### UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No.

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Aerial Image Logistics, LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

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

(a)(2), AND 91.417(a) & (b) CONC ERNING COMMERCIAL OPERATION OF DJI INSPIRE 1 , DJI

S900, and DJI F450 UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112

- 95)

Submitted on August 1 1

, 2015

Aerial Image Logistics, LLC

Richard F. Davis

969 Tamarind Way

B oca Raton, Florida 33486

Email: rdthree@bellsouth.net

Ph: 561

- 702

- 47332 

### TABLE OF CONTENTS

GLOSSARY OF ABBREVIATIONS

................................ ................................ ................................ ..... 3

SUMMARY

................................ ................................ ................................ ................................ ...... 4

INTRODUCTION AND INTERESTS OF THE PETITIONER

................................ ................................ .. 4

BACKGROUND

................................ ................................ ................................ ................................ 4

BASIS FOR PETITION

................................ ................................ ................................ ....................... 5

A. Name And Address Of The Petitioner

................................ ................................ ............... 7

B. The Specific Sections Of 14 C.F.R. From Which Aerial Image Logistics, LLC Seeks

Exemption

................................ ................................ ................................ ........................... 7

C. The Extent Of Relief Aerial Image Logistics, LLC Seeks And The Reason Aerial Image

Logistics, LLC Seeks The Relief

................................ ................................ .......................... 10

D. The Reasons Why Granting Aerial Image Logistics, LLC Request Would Be In The Public

Interest

................................ ................................ ................................ ............................. 1 2

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety

.......... 1 4

F. The Rules From Which Aerial Image Logistics, LLC Seeks Exemption

............................ 2 2

G. Any Additional Information, Views, Or Arguments Available To Support Request

...... 2 2

CONCLUSION

................................ ................................ ................................ ................................ 2 3

APPENDICES

................................ ................................ ................................ ................................ ................................ ......... 2 4

APPENDIX

- A: DJI Inspire 1 Technical Specifications

................................ ................................ ................................ .... 2 4

APPENDIX

- B: DJI Inspire 1 Manufacturer’s User Manual

................................ ................................ ............................ 2 4

APPENDIX

- C: DJI Inspire 1 Manufacturer’s Maintenance Manual

................................ ................................ .............. 2 4

APPENDIX

- D: DJI Inspire 1 Manufacturer’s Safety Guidelines

................................ ................................ .................... 2 4

APPENDIX

- E: DJI S900 Release Notes

................................ ................................ ................................ ..................... 25

APPENDIX

- .F: DJI S900 User Manual

................................ ................................ ................................ ....................... 25

APPENDIX

- G: DJI Futaba 14SG RC System User Manual

................................ ................................ ......................... 25

APPENDIX

- H: DJI HK

- M Quick Start Guide

................................ ................................ ................................ .............. 25

APPENDIX

- I: DJI A2 Quick Start Guide

................................ ................................ ................................ .................... 25

APPENDIX

- J: DJI IOSD Mark II User Manual

................................ ................................ ................................ ........... 2 5

APPENDIX

- K: DJI F450 User Manual

................................ ................................ ................................ ....................... 26

APPENDIX

- L : DJI E300 Propulsion System User Manual

................................ ................................ ............................. 26

APPENDIX

- M : DJI DT7 & DR16 RC System User Manual

................................ ................................ ......................... 26

APPENDIX

- N : DJI NAZA

- M V2 Quick Start Manual

................................ ................................ ................................ . 26

APPENDIX

- O : DJI iOSD mini User Manual

................................ ................................ ................................ .............. 26

APPENDIX

- P: Fly s ight Black Pearl Video Monitor

................................ ................................ ................................ ... 263 GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

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

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing4 SUMMARY

Aerial Image Logistics, 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), 91.407(a) (1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to

operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform

Act of 2012 (FMRA). This exemption will permit Aerial Image Logistics, LLC to operate an Unmanned

Aircraft System (UAS) for the commercial purpose of :

1. Aerial photography/video for public and/or private use including residential and commercial

real estate marketing

, appraisal, architecture, land surveying, construction, engineering

, bridge inspection, roof inspection, and other related professional activities.

2. Aerial video /photography for public and/or private use inc luding television, public events,

cinematography and news gathering.

3. Aerial inspection/photography of residential/commercial utility infrastructure including but

not limited to electrical power lines, wind turbines

, and cell towers.

4. Aerial inspection/photography/monitoring of agricultural crops.

5. Aerial video/photography or providing live video feed to assist with search and rescue

operations in cases of an emergency or natural disaster only when the Civil Air Patrol, local

authorities or gov ernment ha ve requested it by contract or donation.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Aerial Image Logistics, LLC

, is being formed to provide safe, reliable, high quality, and cost effective

airborne imaging and data collection that meet the ne eds of our customers. The principle of the

company; Richard F. Davis

, has been a Florida Licensed Real E sta t e Broker (#BK 444841) since 1986 with

over 25 years of experience marketing and appraising both residential and commercial properties. He is

also a Florida Licensed Appr aiser Trainee (#R123469)

.

