Attn:

U. S. Department of Transportation Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Ave, SE Washington, DC 20590

RE: Dennis McDOugall dba. MDEZIN CREATIVE GROUP

REQUEST AN EXEMPTION FROM THE REQUIREMENTS OFTITLE 14 OF THE CODE

OF FEDERAL REGULATIONS

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) &

(a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF DJI Phantom

3UNMANNED AIRCRAFT SYSTEMSPURSUANT TO SECTION 333 OF THE FAA MOD

ERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Dennis McDougall (owner)

MDEZIN CREATIVE GROUP

224 Pease Ct. Janesville WI 53545

608-774-3623

dmcdougall@mdezin.com

1TABLE OF CONTENTS

Page

GLOSSARY OF ABBREVIATIONS...................................................................................3

SUMMARY...........................................................................................................................4

INTRODUCTION AND INTERESTS OF PETITIONER....................................................4

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

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

NAME AND ADDRESS OF PETITIONER.........................................................................6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH THEMDEZIN CREATIVE GROUP

SEEKS EXEMPTION............................................................................................................7

THE EXTENT OF RELIEF THEMDEZIN CREATIVE GROUP SEEKS AND THE REASON THE

MDEZIN CREATIVE GROUP SEEKS THE RELIEF..............................................................10

THE REASONS WHY GRANTING THEMDEZIN CREATIVE GROUP’S REQUEST WOULD

BE IN THE PUBLIC INTEREST ............................................................................................12

THE REASONS WHY GRANTING THE EXEMPTION TO THE MDEZIN CREATIVE GROUP

WOULD NOT ADVERSELY AFFECT SAFETY..............................................................14

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER...................25

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUP

PORT THE MDEZIN CREATIVE GROUP’S REQUEST..................................................25

CONCLUSION.....................................................................................................................25

APPENDICES.........................................................................................26

2GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

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

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing

3SUMMARY

Dennis McDougall, dba. MDEZIN CREATIVE GROUP hereafter referred to as The MDEZIN

CREATIVE GROUP seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b),

91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b),

to operate an Unmanned Aircraft System (DJI Phantom 2+) pursuant to Section 333 of the FAA

Modernization and Reform Act of 2012 (FMRA). This exemption will permit The MDEZIN

CREATIVE GROUP to operate an Unmanned Aircraft System (UAS ) for the commercial pur

pose of conducting aerial video and photography of construction sites, residential and commer

cial real estate, civil landscapes and eventsover certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

The MDEZIN CREATIVE GROUP has for over 15 years provided their clients (which include

private sector businesses and non-profits, along with local state agencies) with expertise and

knowledge in video and multimedia marketing, advertising, public relations and training us

ing advanced technologies and solutions. The MDEZIN CREATIVE GROUP has worked on

thousands of productions over the past 15 years in all types of locations with a perfect client and

employee safety record. The objective of The MDEZIN CREATIVE GROUP and our Unmanned

Aircraft System (DJI Phantom 2+) aerial operations is to provide a more affordable, high-quality

production system for a variety of governmental, commercial, public, and residential uses, spe

cifically targeting

• Construction sites before and after

• Appraisals

• Real-estate marketing

• Economic development

• Civic land marks

• Special event coverage

• Private and governmental training

My staff has safely flown small RC electric quadcopters recreationally for approximately 2 years

without incident.

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 2+, UAS

The MDEZIN CREATIVE GROUP seeks an exemption to operate DJI Phantom 2+ system

for compensation or hire within the NAS. The DJI Phantom 2+is vertical takeoff and landing

(VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tab

let or smart phone systems. The DJI Phantom 2+ has a maximum gross weight of approximately

2.8lb. while having a diagonal dimension of 23.2”, a maximum speed of approximately 16.4’fp

sand a maximum flyingheightof 400’. The DJI Phantom 2+ is equipped with four main rotors;

driven by Lithium Polymer battery powered electric motors.

4The DJI Phantom 2+ that will be operated by The MDEZIN CREATIVE GROUP will be reg

istered in accordance with 49 U.S.C. 44103, Registration of Aircraft , as well as 14 C.F.R Part

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

Registration Marking

.

BASIS FOR PETITION

Petitioner, The MDEZIN CREATIVE GROUP, pursuant to the provisions of the Federal Aviation

Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA),

Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereby petitions the

Administrator to commercially operate the DJI Phantom 2+, UAS in the National Airspace System

(NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a),

91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

In consideration of the speed, weight, size, and limited operating area associated with the un

manned aircraft and its operation, The MDEZIN CREATIVE GROUP operation of DJI Phantom

2+ UAS meets the conditions of FMRA Section 333 and therefore, will not require an airworthi

ness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, The MDEZIN CREATIVE GROUP 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.

The MDEZIN CREATIVE GROUP submits that the requested relief is proper since an equivalent

level of safety will be ensured. TheMDEZIN CREATIVE GROUP will use experienced person

nel or technicians to perform maintenance, alterations, or preventive maintenance on the UAS

using the methods, techniques, and practices prescribed in the operating documents (i.e., Month

ly Maintenance Log, and DJI Phantom 2+Instruction Manual). Furthermore, The MDEZIN

CREATIVE GROUP will document and maintain all maintenance records for the DJI Phantom

2+UAS .

