UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC

Name and Address Of The Petitioner:

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

**AI RWOLFE, LLC**  211 Big Tree Road, South Daytona, Fla. 32119 CELL: 540

- 220

- 8885 Email: billcroom32@gmail

**PURSUA NT TO SECTION 333 OF**  **THE FAA**

**MODERNIZA TION A**  **ND REFORM A CT OF 2012**  **(PUBLIC LA**

**W 112**

**- 95)**  Submitted on March 6, 2016 Wi lliam P. Croom AIRWO LFE, LLC 211 Big Tree Road, South Daytona, Fla. 32119 CEL L: 540

- 220

- 8885 Email: billcroom32@gmail Private Pilot Certificate with Glider Rating Certificate No. 231703257

**SUMMA RY**  **AI RWOLFE, LLC**  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), 91.40 7(a)(1), 91.409(a)(1) & (a)(2),and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 ofthe FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit AIRWO LFE, LLC to operate an Unmanned Aircraft commercial pu rpose of conducting aerial video and photography of construction sites, real estate, special events, and landscape over certain areas of the United States.

**INTRODUCTION AND INTERESTS OF THE PETITIONER**  AIRWO LFE , LLC provides its clients with expertise and knowledge in drone advanced technologies and solutions to provide ph oto, videography and monitoring services. **AI RWOLFE**  **, LLC** also provides its clients w ith the highest quality digital content for use in their commercial, personal, and non

- p rofit multimedia projects. As a holder of a Private Pilot License since 1979, the principal, W illiam P. Croom has over 20 years of recreational/ hobby experience in all aspects of aerial video and photography.The objective of **AI RWOLFE, LLC**  aerial video and photography op erations is to provide

high quality imaging for a variety of commercial, public, and residential uses, including:

Aerial inspections of public and private structures. Aerial photography/videography of residential and commercial buildings Aerial event photography/videography Aerial Appraisals Real Estate Marketing Insurance Inspections of Home and Property Commercial Advertising Video and Photography Real Estate Photography and Videography No cost services offered to community, firefighter and state officia ls Aerial surveying Construction site inspections and monitoring Wi ldlife and forestry monitoring system (UAS)

**BA CKGROUND**  Unmanned Aircraft Systems: DJI Phantom 3 UAS and DJI Inspire 1 **AI RWOLFE**  **, LLC** seeks an exemption to operate DJI systems for compensation or hire within the NAS. The DJI Phantom 3 and the DJI Inspire 1 are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The DJI Phantom 3 has a maximum gross weight of 1260 grams and a maximum speed of approximately 16 m/s. The DJI Inspire 1has a maximum gross weight of 2935 grams and a maximum speed of approximately 22 m/s. The DJI Phantom 3 and DJI Inspire 1 UA’s are equipped w ith four main rotors; Driven by Lithium Polymer battery powered electric motors.

**BA SIS FOR PETITION**  Petitioner, **AI RWOLFE**  **, LLC** , pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and th e FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems

, hereby petitions the Administrator to commercially operate the DJI Phantom 3 and the DJI Inspire 1 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, 91.1 51(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

**A. Name and A** **ddress Of The Petitioner.** The name and address of the Petitioner and point of contact is: Wi lliam P. Croom **AI RWOLFE, LLC**  211 Big Tree Road South Daytona, Florida 32119 Tel: (540) 220

- 8885**B. The Extent Of Relief AI**  **RWOLFE, LL** C **Seeks A nd The Reason**  **AI RWOLFE, LLC** 

**Seeks The Relief.**

**1. Extent Of Relief AI**  **RWOLFE, LLC Seeks A**  **nd The Reason AI**  **RWOLFE, LLC Seeks Relief From Section 61.113(a) A**  **nd (b).** Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command , is requested to the extent necessary to allow a PIC holding a private pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met certain flight

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

This relief is req uested 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. As set forth more fully below, **AI RWOLFE, LLC**  submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the DJ I Phantom 3 UAS unless that PIC has met certain flight

- hour and currency requirements, demonstrating that the PIC is able to safely operate either the DJI Phantom 3 and DJI Inspire 1 UAS in a manner consistent with the operations specifications as describe d in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures.

