UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

ANNA BOLSHAKOVA

FOR AN EXEMPTION SEEKING RELIE F FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING
COMMERCIAL OPERATION OF DJI PHANTOM 3 , DJI PHANTOM 2 VISION+, AND DJI
INSPIRE 1 UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)

Submitted on June 21 , 2015

ANNA BOLSHAKOVA

606 SWALLOWTAIL DRIVE

FREDERICK, MD 21703

(301) 76 8

- 7455TABLE OF CONTENTS

Page

GLOSSARY OF

ABBREVIATIONS.................................................................................................................3

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

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

BACKGROUND.......................................................................... ...........................................5

BASIS FOR PETITION............................................................................ ...............................6

NAME AND ADDRESS OF PETITIONER............................................. ...................7

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH

ANNA BOLSHAKOVA SEEKS EXEMPTION..........................................................7

THE EXTENT OF RELIEF ANNA BOLSHAKOVA SEEKS AND

THE REASON ANNA BOLSHAKOVA SEEKS THE R ELIEF.........................10

THE REASONS WHY GRANTING ANNA BOLSHAKOVA REQUEST

WOULD BE IN THE PUBLIC INTEREST ............................... ..............................13

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

ADVERSELY AFFECT SAFETY.............

..................................... ............................15

CONCLUSION......................................................................................... ..............................21GLOSSARY 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 Adm inistration

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

DJI UAV manufacturerESC Electronic speed control

FPV First Person View

LI

- PO Lithium Polymer battery

RCV Radio Controlled vehicle

SUMMARY

ANNA BOLSHAKOVA 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 Sectio n 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit ANNA BOLSHAKOVA to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography for real estate photography, and rea l estate fly

- over video over certain
areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

My name is ANNA BOLSHAKOVA, and I am a drone operator (pilot) with expertise and knowledge in all aspects of operating multiple types of U AS'S along with camera set up and operation. ANNA BOLSHAKOVA also provides clients with the highest quality digital conte nt for use in their commercial real estate listings. ANNA BOLSHAKOVA has 10 years of radio controlled helicopter experience.

The objec tive of ANNA BOLSHAKOVA’ aerial video and photography operations is to provide high quality imaging for a variety of comm ercial, and residential uses. ANNA BOLSHAKOVA

will also provide knowledge of UAS and promote safe UAS operations.BACKGROUND

Unm anned Aircraft Systems: DJI Phantom 2 Vision+ , DJI Inspire 1 UASs

ANNA BOLSHAKOVA seeks an exemption to operate DJI systems for compensation or hire
within the NAS. The DJI Phantom 3 , DJI Phantom 2 Vision+, and DJI Inspire 1 are vertical
takeoff and landi ng (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The DJI Phantom 3 has a maximum gross weight of approximately 2 pounds 14 ounces, while having a length of 16 inches width of 16
inches , height of 8 inches, and a maximum speed of approximately 29 knots. The DJI Phantom 2
Vision+ has a maximum gross wei ght of approximately 2 pounds 13 ounces, while having a length of 16 inches width of 16 inches, height of 8 inches, and a maximum speed of approximately 29 knots. The DJI Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of approximately 42 knots. The DJI Phantom 3

, Phantom 2 Vision+, and DJI Inspire 1UAs are equipped with four main rotors; driven by Lithium Polymer battery powered electric motors.

The DJI Phantom 3

, Phantom 2 Vision+, and DJI Inspire 1 UAs that will be operated by ANNA BOLSHAKOVA will be registered in accordance with 49 U. S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Markings.BASIS FOR PETITION

Petitioner, ANNA BOLSHAKOVA, pursuant to the pr ovisions 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 P hantom 3, Phantom 2 Vision+, DJI Inspire 1 UASs 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 lim ited operating area associated with the unmanned aircraft and its operation, ANNA BOLSHAKOVA operation of DJI Phantom 3, DJI Phantom 2 Vision+, and DJI Inspire 1 UASs meets the conditions of FMRA S ection 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, ANNA BOLSHAKOVA requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as t hese sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate.

ANNA BOLSHAKOVA submits that the requested relief is proper since an equivalent level of safety will be ensured. ANNA BOLSHAKOVA will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., and DJI Phantom 3 , DJI Phantom 2 Vision+, and DJI Ins pire 1 Instruction Manual). Furthermore, ANNA
BOLSHAKOVA will document and maintain all maintenance records for the DJI Phantom 3

, DJI Phantom 2 Vision+, and DJI Inspire 1 UASs.