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

and limitations: Pilot in command , is requested by The MDEZIN CREATIVE GROUP to the

extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level certifi

cate, as well as an airman medical certificate, and who has demonstrated, by meeting minimum

flight-hour and currency requirements, that the PIC is able to safely operate the DJI Phantom

UAS in a manner consistent with this exemption, including evasive and emergency maneuvers

and maintaining appropriate distances from people, vessels, vehicles and structures.

The MDEZIN CREATIVE GROUP seeks relief from Section 91.7(a), entitled Civil aircraft

airworthiness

, because the DJI Phantom 2+ UAS do not require an airworthiness certificate

in accordance with 14 C.F.R. Part 21, Subpart H. As such, The MDEZIN CREATIVE GROUP

submits that theywill ensure that the DJI Phantom 2+UAS isin an airworthy condition, prior to

every flight, by determining that the UAS are in compliance with the operating documents (i.e.,

Monthly Maintenance Log, and DJI Phantom 2+ Instruction Manual), and that the aircraft are in a

condition for safe flight.

5The MDEZIN CREATIVE GROUP also seeks an exemption from the requirements of Section

91.121, entitled Altimeter Settings , as the DJI Phantom 2+UAS will not have a typical barometric

altimeter onboard. However, altitude information of the DJI Phantom 2+ UAS 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 The MDEZIN CREATIVE GROUP’s operation of the DJI

Phantom 2+ UAS within visual line of sight, at or below 400 feet AGL, will ensure a level of

safety equivalent to Section 91.121.

Additionally, The MDEZIN CREATIVE GROUP seeks an exemption from the requirements of

Section 91.151(b), entitled Fuel requirements for flight in VFR conditions . The MDEZIN CRE

ATIVE GROUP submits that safety will not be affected by operation of the DJI Phantom 2+UAS

during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR),

with enough battery power to fly for a total duration of approximately 23minutes. Battery power

indicators are also able to show exactly how much battery power is left, as well as how much

time is needed to return safely back to point of take off.

In accordance with 14 C.F.R. § 11.81, The MDEZIN CREATIVE GROUP provides the following

information in support of its petition for exemption:

A.Name And Address Of The Petitioner.

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

Dennis McDougall (owner)

MDEZIN CREATIVE

GROUP

224 Pease Ct. Janesville WI

53545

608-774-3623

dmcdougall@mdezin.com

6B. The Specific Sections Of 14 C.F.R. From Which The MDEZIN CREATIVE GROUP

Seeks Exemption.

1. The MDEZIN CREATIVE GROUP Seeks Exemption From The Requirements Of Sec

tion 61.113(a) And (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, sub

sections (a) and (b) prescribe the following, in relevant part:

(a) No person who holds a private pilot certificate may act as a pilot in command

(PIC) of an aircraft that is carrying passengers or property for compensation or hire;

nor maythat person, for compensation or hire, act as PIC of an aircraft.

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connec

tion with any business or employment if—

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire.

2. The MDEZIN CREATIVE GROUP Seeks Exemption From The Requirements Of Sec

tion 91.7(a).

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

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

3. The MDEZIN CREATIVE GROUP Seeks Exemption From The Requirements Of Section

91.121.

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

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level

of that aircraft, as the case may be, by reference to an altimeter that is set, when

operating--

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

(i) The current reported altimeter setting of a station along the route and

within 100 nautical miles of the aircraft;

(ii) 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

(iii) In the case of an aircraft not equipped with a radio, the elevation of the

departure airport or an appropriate altimeter setting available before

departure.

74. The MDEZIN CREATIVE GROUP Seeks Exemption From The Requirements Of Sec

tion 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 (con

sidering wind and forecast weather conditions) there is enough fuel to fly to the first

point of intended landing and, assuming normal cruising speed, to fly after that for at

least 20 minutes.

5. The MDEZIN CREATIVE GROUP Seeks Exemption From The Requirement Of Section

91.405(a).

Section 91.405, entitled Maintenance required , subsection (a), states the following: Each

owner or operator of an aircraft—

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall

between required inspections, except as provided in paragraph (c) of this section, have

discrepancies repaired as prescribed in part 43 of this chapter[.]

6. The MDEZIN CREATIVE GROUP Seeks Exemption From The Requirements Of Sec

tion 91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive maintenance, re

building, or alteration ,subsection (a)(1), states the following:

(a) No person may operate any aircraft that has undergone maintenance, preventive

maintenance, rebuilding, or alteration unless--

(1) It has been approved for return to service by a person authorized under § 43.7

of this chapter[.]

7. The MDEZIN CREATIVE GROUP Seeks Exemption From The Requirements Of Sec

tions 91.409(a)(1) And 91.409(a)(2).

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

(a) Except as provided in paragraph (c) of this section, no person may operate an

aircraft unless, within the preceding 12 calendar months, it has had --

(1) An annual inspection in accordance with part 43 of this chapter and has been

approved for return to service by a person authorized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance

with part 21 of this chapter.

88. The MDEZIN CREATIVE GROUP Seeks Exemption From The Requirements Of Sec

tions 91.417(a) And 91.417(b).

