstructed)

▪ Receiver Sensitivity (1%PER):

- 101 dBm ±2 dBm

▪ Transmitter Power (EIRP): FCC: 20 dBm CE: 16 dBm

▪ Working Voltage: 1.2 A @7.4 V

DJI VISION APP

▪ EIRP: 100mW

▪ Live View Working Frequency: 2.4GHz ISM

▪ Live View Quality : 720P @ 30fps (depending on conditions and mobile device)

▪ Required Operating System s : iOS 8.0 or later, Android 4.1.2 or later

▪ Recommended Devices: iOS: iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air
Wi

- Fi + Cellular, iPad mini 2, iPad mini 2 Wi

- Fi + Cellular, iPad Air 2, iPad Air 2
Wi

- Fi + Cellular, iPad mini 3, and iPad mini 3 W i

- Fi + Cellular. This app is optimized for iPhone 5s, iPhone 6, and iPhone 6 Plus Android: Samsung S5, Note 3, Sony Xperia Z3, Google Nexus 7 II, Google Nexus 9, Mi 3, Nubia Z7 mini

### Pack List

- Phantom 3 Pro

- Battery #1 (Charged)

- Controller (Charged)

- iPad Mini 2 (Charged)

- Props (2 sets)

- Micro SD Cards

- USB Cable

- Reading Glasses

- Sun Shade for iPad

- Lanyard

- DJI Charger

- Phone for HotSpot 

### Pre

- Flight

- Connect USB to iPad

- Download Area Maps

- Connect Lanyard

- Remove Lens Cover

- Remove Gimbal Bracket

- Insert Micro SD Card

- Install Battery in P3P

- Install Props

- Turn On Radio

- Turn On iPad and Launch DJI Pilot app Max Volume

- Turn Off WIFI

- Place P3P at Take

- Off Location (Home Point)

- Turn On P3P

- Adjust Camera Settings

- Format Micro SD Card

- Check Values:

- Compass Status

- IMU Values

- Gain Values and EXP

- Max Height

- RTH Height

- R/C EXP & Gain

- VPS On (Indoor Flight)

- Satellite Count 

### Hover Check

- Check Camera View and
Level

- Check for Vibrations

- Check Distance to Home

Point



### Post Flight

- Turn Off P3P (First)

- Turn Off Radio

- Turn Off iPad

- Remove Props

- Install Gimbal Lock

- Install Lens Cover