Relief from certain requirements of Section 61.113(a) and (b), entitled Priv ate pilot privileges and limitations: Pilot in command, is requested by ANNA BOLSHAKOVA to the extent necessary to allow a Pilot in Command (PIC) who has demonstrated, by m eeting minimum flight

- hour requirements, that the PIC is able to safely operate the DJI Phantom , DJI Phantom 2 Vision+, and DJI Inspire 1 UASs in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vess els, vehicles
and structures.

ANNA BOLSHAKOVA seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness,
because the DJI Phantom 3 , DJI Phantom 2 Vision+, and DJI Inspire 1 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, ANNA
BOLSHAKO VA submits that he will ensure that the DJI Phantom 3 , DJI Phantom 2 Vision+, and DJI Inspire 1 UASs are in an airworthy condition, prior to every flight, by determining that the UASs are in compliance with the operating do cuments (i.e , and DJI Phantom 3

, DJI Phantom 2 Vision+, and DJI Inspire 1 Instruction Manual s ), and that the aircraft are in a condition for safe flight.ANNA BOLSHAKOVA also seeks an exemption from the requirements of Section 91.121,

entitled Altimeter Settings, as the DJI Phantom 3 an d DJI Inspire 1 UAs will not have a typical barometric altimeter onboard. However, altitude information of the DJI Phantom 3

, DJI Phantom
2 Vision+

, and DJI Inspire 1 UAs will be provided to the PIC via Global Positioning System (GPS) equipment and radio c ommunications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with
ANNA BOLSHAKOVA’S operation of the DJI Phantom 3 v DJI Phantom 2 Vision+

, and DJI Inspire 1 UASs wit hin vis ual line of sight, at or below 5 00 feet AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, ANNA BOLSHAKOVA seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR con ditions. ANNA BOLSHAKOVA submits that safety will not be affected by operation of the DJI Phantom 3

, DJI Phantom 2
Vision+

, and DJI Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough b attery power to fly for a total duration of approximately 15.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after t hat for at least 4.5 minutes.

In accordance with 14 C.F.R. § 11.81, ANNA BOLSHAKOVA provides the following information in support o f its petition for exemption:

A. Name a nd Address o f t he Petitioner.

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

ANNA BOLSHAKOVA

606 Swallowtail Drive,

Frederick, MD 21703

( 301) 768

- 7455

Email: rimbaudy@gmail.com

B. The Specific Sections o f 14 C.F.R. From Which ANNA BOLSHAKOVA Seeks Exemption.

1. A NNA BOLSHAKOVA Seeks Exemption from t he Requirements o f Section 61.113(a) And (b). (a) Section 61.113, entitled Private pilot privileges a nd limitations: Pilot in command, subsections (a) and (b) prescribe the following, in relevant part: ( i ) 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 compensa tion or hire; nor may that person, for compensation or hire, act as PIC of an aircraft. (ii ) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if

—

a. The flight is only incidental to tha t business or employment; and b. The aircraft does not carry passengers or property for compensation orhire.

2. A NNA BOLSHAKOVA Seeks Exemption f rom The Requirements Of Section 91.7(a). (a) Section 91.7, entitled Civil aircraft airworthiness, subsecti on (a) , states the

following:

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

3. A NNA BOLSHAKOVA Seeks Exemption f rom The Requirements Of Section 91.121. (a) Section 91.121, entitled Altimeter settings, subsection ( a), states the following, in

part:

(i) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by referenc e to an altimeter that is set, when operating UAs Below 18,000 feet MSL, to:

a. The curren t reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft;

b. If there is no station within the area of this section, the current reported altimeter setting of an appropriate available station; or

c. 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. A NNA BOLSHAKOVA Seeks Exemption f rom The Requirements Of Section 91.151(b).

(a) Section 91.151, en titled Fuel requirements for flight in VFR conditions,
subsection (b), states the following:

(b) No person may begin a flight in a rotorcraft under VFR condi tions unless (considering wind and forecast weather conditions) there is enough fuel to fly t o th e first point of
intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.