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

ing:

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each regis

tered owner or operator shall keep the following records for the periods specified in

paragraph (b) of this section:

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

cords of the 100-hour, annual, progressive, and other required or approved inspec

tions, as appropriate, for each aircraft (including the airframe) and each engine,

propeller, rotor, and appliance of an aircraft. The records must include--

(i) A description (or reference to data acceptable to the Administrator) of the

work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the aircraft

for return to service.

(2) Records containing the following information:

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

each rotor.

(ii) The current status of life-limited parts of each airframe, engine, propeller,

rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which

are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the

last inspection required by the inspection program under which the aircraft

and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety

directives including, for each, the method of compliance, the AD or safety di

rective number and revision date. If the AD or safety directive involves recur

ring action, the time and date when the next action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each ma

jor alteration to the airframe and currently installed engines, rotors, propel

lers, and appliances.

9(b) The owner or operator shall retain the following records for the periods pre

scribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until

the work is repeated or superseded by other work or for 1 year after the work is

performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and

transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 of

this chapter shall be retained until the defects are repaired and the aircraft is ap

proved for return to service.

C. The Extent Of Relief The MDEZIN CREATIVE GROUPSeeks And The Reason The

MDEZIN CREATIVE GROUPSeeks The Relief.

1. Extent Of Relief The MDEZIN CREATIVE GROUP Seeks And The Reason The

MDEZIN CREATIVE GROUPSeeks Relief From Section 61.113(a) And (b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in

command , is requested to the extent necessary to allow a PIC holding a private pilot or higher

level certificate, as well as a current and valid airman medical certificate, and who has met cer

tain 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 pri

vate 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, The MDEZIN CREATIVE GROUPsubmits that an equivalent level

of safety will be maintained because no PIC will be allowed to operate the DJI Phantom 2+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 2+UAS in a manner consistent with the opera

tions specifications as described in this exemption, including evasive and emergency maneuvers,

as well as maintaining appropriate distances from people, vessels, vehicles and structures.

Further, The MDEZIN CREATIVE GROUP submits that all flights of the DJI Phantom 2+UAS

, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to The MDEZIN

CREATIVE GROUP’s business; and (2) will not carry passengers or property for compensation

or hire.

102. Extent Of Relief The MDEZIN CREATIVE GROUP Seeks And The Reason The

MDEZIN CREATIVE GROUPSeeks Relief From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to the extent re

quired to allow The MDEZIN CREATIVE GROUPto determine that the DJI Phantom 2+ UAS

are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with

the operating documents (i.e., the MDEZIN CREATIVE GROUPAerial Operations Manual,

Monthly Maintenance Log, and DJI Phantom 2+Instruction Manual).

The MDEZIN CREATIVE GROUPseeks the requested relief because the DJI Phantom 2+ UAS

do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Therefore, The MDEZIN CREATIVE GROUPwill ensure that the DJI Phantom 2+ UAS are

in airworthy condition based upon its compliance with the operating documents (i.e., Monthly

Maintenance Log, and DJI Phantom 2+) prior to every flight, and further, determine that the air

craft are in condition for safe flight, as stated in the conditions and limitations below.

3. Extent Of Relief The MDEZIN CREATIVE GROUP Seeks And The Reason The

MDEZIN CREATIVE GROUP 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 2+UAS , which utilize a barometric pressure sensor, GPS equipment, and a

radio communications telemetry data link to downlink altitude information from the UA to the

PIC at the ground control station (GCS). Since the FAA requires that any altitude information

concerning UAS operations be reported to air traffic control (ATC) in feet above ground level

(AGL), The MDEZIN CREATIVE GROUP seeks the requested relief because the DJI Phantom

2+ UA’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric

pressure or field altitude, before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought

to the extent necessary to comply with the applicable conditions and limitations stated below. As

more fully set forth herein, an equivalent level of safety will be maintained since the DJI

Phantom 2+ UAS are equipped with a barometric pressure sensor and GPS equipment, which

automatically ensures that a ground level pressure setting will be established prior to each flight,

and provides the PIC with altitude information of the UA on the heads-up display of the GCS.

4. Extent Of Relief The MDEZIN CREATIVE GROUP Seeks And The Reason The

MDEZIN CREATIVE GROUP Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is request

ed to the extent required to allow flights of the battery powered DJI Phantom 2+ UAS during

daylight hours invisual meteorological conditions (VMC), under visual flight rules (VFR), for a

total duration of 23minutes.The MDEZIN CREATIVE GROUP seeks the requested relief be

cause without an exemption from Section 91.151(b), the flight time duration of the

11battery powered DJI Phantom 2+ UAS will severely constrain the practicality of any aerial video

or still photo flight operations that The MDEZIN CREATIVE GROUP proposes to conduct pur

suant to this Petition.

Significantly, as set forth below, the technical specifications of the DJI Phantom 2+ UAS

, the DJI

Phantom 2+ operating documents, and The MDEZIN CREATIVE GROUP’s proposed operating

limitations, ensure that The MDEZIN CREATIVE GROUP will safely operate the battery pow

ered DJI Phantom 2+ UAS during daylight hours in visual meteorological conditions (VMC),

under visual flight rules (VFR), with enough battery power to fly for a total duration of 18 min

utes.