Richard F. Davis has been a FAA licensed pilot since 1989 and possesses a Commercial Pilot certificate

(# 2784324 ), a C ertified Flight Instructor certificate (#2784324CFI), and Advanced Ground Instructor

certificate (#2784324).

Richard F. Davis also is a Civil Air Patrol (U nited S tates A ir F orce Auxiliary) Mission Pilot, Instructor Pilot,

and Check Pilot Examiner , and has been an active member of the CAP organization for 1 2 years. The

Civil Air Patrol is best known for its search

- and

- rescue efforts, CAP flies more than 85 percent of all

federal inland search

- and

- rescue missions directed by the Air Force Rescue Coordination Center at

Tyndall Air Force Base, Fl orida.

BACKGROUND

Unmanned Aircraft Systems: DJI Inspire 1 , DJI S900

and DJI F450 UAS

Aerial Image Logistics, LLC seeks an exemption to operate DJI UA systems for compensation or hire

within the NAS.

The DJI Inspire 1 vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control

Station (GCS) utilizes electronic tablet or smart phone systems. The DJI Inspire 1 has a maximum gross

weight of 6 pounds 8 ounces, a length of 17 inches, width of 17 inches, height of 1 2 inches, and a5

maximum speed of approximately 22 m/s or 4 2 knots. The DJI Inspire 1 UA is equipped with four main

rotors; driven by Lithium Polymer battery powered electric motors.

The DJI S900 vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) , has a maximum gross weight

of 8.2 kg, or 18 pounds . The di mensions are 9 00mm x 9 00mm (motor to motor) or 35 inches x 35 inches

(motor to motor) . Under still air the maximum speed is no more than 1 9 m/s or 3 7 knots. The DJI S900

has the ability to hover and move along a vertical and horizontal plane simultaneousl y. The DJI S900 has

six kV

- 400 rpm/V electric motors , powered by a 6 cell Lithium Polymer battery. There are six 15 x 5.2

inch propellers

. The DJI S900 will be controlled with the Futaba 24SG twenty four channel remote

controller (GCU) and the FutubaR7008SB eight+ channel receiver with an operating frequency of

2.404GHz

– 2.476GHz. The live video feed will have an operating frequency of 5.74GHz

– 5.86GHz. The

DJI S900 is to be equipped with either the DJI mini iOSD (On Screen Display) unit or the DJI Mark II OSD

which provides real time data including power voltage, flight velocity, height, distance from the home

point, horizontal attitude, pitch, roll, number of GPS satellites and more. The flight data information is

visible to the operator o n the LCD monitor attached to the remote control unit (GCU)

The DJI F450 vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) , with extended motor arms

(extends frame arms 5cm), has a maximum gross weight of 1600g or 3.53lbs. The dimensions are 500 mm

x 500mm x 280mm (including GPS mast) or 20 inches x 20 inches x 1 2 inches (including GPS mast). Under

still air the maximum speed is no more than 18m/s or 35 knots . The DJI F450 has the ability to hover and

move along a vertical and horizontal plane s imultaneously. The DJI F450 has four motors, Motor Model

DJI 2212/920KV E300 tuned propulsion system, powered by a 3 or 4 cell Lithium Polymer battery. There

are four propellers, Propeller Model DJI 9443, or 9450, 1038 are in use. The DJI F450 will be c ontrolled

with the DJI DT7 seven channel remote controller (GCU) and the DJI DR16 sixteen channel receiver with an

operating frequency of 2.404GHz

– 2.476GHz. The live video feed will have an operating frequency of

5.74GHz

– 5.86GHz. The DJI F450 is equi pped with the DJI mini iOSD (On Screen Display) unit which

provides real time data including power voltage, flight velocity, height, distance from the home point,

horizontal attitude, pitch, roll, number of GPS satellite s and more

. The flight data informa tion is visible to

the operator on the LCD monitor attached to the remote control unit (GCU).

The DJI UA that will be operated by Aerial Image Logistics, LLC will all be registered in accordance with

49 U.S.C. 44103, Registration of Aircraft , as well as 14 C.F.R Part 47, Aircraft Registration , and marked in

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

.

BASIS FOR PETITION

Petitioner, Aerial Image Logistics, LLC , pursuant to the provisions of the Federal Aviation Regulations (14

C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules

for Certain Unmanned Aircraft Systems , hereby petitions the Administrator to commercially operate the

DJI Inspire 1, DJI S900, and DJI F450 UAS in the National Airspace System (NAS), and for an exemption

from the requirements of 14 C.F.R§§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1),

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

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

aircraft and its operation, Aerial Image Logistics, LLC operation of the DJI Inspire 1 , DJI S900 and DJI F4506

UAS meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness

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

Accordingly, Aerial Image Logistics, LLC requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1)

& (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to

aircraft with an airworthiness certificate.

Aerial Image Logistics, LLC submits that the requested relief is proper since an equivalent level of safety

will be ensured. Aerial Image Logis tics, LLC will perform maintenance, alterations, or preventive

maintenance on the UAS using the methods, techniques, and practices prescribed in the operating

documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 , DJI S900, and DJI F450 Instruction

M anual). Furthermore, Aerial Image Logistics, LLC will document and maintain all maintenance records

for the DJI Inspire 1 , DJI S900, and DJI F450 UAS.