5. ANNA BOLSHAKOVA Seeks Exemption from The Requirement Of Section 91.405(a).

(a) Section 91.405, entitled Maintenance required, subse ction (a), states the following: Each owner or operator of an aircraft

—

(i ) Shall have that aircraft inspected as required and shall between required inspections have discrepancies repaired as required.6. A NNA BOLSHAKOVA Seeks Exemption f r om The Req uirements Of Section 91.407(a)(1 )

(a) Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration, subsection (a)(1), states the following:

(i ) No person may operate any aircraft that has undergone maintenance

, preventive maintenance, rebuilding, or alteration unless

--

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

7. ANNA BOLSHAKOVA S eeks Exemption f r om The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2).

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

--

a. 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 b. An inspection for the issuance of an airworthiness certificate in accordance with par t 21 of this chapter.

8. ANNA BOLSHAKOVA Seeks Exemption from the Requirements of Sections 91.417(a) and 91.417(b).

(a.) Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following: ( i ) Except for work performed in a ccordance 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:

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

- hour, annual, 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

-- 1. A description (or reference to data acceptable to the

Administrator) of the work performed; and 2. The date of completion of the work performed; and 3. The signature, and certificate number of the person approving the aircraft for return to service. b. Records containing the following in formation: 1. The total time in service of the airframe, each engine, each propeller, and each rotor. 2. The current status of life

- limited parts of each airframe, engine, propeller, rotor, a nd appliance.3. The time since last overhaul of all items inst alled on the aircraft which are required to be overhauled on a specified time basis. 4. 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 applianc es are maintained. 5. The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required.
6. 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.

c. The owner or opera tor shall retain the following records for the periods prescribed: 1. The recor ds specified in paragraph (a) 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 recor ds sp ecified in paragraph (a) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold. A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.

C. The Extent Of Relief ANNA BOLSHAKOVA Seeks And The Reason ANNA BOLSHAKOVA Seeks The Relief.

1. Extent o f Relief ANNA BOLSH AKOVA Seeks a nd t he Reason ANNA BOLSHAKOVA Seeks Relief From Se ction 61.113(a) And (b).

(a) Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command, is requested to the extent n ecessary to allow a PIC who has met certain flight

- hour and currency requ irements, to con duct the proposed UAS flight operations for compensation or hire. Thi s relief is requested since the limitations set forth in Se ction 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: d. The flight is only incidental t o that business or employment; and

e. The aircraft does not carry passengers or property for compensation or hire. As set forth more fully below, ANNA BOLSHAKOVA su bmits that an equivalent le vel of safety will be maintained because no PIC will be allowed to operate the DJI Phantom 3 UAS, DJI Phantom 2 Vision+

, or DJI Inspire 1 UAS unless that PIC has met certain flight

- hour and currency requirements, demonstrating that the PIC is able to safel y operate either
the DJI Phantom 3

, DJI Phantom 2 Vision+ , or DJI Inspire 1 UAS in a manner consistent withthe operations specifications a s described in this exemption, including evasive and emergency

maneuvers, as well as maintain ing appropriate distance s from people, vessels, vehicles and structures. Further, ANNA BOLSHAKOVA submits that all flights of the DJI Phantom 3

, DJI
Phantom 2 Vision+

, and DJI Inspire 1 UASs, conducted by the PIC pursuant to the grant of this
Petitio n:

1. Will be incidental to ANN A BOLSHAKOVA' S business; and
2. W ill not ca rry passengers or property for compensation or hire.

2. Extent Of Relief ANNA BOLSH AKOVA Seeks And The Reason ANNA BOLSHAKOVA Seeks Relief From Section 91.7(a).
3. (a) Relief from Section 91.7(a) entitled Civil aircraft airw orthiness, is requested to the

extent required to allow ANNA BOLSHAKOVA to determine that the DJI
Phantom 3

, DJI Phantom 2 Vision+

, and DJI Inspire 1 UASs are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., DJI Phantom 3

, DJI Phantom 2 Vision+

, and DJI In spire 1 Instruction Manual). ANNA BOLSHAKOVA seeks the requested relief bec ause the DJI Phantom 3, DJI Phantom 2 Vision+ , and DJI Inspire 1 UASs do not require
an airworthiness certificate in acco rdance with 14 C.F.R. Part 21, Subpart H. Therefore, ANNA BOLSHAKOVA will ensure that the DJI Phantom 3, DJI Phantom 2 Vision+, and DJI Inspire 1 UASs are in airworthy condition based upon its compliance with the ope rating documents (i. e., Monthly Maintenance Log, and
DJI Phantom 3

, DJI Phantom 2 Vision+ , and DJI Inspire 1 Instruction Manual) prior to every flight, and further, determine that the airc raft are in condition for safe flight, as stated in the c onditions and limitations below

.
3. Extent Of Relief ANNA BOLSHAKOVA Seeks And The Reason ANNA
BOLSHAKOVA Seeks Relief f rom Section 91.121.