5. Extent Of Relief The MDEZIN CREATIVE GROUP Seeks And The Reason The

MDEZIN CREATIVE GROUP 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, The MDEZIN CREATIVE GROUP requests relief from

these Sections because the DJI Phantom 2+ UAS do not require airworthiness certificates. As set

forth more fully below, the DJI Phantom 2+ UAS meet the conditions of FMRA Section 333 for

operation without an airworthiness certificate. Accordingly, The MDEZIN CREATIVE GROUP

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 docu

ments (i.e., the The MDEZIN CREATIVE GROUP Aerial Operations Manual, Monthly Mainte

nance Log, and DJI Phantom 2+ Instruction Manual). Furthermore, The MDEZIN CREATIVE

GROUP will document and maintain all maintenance records for the DJI Phantom 2+ UAS .

D. The Reasons Why Granting The MDEZIN CREATIVE GROUP Request Would Be In

The Public Interest; That Is, How It Would Benefit The Public As A Whole.

Granting the present Petition will further the public interest by allowing The ALTEK MEDIA

GROUP to safely, efficiently, and economically perform aerial video and photography of

construction sites, real estate, events and civic landscape over certain areas of the United States.

Additionally, use of the DJI Phantom 2+ UAS will decrease congestion of the NAS, reduce pol

lution, and provide significant benefits to the economy. Notably, the benefits of The MDEZIN

CREATIVE GROUP’s proposed operation of the DJI Phantom 2+ UAS will be realized without

implicating any privacy issues.

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

The DJI Phantom 2+ UAS are battery powered and serve as a safe, efficient, and economical al

ternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the

12amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use

of a DJI Phantom 2+UAS would reduce the amount of manned aircraft in the NAS, reduce noise

and air pollution, as well as increase the safety of life and property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion

around airports caused by arriving and departing aircraft will be reduced. The DJI Phantom

2+ UAS do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft

conducting aerial video and photography missions would result in fewer aircraft that must be

handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of

flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 2+ UAS .

Conducting aerial acquisitions with the DJI Phantom 2+ UAS , instead of manned aircraft, will

greatly benefit the public by drastically reducing the levels of air and noise pollution generated

duringtraditional aerial video and still photography flight operations. By using battery power and

electric motors, the DJI Phantom 2+ UAS produce no air pollution, and is the most viable en

vironmentally conscious alternative to the cabin class, six cylinder internal combustion engine

aircraft that are typically utilized for aerial video and photography, while burning approximately

20-30 gallons per hour of leaded aviation fuel. The DJI Phantom 2+ UAS , while reducing the

carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAS are propelled

by battery powered electric motors, rather than an internal combustion engine.

By using the DJI Phantom 2+ UAS to perform aerial acquisitions, the substantial risk to life and

property in the air and on the ground, which is usually associated with traditional manned aircraft

flight operations, will be substantially reduced or completely eliminated. Aside from the lack of

flight crew members located onboard the aircraft, the DJI Phantom 2+ UAS (weighing approxi

mately 2.8 pounds at their maximum gross weight with diagonal dimension of 23.2 inches, and

with no fuel on board), has less physical potential for collateral damage to life and property on

the ground, and in the air, compared to the manned aircraft that typically conduct similar opera

tions (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length

of 34 feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations With The DJI Phantom 2+

UAS Will Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 2+ UAS are also an economical alterna

tive to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI

Phantom 2+ UAS will allow United States based companies, like The MDEZIN CREATIVE

GROUP, 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 ac

tions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and

alternative technology in order to remain competitive. Operating the battery powered DJI Phan

tom 2+ UAS is one such technology that not only allows companies greater operational

13flexibility compared to manned aircraft, but provides such flexibility without the high operational

cost of a traditional manned aircraft.

By operating the DJI Phantom 2+ UAS , companies such as The MDEZIN CREATIVE GROUP,

can remain competitive and profitable, and therefore, provide greater job stability to employ

ees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved

financial performance of U.S. companies, through commercial use of the DJI Phantom 2+ UAS

, provides a stable workforce that increases consumer spending; improves local, state, and federal

tax revenues; and allows companies to invest in research and development in order to remain

competitive both in the United States and abroad.

4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for decades,

The MDEZIN CREATIVE GROUP’s proposed operation of the DJI Phantom 2+ UAS will not

implicate any privacy issues. Specifically, the DJI Phantom 2+ UAS will be operated only in

compliance with operating documents (i.e., the MDEZIN CREATIVE GROUP Aerial Operations

Manual, Monthly Maintenance Log, and DJI Phantom 2+ 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.

E. 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 The MDEZIN CREATIVE GROUP Seeks Exemption.

1. Reasons Why The DJI Phantom 3 UAS Meet The Conditions Of The FAA Mod

ernization and Reform Act of 2012 (FMRA) Section 333.