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

limitations: Pilot in command , is requested by Aerial Image Logistics, LLC to the extent necessary to

allow a Pilot in Command (PIC) holding a private pilot or higher level certificate , as well as an airman

medical certificate, and who has demonstrated, by meeting minimum flight

- hour and currency

requirements, that the PIC is able to safely operate the DJI Inspire 1 , DJI S900, and DJI F450 UAS in a

manner consistent with this exemption, including evasive and emergency maneuvers and maintaining

appropriate distances from people, vessels, vehicles and structures.

Aerial Image Logistics, LLC seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness

, because

the DJI Inspire 1, DJI S900, and DJI F450 UAS do not require an airworthiness certificate in accordance

with 14 C.F.R. Part 21, Subpart H. As such, Aerial Image Logistics, LLC submits that it will ensure that the

DJI Inspire 1, DJI S900, and DJI F450 UAS are in a safe condition, prior to every flight, by determining

that the UAS are in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI

Inspire 1, DJI S900, and DJI F450 Instruction Manual)

.

Aerial Image Logistics, LLC also seeks an exemption from the requirements of Section 91.121, entitled

Altimeter Sett ings , as the DJI Inspire 1, DJI S900, and DJI F450 UA will not have a typical barometric

altimeter onboard. However, altitude information of the DJI Inspire 1, DJI S900, and DJI F450 UA will be

provided to the PIC via Global Positioning System (GPS) equipm ent 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 Aerial Image Logistics, LLC ’s operation of the DJI Inspire 1, DJI S900, and DJI

F450 UAS within visual line of sight, at or below 4 00 feet AGL, will ensure a level of safety equivalent to

Section 91.121.

Additionally, Aerial Image Logistics, LLC seeks an exemption from the requirements of Section

91.151(b), entitled Fuel requirements for flight in VFR conditions

. Aerial Image Logistics, LLC submits that

safety will not be affected by operation of the DJI Inspire 1, DJI S900, and DJI F450 UA during daylight

hours in visual meteorological conditions (VMC) under visual flight rules (VFR), al l three DJI UA have

enough battery power to fly for a maximum duration of approximately 7 to 1 5 minutes to the first point7

of intended landing and, assuming normal cruising speed, to fly after that for at least 5 minutes (or land

with 25% remaining battery power , whichever occurs first )

.

In accordance with 14 C.F.R. § 11.81, Aerial Image Logistics, LLC 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:

Aerial Image Logistics, LLC

Richard F. Davis

969 Tamarind Way

B oca Raton, Florida 33486

Phone: 561

- 702

- 4733

Email: rdthree@bellsouth.net

B. The Specific Sections Of 14 C.F.R. From Which Aerial Image Logistics, LLC Seeks Exemption.

1. Aeria l Image Logistics, LLC Seeks Exemption From The Requirements Of Section 61.113(a)

And (b).

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

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

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

an aircraft that is carrying passengers or property for compensation or hire; nor

may that person, for compensation or hire, act as PIC of an aircraft.

(b) A private pilot may, for compe nsation 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.

2. Aerial Image Logistics, LLC Seeks Exemption From The Requirements Of Section 91.7(a).

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

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

3. Aerial Image Logistics, LLC 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 lev el 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) of8 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.

4. Aerial Image Logistics, LLC Seeks Exemption From The Requirements Of Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions , subsection (b), states the

followin g:

(b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering

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

intended landing and, assuming normal cruising speed, to fly after that for at least 20

minutes.

5. Aerial Image Logistics, LLC 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 tha t 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. Aerial Image Logistics, LLC Seeks Exemption From The Requirements Of Section 91.407(a ) ( 1)

Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or

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

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

maintenance, rebuilding, or alteration unless

--

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

chapter[.]

7. Aerial Image Logistics, LLC Seeks Exemption From The Requirements Of Sectio ns

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

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

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

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

--

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

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

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

part 21 of this chapter.

8. Aerial Image Logistics, LLC Seeks Exemption From The Requirements Of Sections 91.417(a)9 And 91.417(b).

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

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

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

(b) of this section:

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

the 100

- hour, annua l, progressive, and other required or approved inspections, as

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

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

--

(i) A description (or reference to data acceptabl e 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 stat us of applicable airworthiness directives (AD) and safety

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

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

recurring action the time and date when the next action is required.

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

alteration to the airframe and currently installed engines, rotors, propellers,

and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

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

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

performed.

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

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

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

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

approved for return to service.

C. The Extent Of Relief Aerial Image Logistics, LLC Seeks And The Reason Aerial Image Logistics, LLC

Seeks The Relief.10

1. Extent Of Relief Aerial Image Logistics, LLC Seeks And The Reason Aerial Image

Logistics, LLC Seeks Relief From Section 61.113(a) And (b).

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

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

higher level certificate, as well as a cur rent 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 requested since the limitations set forth in Section 61.113(a) and (b) state that a

private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any

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

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

Aerial Image Logistics, LLC submits that an equivalent level of safety will be maintained

because no PIC will be allowed to operate the DJI Inspire 1, DJI S900, and DJI F450 UAS

unless that PIC has met certain flight

- hour and currency requirements, demonstrating that

the PIC is able to safely operate any of the DJI UAS in a manner consistent with the

operations specifications as described in this exemption, including evasive and emergency

maneuvers, as well as maintai ning appropriate distances from people, vessels, vehicles and

structures.