**2. Extent Of Relief AI**  **RWOLFE, LLC Seeks A**  **nd The Reason AI**  **RWOLFE, 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 Max Aerial Imagery, LLC to determine that the DJI Phantom 3 DJI Inspire 1 UAS are in airworthy condition prior to every fli ght by ensu ring that the UAS is in compliance with the operating documents provided online by DJI, the manufacturer, at http://www.dji.com/product/phantom

- 3/download and 5 http://www.dji.com/product/inspire

- 1/download AIRWO LFE, LLC seeks the requested relief because the DJI Phantom 3 and DJI Inspire 1 UAS do not require an airworthiness certifica te in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Max Aerial Imagery, LLC will ensure that the DJI Phantom 3 and DJI Inspire 1 U AS are in airworthy condition bas ed upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 and DJI Inspire 1 ( Instruction Manual) prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated in the conditions and limitations below.**3. Extent Of Relief AI**  **RWOLFE, LLC Seeks A**  **nd The Reason AI**  **RWOLFE, LLC**

**Seeks Relief From Section 91.121.** Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the DJI Phantom 3 and DJI Inspire 1 UA S, which utilize a GPS altitude reading, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PIC at the ground c ontrol station (GCS). Since the FAA requires that any altitude information concerning UA S operations be reported to air traffic control (ATC) in feet above ground level (AGL), AIR WO LFE, LLC seeks the requested relief because the DJI Phantom 3 and DJI Inspire 1 UAS 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.

**4. Extent Of Relief AI**  **RWOLFE, LLC Seeks A**  **nd The Reason AI**  **RWOLFE, LLC Seeks Relief From Section 91.151(b).** 

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions , is requested to the extent required to allow flights of the battery powered DJI Phantom 3 and DJI Inspire 1 UA during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 14 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4 minutes. Max Aerial Imagery, LLC seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powe red DJI Phantom 3 and DJI Inspire 1 UAs will severely constrain the practicality of any aerial video or still photo flight operations that Max Aerial Imagery, LLC proposes to conduct pursuant to this Petition. Significantly, as set forth below, the technical specifications of the DJI Phantom 3 and DJI Inspire 1 UAS operating documents, and Max Aerial Imagery, LLC proposed operating limitations, ensure that Max Aerial Imagery, LLC will safely operate the battery powered DJI Phantom 3 and DJI Inspire 1 UA dur ing daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total duration of 14 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4 minutes.**5. Extent Of Relief AI**  **RWOLFE, LLC Seeks A**  **nd The Reason AI**  **RWOLFE, LLC**

**Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), A**  **nd 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, AIRWO LFE, LLC requests relief from these Sections because the DJI Phantom 3 and DJI Inspire 1 UAS do not require airworthiness certificates. As set forth more ful ly be low, the DJI Phantom 3 and DJI Inspire 1 UAS meet the conditions of FMRA Section 333 for operation without

an airworthiness certificate. Accordingly, AIRW OLFE, LLC will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS operating documents Online at http://www.dji.com/product/phantom

- 3/download and http://www.dji.com/product/inspire

- 1/download AIRWO LFE, LLC will document and maintain all mainten ance records for the DJI Phantom 3 and DJI Inspire 1.

**D. The Reasons Why**

**Granting** AIRWO LFE, LLC **Request Would Be In The Public Interest; That Is, How It Would Benefit The Public A**  **s A Whole.**  Granting the present Petition will further the public interest by allowing **AI RWOLFE,**  **LLC** to safely, efficiently, and economically perform aerial video and photography of construction sites, real estate, special events, film sets, and landscape over cert ain areas of the United States. Additionally, use of the DJI Phantom 3 and the DJI Inspire 1 UAS will decrease congestion of the NAS, reduce pollution, and provide signi ficant benefits to the economy. Notably, the benefits of AIR WO LFE, LLC proposed operation of the DJI Phantom 3 and the DJI Inspire 1 UAS will be realized without implicating any privacy issues.

**1. The Public Will Benefit From Decreased Congestion Of The NA S.**  The DJI Phantom 3 and the DJI Inspire 1 UAs are battery powered and serve as a safe, e fficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned ai rcraft needed to perform aerial acquisitions, an exemption allowing the use of a DJI Phantom 3 and the DJI Inspire 1 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground. Furthermore, by reducing the number of manned aircraft operating in the N AS, congestion around airports caused by arriving and departing aircraft will be reduced. The DJI Phantom 3 and the DJI Inspire 1 UA do not require an airport to takeoff or land.**2. The Public Will Benefit From The Safety A nd Efficiency**  **Of The DJI Phantom 3 and the DJI Inspire1 UA** **S.** Conducting aerial acquisitions with the DJI Phantom 3 and the DJI Inspire 1 UASs, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aer ial video and still photography flight operations. By using battery power and electric mo tors, the DJI Phantom 3 and the DJI Inspire 1 UAS produce no air pollution, and is the most viable environmentally conscious alternative to the cab in c lass, six cylinder internal combustion engine aircraft that are typically utilized for aerial video and photography. The DJI Phantom 3 and the DJI Inspire 1 UA, while reducing the carbon footprint of aeria l acquisitions, also eliminates noise pollution, as the UA are propelled by battery powered electric motors, rather than an internal combustion engine. By using the DJI Phantom 3 and the DJI Inspire 1 UAS to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground , which is usually associated with traditional manned aircraft flight operations, will be substantially reduced.