(a) Relief from Section 91.121, entitled Altimeter settings, m ay be required to allow flight operations of the DJI Phantom 3

, DJI Phantom 2 Visi on+ , and DJI Inspire 1 UASs, 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 reporte d to air traffic control (ATC) in feet above ground level (AGL), ANNA BOLSHAKOVA seek s the requested relief because the DJI Phantom 3

, DJI Phantom 2 Vision+

, and DJI Inspire 1 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 wi th the applicable conditions and li mitations stated below. As more fully set forth herein, an equivalent level of safet y will be maintained since the
DJI Phantom 3

, DJI Phantom 2 Vision+

, and DJI Inspire 1 UAs are equipped with abaro metric pressure sensor and GPS equipment, which automatically ensures that a ground level pressu re setting will be established prior to each flight, and provides the
PIC with altitude informat ion of the UA on the heads

- up d isplay of the GCS.

4. Extent Of Relief ANNA BOLSHAKO VA Seeks And The Reason ANNA
BOLSHAKOVA Seeks Relief From Section 91.151(b).

(a) Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions,
is r equested to the extent required to allow flights of the battery powered DJI
Phant om 3

, DJI Phantom 2 Vision+ , and DJI Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total
duration of 15.5 minutes to the first point of intended landing and, assuming normal cruising s peed, to fly after that for at least 4.5 minutes. ABBA BOLSHAKOVA seeks the requested relief because without an exe mption from Section 91.151(b), the flight time duration of the battery powered DJI Phantom 3

, DJI Phantom 2 Vision+

, and DJI Inspire 1 UAs wi ll severely constrain the practicality of any aerial video or still pho to flight operations that ANNA BOLSHAKOVA proposes to conduct pursuant to
this Petition. Significantly, as set forth below, the technical specifica tions of the DJI Phantom 3, DJI Phanto m 2 Vision+ , and DJI Inspire 1 UASs, the DJI Phantom 3

, DJI
Phantom 2 Vision+

, and DJI Inspire 1 operating documents, and ANNA
BOLSHAKOVA ’ S proposed operating limitations, ensure th at ANNA BOLSHAKOVA will safely operate the battery powered DJI Phantom 3

, D JI
Phantom 2 Vision+

, and DJI Inspire 1 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 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

5. Extent Of Relief ANNA BOLSHAKOVA Seeks And The Reason ANNA BOLSHAKOVA Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b).

(a) 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, ANNA B OLSHAKOVA requests relief from these Sections because the DJI Phantom 3

, DJI Phantom 2 Vision+

, and DJI Inspire 1 UASs do not require airworthiness certificates. As set forth more fully below, the DJI Phantom 3

, DJI Phantom 2 Vision+

, a nd DJI Inspire 1 UASs meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, ANNA B OLSHAKOVA will use trained techn icians to perform maintenance, alterations, or preventive maintenance on the UASs usin g the methods, techniques, and practices prescribed in the UAS operating documents (i.e., ANNA BOLSHAKOVA Aerial Operations Manual, Monthl y Maintenance Log, and D JI Phantom 3, DJI Phantom 2 Vision+ , and DJI Inspire 1 Instruction Manual). Furthermore, ANNA BOLSHAKOVA will document and maintain all maintenance records for the DJI Phantom 3

, DJI Phantom 2 Vision+

, and DJI Inspire 1 UASs.D. The Reasons Why Granting ANNA BOLSHAKOVA 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 ANNA
BOLSHAKOVA to safely, efficiently, an d economically perform a erial video and photography of real estate properties over certain areas of the United States.

Additionally, use of the DJI Phantom 3

, DJI Phantom 2 Vision+

, and DJI Inspire
1 UASs will decre ase congestion of the NAS, reduce pol lution, crashes and accidents cau sed by pilot error and provide significant benefits to the eco nomy. Notably, the benefits of ANNA
BOLSHAKOVA’ S proposed operation of the DJI Phantom 3, DJI Phantom 2 Vision+

, and DJI Inspire 1 UASs will be realized without i mplicating any privacy issues.