Further, Aerial Image Logistics, LLC submits that all flights of the DJI Inspire 1, DJI S900, and

DJI F450 UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be

incidental to Aerial Image Logistics, LLC business; and (2) will not carry passengers or

property for compensation or hire.

2. Extent Of Relief Aerial Image Logistics, LLC Seeks And The Reason Aerial Image

Logistics, 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 Aerial Image Logistics, LLC to determine that the DJI Inspire 1 , DJI S900, and

DJI F450 are in good operating condition prior to every flight by ensuring that the UAS is in

compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1,

DJI S900, and DJI F450 Instruction Manual).

Aerial Image Logistics, LLC seeks the requested relief because the DJI Inspire 1 , DJI S900, and

DJI F450 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21,

Subpart H.

Therefore, Aerial Image Logistics, LLC will ensure that the DJI Inspire 1, DJI S900, and DJI F450

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

Monthly Maintenance Log, and DJI Inspire 1, DJI S900, and DJI F450 Instruction Manual) prior to11

every flight, and further, determine that the aircraft are in condition for safe flight

.

3. Extent Of Relief Aerial Image Logistics, LLC Seeks And The Reason Aerial Image Logistics, 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 Inspire 1, DJI S 900, and DJI F450 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 al titude information concerning UAS operations be reported to air traffic control

(ATC) in feet above ground level (AGL), Aerial Image Logistics, LLC seeks the requested relief

because the DJI Inspire 1, DJI S900, and DJI F450 UAs ’ altimeter may be set on th e 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

Inspire 1, DJI S900, and DJI F450 UA 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 display of

the GCS.

4. Extent Of Relief Aerial Image Logistics, LLC Seeks And The Reason Aeri al Image

Logistics, 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 Inspire 1, DJI S900,

and DJ I F450 UA during daylight hours in visual meteorological conditions (VMC), under visual

flight rules (VFR), for a total duration of 7 to 13 minutes to the first point of intended landing

and, assuming normal cruising speed, to fly after that for at least 5 minutes (or land with 25%

battery power remaining , whichever occurs first )

. Aerial Image Logistics, LLC seeks the

requested relief because without an exemption from Section 91.151(b), the flight time duration

of the battery powered DJI Inspire 1, DJI S900, and DJI F450 UA will severely constrain the

practicality of any aerial video or still photo flight operations that Aerial Image Logistics, LLC

proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the DJI Inspire 1, DJI S900,

and DJI F450 UAS, the DJI Inspire 1 and DJI F50 operating documents, and Aerial Image

Logistics, LLC s proposed operating limitations, ensure that Aerial Image L ogistics, LLC will

safely operate the battery powered DJI Inspire , DJI S900, and DJI F450 1 UA during daylight

hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough

battery power to fly for a total duration of 7 to 1 3 minutes to the first point of intended

landing and, assuming normal cruising speed, to fly after that for at least 5 minutes (or land

with 25% battery power remaining , whichever occurs first )

.12

5. Extent Of Relief Aerial Image Logistics, LLC Seeks And The Reason Aerial Image

Logistics, LLC Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) &

(a)(2), And 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply

to aircraft wit h an airworthiness certificate, Aerial Image Logistics, LLC requests relief from

these Sections because the DJI Inspire 1, DJI S900, and DJI F450 UAS do not require

airworthiness certificates. As set forth more fully below, the DJI Inspire 1, DJI S900, and DJI

F450 UAS meet the conditions of FMRA Section 333 for operation without an airworthiness

certificate. Accordingly, Aerial Image Logistics, LLC will perform maintenance, alterations, or

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

prescribed in the UAS operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1,

DJI S900, and DJI F450 Instruction Manual). Furthermore, Aerial Image Logistics, LLC will

document and maintain all mainten ance records for the DJI Inspire 1, DJI S900, and DJI F450

UAS.

D. The Reasons Why Granting Aerial Image Logistics, LLC 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 Aerial Image Logistics, LLC

t o o safely, efficiently, and economically perform aerial video and photography and for other

purposes as described in the Summary on Page 4 within this p etition for exemption over certain

areas of the United States.

Additionally, use of the DJI Inspire 1, DJI S900, and DJI F450 UAS will decrease congestion of the

NAS, reduce pollution, and provide significant benefits to the economy

.

1. The Public Will Bene fit From Decreased Congestion Of The NAS.

The DJI Inspire 1, DJI S900, and DJI F450 UA are battery powered and serve as a safe, efficient,

and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery.

By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption

allowing the use of a DJI Inspire 1, DJI S900, and DJI F450 UAS would reduce the amount of

manned aircraft in the NAS, reduce noise and air pollution, as well as increase the saf ety 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 Inspire 1, DJI

S900, and DJI F450 UA 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 duri ng the ground, takeoff, departure,

arrival, and landing phases of flight operations.13

E. The Public Will Benefit From The Safety And Efficiency Of The DJI Inspire 1, DJI S900, and DJI

F450 UAS.