In consideration of the size, weight, speed, and limited operating area associated with the un

manned aircraft and its operation, The MDEZIN CREATIVE GROUP’s operation of the DJI

Phantom 2+ UAS meet the conditions of FMRA Section 333, and will not require an airworthi

ness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Section 333 provides authority for a UAS to operate without airworthiness certification and sets

forth requirements for considering whether a UAS will create a hazard to users of the NAS or the

public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the

following, in part:

(a) In General.--Notwithstanding any other requirement 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 nation

al 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.

14(b) Assessment of Unmanned Aircraft Systems.--In making the determination under

subsection (a), theSecretary shall determine, at a minimum--

(1) which types of unmanned aircraft systems, if any, as a result of their size,

weight, speed, operational capability, proximity to airports and populated

areas, and operation within visual line of sight do not create a hazard to us

ers of the national airspace system or the public or pose a threat to national

security; and

(2) whether a certificate of waiver, certificate of authorization, or air

worthiness certification under section 44704 of title 49, United States Code,

is required for the operation of unmanned aircraft systems identified under

paragraph (1).

(c) Requirements for Safe Operation.--If the Secretary determines under this section

that certain unmanned aircraft systems may operate safely in the national airspace

system, the Secretary shall establish requirements for the safe operation of such air

craft systems in the national airspace system.

In seeking this exemption, The MDEZIN CREATIVE GROUP submits that the DJI Phantom 2+

UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the

characteristics of the DJI Phantom 2+ UAS ; (b) the pilot certification requirement; and (c) the

specific operating limitations.

a. The Specifications Of The DJI Phantom 2+ UAS Demonstrate Its Safe Characteristics.

The DJI Phantom 2+ UAS does not create a hazard to users of the NAS or the public, or otherwise

pose a threat to national security considering its size, weight, speed, and operational capability.

i. Technical Specifications Of The DJIPhantom 2+ UAS .

The technical specifications of the DJI Phantom 2+ UAS are set forth by the DJI Phantom 2+

User Manual, attached hereto as Appendix A.

ii. The DJI Phantom 2+ UAS Global Positioning Modes Enable The UAS To Re

main Within A Defined Operational Area.

The DJI Phantom 2+ UAS may be operated in both manual and global positioning flight modes. A

complete description of the flight and navigational modes of the DJI Phantom 2+ UAS is provid

ed at pages 5 of the DJI Phantom 2+ User Manual attached here to as Appendix A.

iii. The DJI Phantom 2+ UAS Are Designed For Automatic Return To Home

Point Or Hover In The Event Of Loss Of The Control Link Or Navigation.

When the Control Link is lost, the DJI Phantom 2+ UAS will remain stationary, in flight, for 3

seconds or more. If, after 3 seconds, the DJI Phantom 2+ UAS doesnot reacquire controllink data

from the GCS, the UAS will assume that the Control Link is lost and thewill return to the home

position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown.

15A complete description of the Failsafe Functions of the DJI Phantom 2+UAS are set forth at

pages 12through 14of the DJI Phantom 2+ User Manual, attached hereto as Appendix A.

iv. The DJI Phantom 2+ GCS And Its Operation.

A complete description of the operation and specifications of the DJI Phantom 2+ GCS and flight

control software is provided at page 5 of the DJI Phantom 2+ User Manual. DJI Phantom 2+

User Manualis attached hereto as Appendix A.

b. Flight Operations Of DJI Phantom 2+ UAS IsLimited To The Line Of Sight Of A

Certificated Pilot in Command With A Safety Observer.

The MDEZIN CREATIVE GROUP video production staff will be the only personsto act as a

pilot in command (PIC) of the DJI Phantom 2+ UAS . Additionally, a safety observer will assist

him at all times during flight time.

c. Flights Of DJI Phantom 2+ UAS Will Be Conducted Pursuant To Specific Operat

ing Limitations.

In seeking this exemption, The MDEZIN CREATIVE GROUP proposes to commercially oper

ate DJI Phantom 2+ UAS for the special purpose of conducting aerial video and photography

over certain areas of United States, pursuant to the following specific operating limitations.

1. Operations authorized by this grant of exemption will be limited to the following

aircraft described in the operating documents, rotorcraft UAS weighing less than 55

pounds maximum gross weight: DJI Phantom 2+ Unmanned Aircraft Systems. Pro

posed 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 UA must be operated at an altitude of nomore 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 unaided by any device

other than corrective lenses, as specified on the PIC’s FAA-issued airman medical cer

tificate.

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

ted.

167. 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 must be designated be

fore 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 per

mitted to operate the camera or other instruments.

9. The operating documents and the grant of exemption must be accessible during

UAS operations and made available to the Administrator upon request. If a discrep

ancy exists between the conditions and limitations contained in the grant of exemption

and the procedures outlined in the operating documents, the conditions and limitations

contained in the grant of exemption take precedence and must be followed. Otherwise,

the operator must follow the procedures as outlined in its operating documents. The

operator may update or revise its operating documents. It is the operator’s responsibil

ity to track such revisions and present updated and revised documents to the Admin

istrator upon request. The operator must also present updated and revised documents

if it petitions for extension or amendment to the grant of exemption. If the operator

determines that any update or revision would affect the basis upon which the FAA

granted the exemption, then the operator must petition for amendment to its grant of

exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if ques

tions 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 condi

tion for safe flight. If the inspection reveals a condition that affects the safe operation

of the UAS , the aircraft is prohibited from operating until the necessary maintenance

has been performed and the UAS is found to be in a condition for safe flight. The

Ground Control Station must be included in the preflight inspection. All maintenance

and alterations must be properly documented in the aircraft records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS op

eration 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. inoper

able components, items, or equipment, not already covered in the relevant sections of

the operating documents.