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

The DJI Phantom 3 and DJI Inspire 1 UAs are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditional ly utilized to obtain
aerial imagery. By reducing the amount of manned aircraft needed to p erform aerial acquisitions, an exemption allowing the use of a DJI Phantom 3

, DJI Phantom 2 Vision+

, or DJI Inspire 1 UAS would reduce the amount of manned aircraft in the NAS, reduce no ise 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 3

, DJI Phantom 2 Vision+

, and DJI Inspire 1 UAs do not require an airport t o takeoff or land. Likewi se, a reduction of manned aircraft conducting aerial video and photog raphy missions would result in fewer aircraft that must be handled by air traffic control during t he ground, takeoff, departure, arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Eff iciency Of The DJI Phantom 3, DJI Phantom 2 Vision+ , and DJI Inspire 1 UASs.

Conducting aerial acquisitions with the DJI Phantom 3

, DJI Phantom 2 Vision+

,
a nd DJI Inspire 1 UASs, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By us ing battery power and electric motors, the DJI Phantom 3

, DJI Phantom 2 Vision+

, and DJI Inspire 1 UASs produce no air pollution, and is the most viable environmentally conscious a lternative 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 hou r of leaded aviation fuel. The DJI Phantom 3

, DJI Phantom 2 Vision+

, and DJI Inspire 1 UAs, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAs ar e propelled by battery powered electric motors, rather than an internal combustion engine.

By using the DJI Phantom 3

, DJI Phantom 2 Vision+

, and DJI Inspire 1 UASs to

pe rform aerial acquisitions, the substantial risk to life and property in the air and on the groun d, which is usually associated with traditional manned aircraft flight operations, will besubst antially reduced or completely eliminated. Aside from the lack of flight crew members

located onboard the aircraft, the DJI Phantom 3

, DJI Phantom 2 Vision+

, and DJI Inspire 1 UAs (weighing approximately 2 pounds 14 ounces and 6 pounds 7.5 ounces respectively, at their maximum gross weights with lengths of 16 inches and 17.3 inches respectively, widths of 16
inches and 17.7 inches res pectively, and with no fuel on board), ha s less physical potential for collateral damage to life a nd property on the ground, and in the air, compared to the manned aircraft that typically conduc t similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

4. Performing Aerial Video and Photography Ope rations With The DJI
Phantom 3 , DJI Phantom 2 Vision+ , and DJI Inspire 1 UASs Will Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 3

, DJI Phantom 2
Vision+ , and DJI Inspire 1 UASs are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom 3

, DJI Phantom 2
Visio n+ , and DJI Inspire 1 UASs will allow United States based companies remain competitive
and c ontribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel

an d the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and oper ated companies must adopt new and alternative technology in order to remain competitive. Operating the battery powered DJI Phantom 3

, DJI Phantom 2
Vision+

, and DJI Inspire 1 UASs is one such techn ology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft.

By operating the DJI Ph antom 3

, DJI Phantom 2 Vision+

, and DJI Inspire 1
UASs can remain competitive and profitable, and t herefore, provide greater job stability to employees and contractors, which will ultimately co ntribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through commercial use of the DJI Phantom
3

, DJI Phantom 2 Vision+

, and DJI Inspire 1 UASs, p rovides a stable wor kforce 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.

5. There Are No Pr ivacy Issues.

Similar to the manned aerial acquisition flight operations that have been
conducted for decades, ANNA BOLSHAKOVA ’ S proposed operation of the DJI Phantom 3

, DJI Phantom 2 Vision+ , and D JI Inspire 1 UASs will not implicate any privacy issues. Specifically, the D JI Phantom 3

, DJI Phantom 2 Vision+

, and DJI Inspire 1 UASs will be operated only in compliance with oper ating documents (i.e., Aerial Operations Manual, Monthly
Maintena nce Log, and DJI Phantom 3

, DJI Phantom 2 Vision+

, and DJI Inspire 1 Instruction Manual) which requires property owne r 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 N ot Ad versely Affect Safety, Or

How The Exemption Would Provide A Level Of Safety A t Least Equal To That Provided By The Rule From Which ANNA BOLSHAKOVA Seeks Exemption.

1. Reasons Why The DJI Phantom 3 , DJI Phantom 2 Vision+ , and DJI Inspire 1 UAs
Meet The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA)
Section 333.