Conducting aerial acquisitions with the DJI Inspire 1, DJI S900 , and DJI F450 UAS, instead of

manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise

pollution generated during traditional aerial video and still photography flight operations. By

using battery power and elec tric motors, the DJI Inspire 1, DJI S900, and DJI F450 UAS produce

no air pollution, and are the most viable environmentally conscious alternative to the cabin

class, six cylinder internal combustion engine aircraft that are typically utilized for aerial v ideo

and photography, while burning approximately 20

- 30 gallons per hour of leaded aviation fuel.

The DJI Inspire 1, DJI S900, and DJI F450 UA, while reducing the carbon footprint of aerial

acquisitions, also eliminates noise pollution, as the UA are prope lled by battery powered electric

motors, rather than an internal combustion engine.

By using the DJI Inspire 1, DJI S900, and DJI F450 UAS to perform aerial data 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 DJI F450 , DJI S900,

and DJI Inspire 1 UA ( range in weight from approximately 6 pounds 7.5 ounces for the DJI Inspire

1 to 3 pounds 8 ounces for the DJI F450 , and approximately 18 pounds for the DJI S900 , at

maximum gross weights , and with no fuel on board), has less physical potential for collateral

damage to life and property on the ground, and in the air, compared to the manned aircraft that

typically conduct similar operations (weighing approximately 3

, 1 00 pounds with a wingspan of

approximately 36 feet, a length of 34 feet, and a fuel capacity of 87 gallons).

1. Perfo rming Aerial Video and Photography Operations With The DJI Inspire 1 , DJI S900,

and DJI F450 UAS Will Benefit The Economy.

In addition to being safe and efficient, the DJI Inspire 1, DJI S900, and DJI F450 UAS are also an

economical alternative to using manned aircraft to conduct similar aerial operations. As such,

operation of the DJI Inspire 1, DJI S900, and DJI F450 UAS will allow United States based

companies, like Aerial Image Logistics, LLC , to remain competitive and contribute to growth of

the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environm ental

Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and

operated companies must adopt new and alternative technology in order to rema in

competitive. Operating the battery powered DJI Inspire 1, DJI S900, and DJI F450 UAS is one such

technology that n ot 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 Inspire 1, DJI S900, and DJI F450 UAS, companies such as Aerial Image

Logistics, 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. companies, through commercial use14 of the DJI Inspire 1, DJI S900, and DJI F450 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.

2. There Are No Privacy Issues.

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

Aerial Image Logistics, LLC proposed operation of the DJI Inspire 1, DJI S900, and DJI F450 UAS.

Specifically, the DJI U AS will be operated only in compliance with operating documents (i.e.,

Monthly Maintenance Log, and DJI UAS Operating Manuals ) 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.

F. 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 Aerial Image Logistics, LLC Seeks Exemption.

1. Reasons Why The DJI Inspire 1, DJI S900, and DJI F450 UA S Meet The Conditions Of

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

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

unmanned aircraft and its operation, Aerial Image Logistics, LLC operation of the DJI Inspire

1, DJI S900, and DJI F450 UAS meet the conditions of FMRA Section 333, and will not require

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

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

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

NAS or the public, or otherwise pose a threat to national se curity. Specifically, FMRA Section

333 states the following, in part:

(a) In General.

-- Notwithstanding any other requirement of this subtitle, and not later than

180 days after the date of enactment of this Act, the Secretary of Transportation shall

determine if certain unmanned aircraft systems may operate safely in the national

airspace 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.

(b) Assessment of Unmanned Aircraft Systems.

-- In making the determination under

subsection (a), the Secretary shall determine, at a minimum

--

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

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

operation within visual line of sight do not create a hazard to users of the national

airspace system or the public or pose a threat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or airworthin ess

certification under section 44704 of title 49, United States Code, is required for the15 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 aircraft systems in the

national airspace system.

In seeking this exemption, Aerial Image Logistics, LL C submits that the DJI Inspire 1, DJI S900, and DJI

F450 UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the

characteristics of the DJI Inspire 1, DJI S900, and DJI F450 UAS; (b) the pilot certification requirement;

and (c) the specific operating limitations.

a. The Specifications Of The DJI Inspire 1, DJI S900, and DJI F450 UAS Demonstrate Its

Safe Characteristics.

The DJI Inspire 1, DJI S900, and DJI F450 UAS do not create a hazard to users of the

NAS or the public, or otherwise pose a threat to national security considering their size,

weight, speed, and operational capability.

i. Technical Specifications Of The DJI Inspire 1 , DJI S900, and DJI F450 UAS.

The technical specifications of the DJI Inspire 1, DJI S900, and DJI F450 UAS are set

forth by the DJI Inspire 1, DJI S900, and DJI F450 Technical Specifications, attached

hereto as Appendix A through Appendix P

.

ii. The DJI Inspire 1 UAS Autonomous Flight And Navigation Modes Enable The

UAS To Remain Within A Defined Operational Area.