13. The operator must follow the UAS manufacturer’s aircraft/component, mainte

nance, overhaul, replacement, inspection, and life limit requirements.

1714. The operator must carry out its maintenance, inspections, and record keeping

requirements, in accordance with the operating documents. Maintenance, inspection,

alterations, and status of replacement/overhaul component parts must be noted in the

aircraft records, including total time in service, description of work accomplished,

and the signature of the authorized person returning the UAS to service.

15. Each UAS operated under this exemption must comply with all manufacturer

Safety Bulletins.

16. The authorized person must make an entry in the aircraft record of the corrective

action taken against discrepancies discovered between inspections.

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

18. The operator may not permit any PIC to operate unless the PIC meets the opera

tor’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, includ

ing evasive and emergency maneuvers and maintaining appropriate distances from

persons, vessels, vehicles and structures. PIC qualification flight hours must be logged

in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training

the operator’s PICs are permitted under the terms 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 opera

tions are considered nonparticipants, and the PIC must operate the UA with appropri

ate distance from nonparticipants in accordance with 14 C.F.R. § 91.119.

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1.

All operations must be conducted under visual meteorological conditions (VMC). If

flight at night is required, a special request will be made at the FAA office closest to

proposed area of operations. Flights under special visual flight rules (SVFR) are not

authorized.

20. The UA may not operate within 5 nautical miles of an airport reference point

as denoted on a current FAA-published aeronautical chart unless a letter of agree

ment with that airport’s management is obtained, and theoperation is conducted in

accordance with a NOTAM as required by the operator’s COA. The letter of agree

ment 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 hori

zontally 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 with the operating documents.

1823. 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 fore

cast weather conditions) there is enough power to fly at normal cruising speed to the

intended landing point and land the UA with 25% battery power remaining.

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

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 in accordance with airspace requirements

in the ATO issued COA including class of airspace, altitude level and potential tran

sponder 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 (NNumber) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must

be as large as practicable.

27. Before conducting operations, the radio frequency spectrum used for operation

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 enforce

ment officialupon request.

29. The UA must remain clear and yield the right of way to all manned aviation op

erations 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 atleast 500 feet from all nonparticipating per

sons (persons other than the PIC, SO, operator trainees or essential persons), vessels,

vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating

persons from the UA and/or debris in the event of an accident. The operator

must ensure that nonparticipating persons remain under such protection. If a

situation arises where nonparticipating persons leave such protection and are

within 500 feet of the UA, flightoperations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the owner/

controller of such vessels, vehicles or structures has granted permission and

the PIC has made a safety assessment of the risk of operating closer to those

objects and determined that it does not present an undue hazard, and;

19c. Operations nearer to the PIC, SO, operator trainees or essential persons do

not present an undue hazard to those persons per § 91.119(a).

32. All operationsshall 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 re

ported to the National Transportation Safety Board (NTSB) per instructions contained

on the NTSB Web site: www.ntsb.gov.

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b)

Would Not Adversely Affect Safety.

The MDEZIN CREATIVE GROUP submits that the equivalent level of safety established by

Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI

Phantom 3 UAS unless that PIC has demonstrated, by meeting minimum flight-hour and cur

rency requirements, that the PIC is able to safely operate the DJI Phantom 2+ UAS in a manner

consistent with the exemption, including evasive and emergency maneuvers and maintaining ap

propriate distances from people, vessels, vehicles and structures.

Considering The MDEZIN CREATIVE GROUP’s proposed area of operations, and the operating

limitations set forth-above; the parallel nature of private pilot aeronautical knowledge require

ments to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship

skills necessary to safely operate the DJI Phantom 2+ UAS , The MDEZIN CREATIVE GROUP

submits that the additional manned airmanship experience of a commercially certificated pilot

would not correlate to the airmanship skills necessary for The MDEZIN CREATIVE GROUP’s

specific proposed flight operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS

, in cir

cumstances 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).

The MDEZIN CREATIVE GROUP will not allow any PIC to operate the DJI Phantom 2+UAS

unless that PIC has demonstrated, by meeting minimum flight-hour requirements or the DJI

Phantom 2+ UAS training and currency requirements, that the PIC is able to safely operate the

DJI Phantom 2+ UAS in a manner consistent with this exemption, including evasive and emer

gency maneuvers and maintaining appropriate distances frompeople, vessels, vehicles and struc

tures.

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

20hours as a UAS pilot operating the same make and model of UAS to be used for operations un

der the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and

landings in the preceding 90 days (for currency purposes).