(a) In consideration of the size, weight, speed, and limited operating area associated
with the unmanned aircraft and its operation, ANNA BOLSHAKOVA ’S operation of the
DJI Ph antom 3

, DJI Phantom 2 Vision+

, and DJI Inspire 1 UASs meet the conditions of
FMRA Sectio n 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Su bpart H. Section 333 provides authority for a UAS to operate
withou t airworthiness certificati on and sets forth requirements for considering whether a
UAS will create a hazard to user s of the NAS or the public, or otherwise pose a threat to national security. Specificall y, FMRA Section 333 states the following, in part :

(i ) In General.

-- Notwithstanding any other requirement o f this subtitle, and
not later than 180 days after the date of enactment of this Act, the Sec retary 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.

(ii ) Assessment of Unmanned Aircraft Systems.

-- In making the determination
under subse ction (a), the Secretary s hall determine, at a minimum

—

(a ) which types of unma nned aircraft systems (UAS ) , if a ny, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual l ine of sight do
not create a hazard to users of the n ational airspace system or the public or pose a threat to national security; and whether a certifi cate of waiver,
certificate of authorization, or airworthiness certification under section
44704 of tit le 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1).

(b ) Requirements for Safe Operation.

-- If the Secretary dete rmines under this section
that certain unmanned aircraft systems may oper ate safely in the national airspace system, the Secretary shall establish requirements for the safe operation o f such aircraft systems in the national airspace system.

In seeking this exemption, ANNA BOLSHAKOVA submits that the DJI Phantom
3 and

, DJI Phantom 2 Vision+

, DJ I Inspire 1 UASs can operate safely in the NAS pu rsuant to FMRA Section 333, as demonstrated by:

(a) T he characteristics of the DJI Phantom 3

, DJI Phantom 2 Vision+

, and DJI Inspire 1 UASs;(b) T he pilot certification requirement; and

(c) T he specific operating limitations.

a. The Specifications Of The DJI Phantom 3 , DJI Phantom 2 Vision+ , and DJ I Inspire 1
UAS s Demonstrate Its Safe Characteristics.

The DJI Phantom 3

, DJI Phantom 2 Vision+

, and DJI Inspire 1 UASs do not create a
haz ard to users of the NAS or the public, or otherwise pose a threat to national secur ity
considerin g its size, weight, speed, and operational capability.

i. Technical Specifications Of The DJI Phantom 3 , DJI Phantom 2 Vision+ , and DJI Inspire 1 UASs.

The technical specifications of the DJI Phantom 3 and DJI Inspire 1 UASs are set forth by the DJI Phanto m 3 and DJI Inspire 1 Specifications and Data Sheet s, attached.

ii. The DJI Phantom 3 , DJ I Phantom 2 Vision+ , and DJI Inspire 1 UASs
Aut onomous Flight And Navigation Modes Enable The UASs To Remain Within A Defined Operational Area.

The DJI Pha ntom 3

, DJI Phantom 2 Vision+

, and DJI Inspire 1 UASs may be ope rated in both manual and fully autonomous flight modes. A complete description of the flight and navigational modes of the DJI Phantom 3

, DJI Phantom 2 Vision+

, and DJI Inspire 1 UASs is provided at pages 25

- 35 of the DJI Phantom 3

, pages 11

- 12 of the DJI Phantom 2 Vision+

, and

p ages 12

- 1 6 and 45

- 50 of the DJI Inspire 1 User Manuals.

iii. The DJI Phantom 3 and DJI Inspire 1 UAS s Are Designed For
Automatic Return To Home Point Or Hover In The Event Of Loss Of The Control Link Or Navig ation.

When the Control Link is lost, the DJI Phantom 3

, DJI Phantom 2 Vision+

, and DJI Inspire 1 UAs will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI
Phan tom 3

, DJI Phantom 2 Vision+

, and DJI Inspire 1 UAs do not reacquire control link data from the GCS, the UAs will assume that the Control Link is lost and the UAs will return to the home position (i.e., failsafe mode ) via GPS, and will descend to the takeoff position and
shutdown. A complete description of the Failsafe Functions of the DJI Phantom 3 UAS are set forth at page 13 of the DJI Phantom 3 , pages 27

- 28 of the DJI Phantom 2 Vision+

, and page 13

o f the DJI I nspire 1 User Manual s.

iv

. The DJI Phantom 3 and DJI Inspire 1 GCS And Its Operation. A complete desc ription of the operation and specificat ions of the DJI Phantom 3