**3. Performing A erial Video and Photography**  **Operations w ith DJI Phantom 3**  **and the DJI Inspire 1 UA S Will Benefit The Economy** 

**.** In addition to be ing safe and efficient, the DJI Phantom 3 UAS are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom 3 UAS will allow United States based companies, like **AI RWOLFE, LLC**  , to remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies mus t adopt new and alternative technology in order to remain competitive. Operating the battery powered DJI Phantom 3 UAS is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft. By operating the DJI Phantom 3 and the DJI Inspire 1 UAS, AIRWO LFE, LLC , 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. compa nies, through commercial use of the DJI Phantom 3 and the DJI Inspire 1 UAS, provides a stable workforce tha t increases consumer spending; improves local, state, and federal tax revenues.**4. There A re No Privacy**  **Issues.** Similar to the manned aerial acquisition flight operations that have been conducted for decades, **AI RWOLFE, LLC**  proposed operation of the DJI Phantom 3 and the DJI Inspire 1 UAS will not implicate any privacy issues. Specifically, the DJI Phantom 3 and the DJI Inspire 1 UAS will be operated only in compliance with operating documents which requires property owner involvement as well as loca l law enforcement notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.
**E. The Reasons Why**

**Granting The Exemption Would Not A dv** **ersely A**  **ffect Safety, Or How The**  **Exemption Would Provide A Lev** **el Of Safety**

**A t Least Equal To That**  **Provided By**

**The Rule From Which** AIRW OLFE, LLC **Seeks Exemption. 1. Reasons Why** 

**The DJI Phantom 3 and DJI Inspire 1 UA ’s Meet The**  **Conditions Of The FAA Modernization and Reform A** **ct of 2012 (FM RA** **) Section 333.**  In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, AIRWO LFE, LLC operation of the DJI Phantom 3 and the DJI Inspire 1 UAS meet the cond itions of FMRA Section 333

, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpa rt H. Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will crea te a hazard to users of the NAS or the public, or otherwise pose a threat to national security.

**a. The Specifications Of The The DJI Phantom 3 and DJI Inspire 1 UA ’s**  **UA S Demonstrate Its Safe Characteristics.** 

The DJI Phantom 3 and DJI Inspire 1 UAS do 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 and DJI Inspire 1 UA** **S.** The technical spec if ications of the DJI Phantom 3 UAS are set forth by the DJI Phantom 3 Specifications and Data Sheet, attached hereto as Exhibit A. The DJI Inspire 1 UAS Specifications and Data Sheet, attached hereto as Exhibit C.

**ii. The DJI Phantom 3 and DJI Inspire 1 UA** **’s A utonomous Flight A**  **nd Navigation Modes Enable The UA** **S To Remain Within A Defined**  **Operational A rea.**  The DJI Phantom 3 and the DJI Inspire 1 UAS may be op erated in both manual and fully autonomous flight modes.**iii. The DJI Phantom 3 and DJI Inspire 1 UA** **’s A re Designed For A**  **utomatic**

**Return To Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation.** 

Wh en the Control Link is lost, the DJI Phantom 3 and the DJI Inspire 1 UA will remain stationary, in flight, for 3 seconds or m ore. If, aft er 3 seconds, the DJI Phantom 3 UA 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 po sition and shutdown. A complete description of the Failsafe Functions of the DJI Phantom 3 and the DJI Inspire 1 UAS is provided in the Manufacturer’s User Manual

. **b. Flights Of The DJI Phantom 3 and DJI Inspire 1 UA ’s Will Be**  **Conducted Pursuant To Specific Operating Limitations.**  In seeking this exemption, AIRW OLFE, LLC proposes to commercially operate DJI Phantom 3 and DJI Inspire 1 UAS for the special purpose of conducting aerial video and photography over certain areas of United States, pursuant t o 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 Phan tom 3 and DJI Inspire 1 Unmanned Aircraft Systems. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant.