The DJI Inspire 1 UAS may be operated in both manual and fully autonomous flight

modes . A complete description of the flight and navigational modes of the DJI

Inspire 1 UAS is provided at pages 45

- 50 of the DJI I nspire 1 User Manuals, attached

hereto as Appendix B.

iii. The DJI Inspire 1 , DJI S900 and DJI F450 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 Ins pire 1 , DJI S900, and DJI F450 UA will

remain stationary, in flight, if the DJI UA do not reacquire control link data from

the GCS, the UAs will assume that the Control Link is lost and the UA s will return to

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

position and shutdown.

iv. The DJI Inspire 1 , DJI S900, and DJI F450 GCS And Their Operation.16 A complete description of the operation and specifications of the DJI Inspire 1 GCS is

described in the Inspire 1 User Manual. DJI Inspire 1 User Manual is attached hereto

as Appendix B. A description of the DJI S900 GCS is attached hereto as Appendix G,

and a description of the DJI F450 GCU is attached hereto as Appendix M

.

b. Flight Operations Of The DJI Inspire 1 , DJI S900, and DJI F450 UAS Are Limited To

The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer.

Aerial Image Logistics, LLC will only utilize certificated operators to act as a pilot in

command (PIC) of the DJI UAS. Additionally, when required a safety observer will assist all

pilots during flight time.

c. Flights Of DJI Inspire 1 UAS Will Be Conducted Pursuant To Specific Operating

Limitations.

In seeking this exemption, Aerial Image Logistics, LLC proposes to commercially operate

the DJI Inspi re 1, DJI S900, and DJI F450 UAS for the special purpose of conducting aerial

video and photography as further described in the Summary section of this petition for

exemption 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 Inspire 1, DJI S900, and DJI F450 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 and as further described in the

Summary section on Page 4 of this petition for exemption

.

3. The UA may not be flown at an indicated airspeed exceeding 5 0 knots.

4. The UA must be operated at an altitude of no more than 4 00 feet above ground

level (AGL), as indicated by the procedures specified in the operating documents

unless a special request is made and approved by ATC. All altitudes reported to ATC

must be in feet AGL.

5. The UAs must be operated within visual line 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

permitte d.

7. All operations will utilize a safety observer (SO) if deemed necessary . The SO may

be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS17 capability. The SO and PIC must maintain effective communicat ions at all times. 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 will assist the PIC with seeing and avoiding other air traffic and other

ground based obstacles/obstructions and may also operate the camera or other

instruments when requested by the PIC

.

9. Prior to each flight the PIC must inspect the UAS to ensure that it is in a

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

safe operation of the UAS, the aircraft is prohibited from operating until the

necessary maintenance has been performed and the UAS is found to be in a

condition for safe flight. The Ground Control St ation must be included in the

preflight inspection. All maintenance and alterations must be properly

documented in the aircraft records.

10. Any UAS that has undergone maintenance or alterations that affect the UAS

operation or flight characteristics, e.g. re placement 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.

11. The pre

- flight inspection must account for discrepancies, e.g. inoperable

components, items, or equipment, not already covered in the relevant

sections of the operating documents.

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

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

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

Safety Bulletins.

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

action taken against discrepancies discovered between inspections.

15. The PIC must possess at least a Private pilot certificate and at least a current

third

- class medical certificate.

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

operations must be conducted under visual meteorologica l 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.

17. The UA may not operate within 5 nautical mile s 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.18 18. 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 m iles from the

PIC.

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

determined location within the planned operating area and land

.

20. The PIC must abort the flight in the event of unpredicted obstacles or

emergencies

.

21. The PIC is prohibited from beginning a flight unless (considering wind and

forecast weather conditions) there is enough power to fly at normal cruising

speed to the intended landing point and land the UA with 25% battery power

remaining.

22. 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.

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

operations and activities at all times.

24. The UAS may not be operated by the PIC from any moving device or vehicle.

25. The Operator will obtain verbal/written consent of all non

- parti cipating persons

for the planned operation and ensure that only consenting persons will be allowed

within 100 feet of flight operations, and the radius may be reduced to 30 feet

based on an equivalent level of safety determination

26. Flight operations must b e 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

, b arriers or structures are present that

sufficiently protect nonparticipating persons from the UA and/or debris in the

event of an accident , t he 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 ), and o perations

nearer to the PIC, SO, operator trainees or essential persons do not present an

undue hazard to those persons per § 91.119(a)

27. 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.

28. Any accident that results in injury or property damage will be rep orted to the FAA

within 10 days of the accident.

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would19

Not Adversely Affect Safety.

Aerial Image Logistics, LLC submits that the equivalent level of safety established by Section

61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI Inspire 1

,

DJI S900, or DJI F450 UAS unless that PIC has demonstrated that the PIC is able to safely

operate the DJI Inspire 1, DJI S900, and DJI F450 UAS in a manner consistent with the

exemption, including evasive and emergency maneuvers and maintaining appropriate distances

from people, vessels, vehicles and structures.

Considering Aerial Image Logist ics, LLC ’s proposed area of operations, and the operating

limitations set forth

- above; the parallel nature of private pilot aeronautical knowledge

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

airmanship skills necessary to safely operate the DJI Inspire 1, DJI S900, and DJI F450 UAS, Aerial

Image Logistics, LLC submits that the additional manned airmanship experience of a

commercially certificated pilot would not correlate to the airmanship skills necessary for Aerial

Image Logistics, LLC ’s specific proposed flight operations.