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was ob

tained in compliance with applicable regulations will ensure an equivalent level of safety during

The MDEZIN CREATIVE GROUP’s proposed operations. The Administrator has held that prior

documented flight experience that was obtained in compliance with applicable regulations would

ensure safe operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for the

purpose of motion picture filming (or similar operations), the PIC must have accumulated

and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time asa UAS

rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor UAS

. Prior to operations under Exemption No. 11062, the PIC must also have accumulated

and logged a minimum of 5 hours as a UAS pilot operating the same make and model of

UAS to be used for operations under the exemption. For clarification, the FAA considers

these 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 require

ments, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for

currency purposes). The FAA finds that at a minimum, the flight-hour requirements in

Exemption No. 11062 are appropriate to practice and build proficiency in the skills neces

sary to safely conduct the petitioner’s proposed operations. The FAA also finds that prior

documented flight experience that was obtained in compliance with applicable regulations

would satisfy this requirement. Training, proficiency, and experience-building flights can

also be conducted under the grant of exemption to accomplish the required flight time.

During training, proficiency, and experience-building flights the PIC is required to oper

ate the UA with appropriate distances in accordance with 14 C.F.R 91.119.

Exemption No. 11138 at page 15.

Accordingly, The MDEZIN CREATIVE GROUP will ensure safe operations by not allowing any

PIC to operate the DJI Phantom 2+UAS unless that PIC has demonstrated, by meeting minimum

flight-hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 2+

UAS in a manner consistent with the exemption, including evasive and emergency maneuvers

and maintaining appropriate distances from people, vessels, vehicles and structures.

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Ad

versely Affect Safety.

21The equivalent level of safety established by Section 91.7(a) will be maintained because prior to

every flight, The MDEZIN CREATIVE GROUP will ensure that the DJI Phantom 2+ UAS is in

an airworthy condition based upon the UAS ’s compliance with its operating documents and as

stated in the conditions and limitations herein.

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS

, in

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos.

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150,

11153, 11156, 11157, 11158, 11159, 11160, 11161).

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Ad

versely Affect Safety.

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

altitude information of the DJI Phantom 2+ UAS 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 The

MDEZIN CREATIVE GROUP’s operation of the DJI Phantom 2+ UAS 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

flight, a zero altitude initiation point is automatically established by the UAS at ground level.

The FAA has previously granted relief from Section 91.121 specific to UAS

, in circumstances

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063,

11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157,

11158, 11159, 11160, 11161).

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not

Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R.

Section 91.151(b) as a result of (1) the technical specifications of the DJI Phantom 2+ UAS ; (2)

the limitations on the proposed flight operations; and (3) the location of the proposed flight op

erations. Accordingly, The MDEZIN CREATIVE GROUP will ensure that it will safely operate

the battery powered DJI Phantom 2+ UAS during daylight hours in VFR conditions, with enough

battery power to fly for a total duration of 23minutes.

Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 2+ UAS ; the

limitations on the proposed flight operations; and the location of the proposed operations, will

ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore,

safety will be ensured as the DJI Phantom 2+ UAS provide audible and visual warnings tothe PIC

at the GCS when the UAS experiences low battery voltage, the first warning occurring at approx

imately 33% remaining battery power, and again at approximately 10% remaining battery

22power. At the critically lowbattery level, the DJI Phantom 2+ UAS will descend and land auto

matically.

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. Relief 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 cir

cumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811,

10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136,

11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety.

In seeking this exemption, The MDEZIN CREATIVE GROUP submits that the equivalent level

of safety with regard to the regulatory maintenance and alteration requirements established by

Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met be

cause The MDEZIN CREATIVE GROUP will use trained technicians to perform maintenance,

alterations, or preventive maintenance on the UAS using the methods, techniques, and practices

prescribed in the operating documents (i.e., the MDEZIN CREATIVE GROUP Aerial Operations

Manual, Monthly Maintenance Log, and DJI Phantom 2+ Instruction Manual). Furthermore, The

MDEZIN CREATIVE GROUP will document and maintain all maintenance records for the DJI

Phantom 2+

UAS .

Since the DJI Phantom 2+ UAS will be inspected as prescribed by the operating documents, The

MDEZIN CREATIVE GROUP will maintain the equivalent level of safety established by Sec

tions 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI Phantom 2+ User Manuals are

attached hereto as Appendix A and B; a copy of the DJI Phantom 2+ UAS Maintenance LOG is

attached hereto as Appendix C.

Likewise, the exemption sought will not adversely affect safety because The MDEZIN CRE

ATIVE GROUP will use trained technicians to perform maintenance, alterations or preventive

maintenance on the UAS using the methods, techniques, and practices prescribed by the operat

ing documents.

Furthermore, the exemption sought would maintain an equivalent level of safety established by

Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI Phantom 2+ UAS

will be performed by trained technicians. Maintenance will be documented and maintained uti

lizing the monthly maintenance log.

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely

affected when the technical characteristics and operating limitations of the UAS are considered.

23In consideration of The MDEZIN CREATIVE GROUP’s proposed operating limitations, the

operating documents, and the technical aspects of the DJI Phantom 2+ UAS , The MDEZIN

CREATIVE GROUP submits that safety will not be adversely affected by granting exemption

from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b).

The FAA has previously granted relief specific to UAS in circumstances similar, in all material

respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066,

11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159,

11160,

11161).