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

3. The UAs may not be flown at an indicated airspeed exceeding 20 knots.
4. The UAs must be operated at an altitude of no more than 400 feet above ground level (AGL), as indicated by the procedures specified i n the operating documents unless a special request is made and approved by ATC. All altitudes reported to ATC must be in fee t 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, 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 ut ilize 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 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 and is not permitted to operate the camera or other instruments.

9. The operating documents and the grant of exempti on must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and lim itations contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the gra nt of exemption take precedence and must be followed. Otherwise, the operator must fo llow the procedures as outlined in its operating documents. The op erator may update or revise its operating documents. It i s the operator’s respons ibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revise d documents if it petitions for extension or amendment to the grant of exe mpt ion. If the operator determines that any update or revision would affect the b asis upon which the FAA granted the exemption, then the operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration Offi ce (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 U AS to ensure that it is in a condition for safe flight. If the inspection revea ls a condition that affects the safe operat ion of the UAS, the aircraft is proh ibited from operating until the necessary maintenance has been performed and the UAS is found to b e in a condition for safe flight. The Ground Control Station must be included in the 13 preflight inspection. All maintena nce a nd 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 fun ctional test f light. The PIC who conducts the functional test flight must make an entry in the aircraft records.

12. The pre

-flight inspection must account for al l potential discrepancies, e.g. inoperable components, items, or equipm ent, not already covered in the relevant sections of the operating documents.

13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements.14. The operator must carry out its maintenance, inspections, and record keeping

requirements, in accordance with the op erating documents. Maintenance, inspection, alterations, and status of repla cement/overhaul component parts must be noted in the aircraft records, including tot al time in service, desc ription of work accomplished, and the signature of the authorized person returning the UAS to service.

15. Each UASs operated under this exemption mu st comply with all manufacturer Safety Bulletins.

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

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

- class medical certificate.

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and mai ntaining 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 of the exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, an d the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119.

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorol ogical conditions (VMC). If flight at night is required, a special request will be made at the FAA office closest to proposed area of operations. Flig hts under special visual flight rules (SVFR) are not authorized.
20. The UA may not operate within 5 nautic al miles of an airport reference point as denoted on a current FAA

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

21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.22. If the UA loses communications or loses its GPS signal, it must return to a

predetermined location within the planned operating area and land or be recovered in accordance wit h the operating documents. 23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents.

24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather c onditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 25% battery power remaining.

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Wa iver 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 b e conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requirements.

26. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (N

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

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

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made available to the Administrator or any law en forcement official upon request.
29. The UA must remain clear and yield the right of way to all man ned aviation operations and activities at all times.

30. The UAS may not be operated by the PIC from any moving device or vehicle.31. Flight operations must be conducted at least 500 feet from all nonparticipating

persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless: a. Barriers or structures are present that suffic iently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must en sure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, veh icles or structures has granted permission and the PIC has made a s afety assessment of the risk of operating closer to those objects and dete rmined that it does not present an undue hazard, and; c. Operations nearer to the PIC, SO, operato r trainees or essential persons do not present an undue hazard to those persons per § 91.119(a).

32. All operations shall be conducted over private or controlled

- access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted

33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by 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 ins tructions contained on the NTSB W eb site: www.ntsb.gov

.

**An y**  **Ad ditional Information, Views, Or A** **rguments Available To Support**  **AI RWOLFE, LLC**  **Request.** This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transpo rtation to determine if certain UAS may operate safely in the NAS. As such, Max Aerial Imagery, 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, AIR WO LFE, LLC will operate the DJI Phantom 3 UAS safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.**CONCLUSION**

As set forth herein, AIRW OLFE, 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 and DJI Inspire UAS commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandat e of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing AIRWO LFE, LLC to safely, efficiently, and economically operate the DJI Phantom 3 UAS commercially within the NAS.

**WHEREFORE** , in accordance wit h the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, Max Aerial Imagery, LLC respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a),91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit **AI RWOLFE, LLC**  to operate the DJI Phantom 3 and DJI Inspire 1 UAS commercially for the purpose of conducting aerial video and photography over certain areas of the United States.

Dated: March 6, 2016 Respectfully submitted, Wi lliam P. Croom **AI RWOLFE, LLC**  211 Big Tree Road South Daytona, Florida 32119 Tel: (540) 220

- 8885