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

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

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

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

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

Adversely Affect Safety.

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

every flight, Aerial Image Logistics, LLC will ensure that the DJI Inspire 1, DJI S900, and DJI F450

UAS are in a safe condition to operate 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

Adversely Affect Safety.

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

altitude information of the DJI Inspire 1, DJI S900, and DJI F450 UA 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 Aerial Image Logistics, LLC ’s operation of the DJI Inspire 1, DJI S900, and DJI F450

UA within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to20

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 establish ed 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, 1 1109, 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 Inspire 1 UAS and DJI

f450 (2) the limitations on the proposed flight operations; and (3) the location of the proposed

flight operations. Accordingly, Ae rial Image Logistics, LLC will ensure that it will safely operate

the battery powered DJI Inspire 1, DJI S900, and DJI F450 UA during daylight hours in VFR

conditions, with enough battery power to fly for a total duration of between 7 to 13 minutes to

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

least 5 minutes (or land with 25% battery power remaining)

.

Furthermore, safety will be ensured as the DJI Inspire 1 , DJI S900, and DJI F450 UAS provide

visual warnings to the PIC at the GCS when the UA experiences low battery voltage

. At the

critically low battery level, the DJI Inspire 1, DJI S900, and DJI F450 UAS will descend and land

automatically.

Significantly, previous exemptions gra nted 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 minimu ms prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650.

Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in

circumstances similar, in all material respects, to those presented herein (e.g. Exempt ion 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, Aerial Image Logistics, LLC submits that the equivalent level of safety

with regard to the regulatory maintenance and alteration requirements established by Sections

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

Image Logistics, LLC will use trained technicians or experienced personnel to perform

maintenance, alterations, or preventive maintenance on the UAS using the methods,

techniques, and practices prescribed in the operating documents (i.e.,Monthly Maintenance21

Log, and the DJI Inspire 1, DJI S900, and DJI F450 Instruction Manual). Furthermore, Aerial Image

Logistics, LLC will document and main tain all maintenance records for the DJI Inspire 1, DJI S900,

and DJI F450 UAS.

Since the DJI Inspire 1, DJI S900, and DJI F450 UAS will be inspected as prescribed by the

operating documents, Aerial Image Logistics, LLC will maintain the equivalent level of safety

established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2).

Likewise, the exemption sought will not adversely affect safety because Aerial Image Logistics,

LLC will perform maintenance, alterations or preventive maintenance on the UAS using the

methods, techniques, and practices prescribed by the operating documents.

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

Sections 91.407, 91.417(a) and 91.417(b), b ecause all maintenance of the DJI Inspire 1, DJI S900,

and DJI F450 UAS will be documented and maintained utilizing the monthly maintenance log.

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

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

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

In consideration of Aerial Image Logistics, LLC ’s proposed operating limitations, the operating

documents, and the technical aspects of the DJI Inspire 1, DJI S900, and DJI F450 UAS, Aerial

Image Logistics, LLC submits that safety will not be adversely affected by granting exemption

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

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

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

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

11160, 11161).

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

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

14 C.F.R. § 21.16 entitled Special Conditions, Aerial Image Logistics, LLC requests that the FAA

prescribe special conditions for the intended operation of the DJI Inspire 1, DJI S900, and DJI

F450 UAS, which contain such safety standards that the Admi nistrator 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), 91.109 (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 and as further

described in the Summary of this petition for exemption over certain areas of the United States

for comp ensation 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 operat e without22

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 th e DJI Inspire 1, DJI S900, and DJI F450 UAS, since the

airworthiness regulations of 14 C.F.R. Part 21 does not contain adequate or appropriate

safety standards, due to the novel or unusual design features of the aircraft. Section 21.16,

entitled Special Co nditions, states the following:

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

adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller

because of a novel or unusual design feature of the aircraft, aircraft engine or

propeller, he prescribes special conditions and amendments thereto for the product.

The special conditions are issued in accordance with Part 11 of this chapter and

contain such safety standards for the aircraft, aircraft e ngine 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 Aerial Image Logistics, LLC intended operation of the DJI

Inspire 1, DJI S900, and DJI F450 UAS, which contain such safety standards that the

Administrator finds necessary to establish a level of safety equivalent to th at established by

14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.109 (a),

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

and 91.417(a) & (b).

G. A Summary That Can Be Published In The Federal Register, stating: The Rules From Which

Aerial Image Logistics, LLC Seeks Exemption:

Aerial Image Logistics, LLC seeks exemption from the requirements of 14 C.F.R Sections

61.113(a)&(b), 91.7(a), 91.109 (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 Aerial Image Logistics, LLC Seeks:

This exemption will permit Aerial Image Logistics, LLC to commercially operate an Unmanned

Aircraft System (UAS) for the purpose of conducting aerial video and photography and other

operations as described within the Summary on page 4 of this petition for exemption o ver certain

areas of the United States.

H. Any Additional Information, Views, Or Arguments Available To Support Aerial Image Logistics,

LLC ’s Request.