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

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and

14 C.F.R. § 21.16 entitled Special Conditions, The MDEZIN CREATIVE GROUP requests that

the FAA prescribe special conditions for the intended operation of the DJI Phantom 2+ UAS ,

which contain such safety standards that the Administrator finds necessary to establish a level of

safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a)

&(b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a)

& (b). Such special conditions will permit safe operation of the UAS for the limited purpose of

conducting aerial video and photography over certain areas of the United States for compensa

tion or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will

create a hazard to users of the NAS or the public, or otherwise pose a threat to national security;

and further, provides the authority for such UAS to operate without airworthiness certification in

accordance with any requirements that must be established for the safe operation of the UAS in

the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for

operation of the DJI Phantom 2+ UAS , since the airworthiness regulations of 14 C.F.R. Part 21

do not contain adequate or appropriate safety standards, due to the novel or unusual design fea

tures of the aircraft. Section 21.16, entitled Special Conditions, states the following:

If the FAA finds that the airworthiness regulations of this subchapter do not contain ad

equate 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 pre

scribes special conditions and amendments thereto for the product. The special conditions

are issued in accordance with Part 11 of this chapter and contain such safety standards for

the aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level of

safety equivalent to that established in the regulations.

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe

special conditions for Leading Edge’s intended operation of the DJI Phantom 2+ UAS , which

contain such safety standards that the Administrator finds necessary to establish a level of safety

equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections

2461.113(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 The MDEZIN CREATIVE GROUP Seeks Exemption:

The MDEZIN CREATIVE GROUP seeks exemption from the requirements of 14 C.F.R

Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), and 91.417(a) & (b).

A Brief Description Of The Nature Of The Exemption The MDEZIN CREATIVE GROUP

Seeks:

This exemption will permit The MDEZIN CREATIVE GROUP to commercially operate an

Unmanned Aircraft System (UAS ) for the purpose of conducting aerial video and pho

tography over certain areas of the United States.

• Any Additional Information, Views, Or Arguments Available To Support The

MDEZIN CREATIVE GROUP’sRequest.

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, The MDEZIN CREATIVE GROUP’s request for ex

emption 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 haz

ard 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, The MDEZIN CREATIVE GROUP will operate the DJI Phantom

2+ UAS safely in the NAS, without creating a hazard to users of the NAS, or the public, or oth

erwise pose a threat to national security.

CONCLUSION

As set forth herein, The MDEZIN CREATIVE GROUP 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 2+ UAS commercially, without an airworthiness

certificate, for the limited purpose of conducting aerial video and photography over certain areas

of the United States. By granting this Petition, the FAA Administrator will be fulfilling the

Congressional mandate of the FAA Modernization and Reform Act of 2012, while also

advancing the interests of the public, by allowing The MDEZIN CREATIVE GROUP to safely,

efficiently, and economically operate the DJI Phantom 2+ UAS commercially within the NAS.

25WHEREFORE , in accordance with the Federal Aviation Regulations and the FAA Modern

ization and Reform Act of 2012, Section 333, The MDEZIN CREATIVE GROUP 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 MDEZIN CREATIVE GROUP to operate the DJI

Phantom 2+ UAS commercially for the purpose of conducting aerial video and photography over

certain areas of the United States.

Dated: Jan, 2016

Respectfully submitted,

Dennis McDougall (owner)

MDEZIN CREATIVE

GROUP

224 Pease Ct. Janesville WI

53545

608-774-3623

dmcdougall@mdezin.com

Appendices :

A – Link to DJI Phantom 2+ Manual: Click on link below

http://dl.djicdn.com/downloads/phantom_2/en/PHANTOM2_User_Manual_v1.4_en.pdf

26 B- List of Unmanned Aircraft Systems UAS

Make & Model Description N-# Weight

DJI Phantom 2+ 4 rotor electric N-127TQ reserved 4 lbs27 2. DJI Phantom 2+ - The operation of the DJI Phantom 2+ system is as follows.

1. Build Materials - Plastic, Aluminum and internal electrics.

2. Motor Configuration - The Phantom 2+ has a quadcopter configuration.

3. Payload - The Phantom 2+ it’s own integrated camera. Total Weight- 4lbs

4. Maintaining the Phantom 2+

I. Before each flight:

• 1. Check all hardware to ensure it is securely tightened.

• 2. Check that the motor is level and locked in place.

• 3. Check the propeller to ensure it is tight and there are no visible signs of cracks, stress,

and/or chips.

• Replace if propeller is questionable.

• 4. Check all wiring to motors, motor controllers, batteries, and flight controller for signs

of

• 5. Check all navigational lighting to ensure it is properly working.

II. After 45 hours of flight

• 1. Remove and check all motors and motor mounts for signs of wear and tear. Replace

as necessary.

• 2. Remove motor controllers and visually inspect and check for damage. Replace as

necessary.

• 3. Remove flight controllers and visually inspect and check for damage. Replace as nec

essary.

• 4. Check for cuts, fraying, cracks, and/or loose/cold solder connections. Fix before fly

ing.

• 5. Check for updates to flight controller firmware. If available, install and perform a

minimum of 15 test flights before conducting commercial work. C- FAA Small Craft Registartion

D- General OperationsE- Flight Log SheetF - Maintenace Log Sheet