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

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS

may operate safely in the NAS. As such, Aerial Ima ge Logistics, LLC ’s request for exemption may23

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 t he 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, Aerial Image Logistics, LLC will operate the DJI Inspire 1, DJI S900,

and DJI F450 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, Aerial Image Logistics, 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 Inspire 1, DJI S900, and DJI F450 UAS commercially, without an airworthiness certificate, for

the limited purpose s of conducting aerial video and photography and other operations as described in

the Summary on page 4 of this petition for exemption over certain areas of the United States. By

granting this Petition, the FAA Administrator will be fulfilling the Congressi onal mandate of the FAA

Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing

Aerial Image Logistics, LLC to safely, efficiently, and economically operate the DJI Inspire 1, DJI S900, and

DJI F450 UAS commercia lly within the NAS.

WHEREFORE , in accordance with the Federal Aviation Regulations and the FAA Modernization and

Reform Act of 2012, Section 333, Aerial Image Logistics, 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 Aerial Image Logistics, LLC to operate the DJI Inspire 1, DJI S900, and DJI F450 UAS

commercially for the purpose of conducting aerial video and photography and other operations as

described in the Summary on page 4 of this petition for exemption over certain areas of the United

States.



### Dated: August 1 1

, 2015

Respectfully submitted,

Richard F. Davis

Richard F. Davis

AERIAL IMAGE LOGISTICS, LLC

969 Tamarind Way

B oca Raton, FL 33486

561

- 702

- 473324 

### APPENDICES

APPENDIX

– A through D : DJI Inspire 1 Documents and Manuals

The following documents an d manuals are found at the link b elow:

1. Appendix A: Quick Start Guide (EN) v1.2

2. Appendix B: DJI Inspire 1 User Manual (EN) v1.4

3. Appendix C: DJI Inspire 1 Safety Guidelines v1.0

4. Appendix D: DJI Inspire 1 Maintenance Manual v1.0

http://www.dji.com/product/inspire

- 1/download

DJI Inspire 1 Specifications

Model: T600

Weight (Battery Included) : 6.5 pounds

Hovering Accuracy (GPS Mode) : Vertical 0.5m/Horizontal 2.5m

Max Ascent Speed: 5 m/s

Max Descent Speed: 4 m/s

Max Speed: 22 m/s (ATTI mode)

Motor Model: DJI 3510

Propeller Model: DJI 1345

Dimensions: 438 x 451 x 301 mm

Approximate Flight Time: 18 minutes25



### APPENDIX

– E through J DJI S900 Documents and Manuals:

The following documents an d manuals are found at the link s below:

1. Appendix E: DJI S900 Release Notes

2. Appendix F: DJI S900 User Manual v1.2

http://www.dji.com/product/spreading

- wings

- s900/download

3. Appendix G: Futaba SG14 2.4 GHz RC control system

http://www.futaba

- rc.com/systems/futk9410

- 14sg/index.html

4. Appendix H: WK

- M Quick Start Guide v1.14

http://www.dji.com/product/wookong

- m/download

5. Appendix I: A2 Quick Start Guide v1.22

http://www.dji.com/product/a2/download

6. Appendix J: IOSD User Manual v2.10

http://www.dji.com/product/iosd

- mark

- ii/download

DJI S900 Specifications:

Model: Spreading Wings S900

Weight: 7.3 to 18 (including battery) pounds

Flight Controller: DJI WK

- M or DJI A2

Max Ascent Speed: 6 m/s

Max Descent Speed: 2 m/s

Max Speed: 19 m/s

Motor: kV

- 400 rpm/V

Propeller: 15 x 5.2 inch

Diagonal Wheelbase: 900mm

Approximate Flight Time: 18 minutes

Flight Data/Telemetry: DJI Mark II

RC Controller: Futaba 14SG

Camera / Gimbal : T o B e D etermined26



### APPENDIX

– K through P DJI F450 Documents and Manuals:

The following documents and manuals are found at the links below:

1. Appendix K : F450 User Manual v2.0

http://www.dji.com/product/flame

- wheel

- arf/download

2. Appendix L : E300 Propulsion System User Manual v1.0

http://www.dji.com/product/e300/download

3. Appendix M : DJI DT7 and DR 16 User Manual

http://www.dji.com/product/dt7

- dr16

- rc

- system/download

4. Appendix N : Naza

- M V2 Quick Start Manual v1.28

http://www.dji.com/product/naza

- m

- v2/download

5. Appendix O : iOSD Mini User Manual v1.06

http://www.dji.com/product/iosd

- mark

- ii/download

6. Appendix P : Fly s ight Black Pearl Rc801 LCD Monitor

http://3drobotics.com/wp

- content/uploads/2014/07/FPV

- Black

- Pear l

Monitor.pdf

DJI F450 Specifications:

Model: Flame Wheel 450 (F450)

Takeoff Weight: 1.8 to 3.5 pounds

Diagonal Wheelbase: 500 mm with AIMDROIX extended motor arms

Battery: 3s or 4s LIPO

Motor: DJI E300 Propulsion System/2212

- 920kV

RC Controller : DJI DT7 and DR 16 RC system

Flight Controller: Naza

- M V2

Propeller: DJI 9443 or DJI 9450

Came ra/Gimbal: T o B e D etermined

Flight Data/Telemetry: DJI iOSD

Approximate Fight Time: 12 minutes