, DJI
Phantom 2 Vision+

, and DJI Inspire 1 GCS and flight control software is provided at pages 32

- 43 of the DJI Phantom 3, pages 32

- 35 of the DJI Phantom 2 Vision+

, and pages 40

- 47 of the DJI Inspire 1 User Manuals.

b. Flight Operations Of DJI Phantom 3 and DJI I nspire 1 UASs Are Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer.ANNA BOLSHAKOVA will only utilize pilots who comply with the FAA requirements

the to act as a pilot in command (PIC ) of the DJI Phantom 3

, DJI Phantom 2 Vision+

, and DJI Inspire 1 UASs. Additionally, a safety observer will assist all pilots during flight time.

c. Flights Of DJI Phantom 3 , DJI Phantom 2 Vision+ , and DJI Inspire 1 UA Ss Will Be
Conducted Pursuant To Specific Operating Limitations.

In seeking this exemption, ANNA BOLSHAKOVA propos es to commercially operate
DJI Phantom 3

, DJI Phantom 2 Vision+

, and DJI Inspire 1 UASs for the special pur pose of
conductin g aerial video and photography over certain areas of United States, pursuant to th e following specific operating limitations:

1. Operations authorized by this grant of exemption wi ll be limited to the following
aircraft described in the operating documents, rotorcraft UAS s weighing less than 55 pounds maximum gross weight: DJI Phantom 3

, DJI Phantom 2 Vision+

, and DJI Inspir e 1 Unmanned Aircraft Systems. Proposed operations of any other aircraft will require a new petiti on or a petition to amend this gran t. 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 altitu de of no more th an 500 feet above ground
level (AGL), as indicated by the procedures specified in the operat ing documents unless a special request is made and approved by ATC. All altitudes reported t o ATC must be in feet AGL.
5. The UAs must be ope rated within visual line of sight ( VLOS) of the PIC at all
times. This requires the PIC to be able to use human vision un aided by any device
other than corrective lenses, as specified on the PIC’s FAA

- issued ai rman medical
certificate.
6. The use o f first person view (FPV) by the PIC or safety observer (SO) is not permitted.
7. All operations must utilize a safety observer (SO). The SO may be used to satisfy
the VLOS requirement as long as the PIC always maintains VLOS capability. The
SO and PIC must be able to communicate verbally at all times. Electronic messagi ng or texting is n ot permitted during flight operations. The PIC must be designated before the fli ght and cannot transfer his or her designation for the duration of the flight. The PIC must ensu re that the SO can perform the functions prescribed in the operating documents.
8. The SO must not perform any other duties beyond ass isting the PIC with seeing
and avoiding other air traffic and other ground based obstacles/obstructio ns and is not permitted to operate the camera or other instruments.
9. The operating documents and the grant of exemption must be accessible during
UAS operations and made available to the Administrator upon re quest. If a discrepancy exists between the conditions and limitations contained in the grant

o f exemption and the procedures outlined in the operating documents, theconditions and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, the operator m ust follow the procedures as outlined in its operating documents. The ope rator may updat e or revise its operating documents. It is the operator’s responsibility to tr ack such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if it petitions for
extension or amendment to the grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted the

exe mption, then the operator must petition for amendment to its grant of exemption. The FAA’s U AS Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to t he operating documents.
10. Prior to each flight the PIC must inspect the UAS to ens ure that it is in a condition
f or 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 Groun d Control Station must be included in the preflight inspection. All maintenance an d alterations must be properly docume nted in the
aircraft records.
11. Any UAS that has underg one maintenance or a lterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the air craft records

. 12. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered i n the relevant
sections of the operating documents.
13. The ope rator must follow the UAS manu facturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements.
14. The operator must carry out its maintenance, i nspections, and record keeping requirements, in accordance with the operating documents. Mainten ance, ins pection, 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 aut horized person returning the UAS
to service.
15. Each UASs operated under this exemption must comply with all manufacturer Safety Bulletins.
16. The authorized person must make an entry in the air craft record of the corrective
action tak en against discrepancies discovered between inspections.
17. The operator may not permit any PIC to operate unless the PIC mee ts the operator’s qualification criteria and demonstrates the ability to safe ly operate the
UAS in a manner consistent with how the UAS will be operated under the

ex emption, including evasive and emergency maneuvers and maintaining appropriate distance s f

ro m 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. Ho wever, training operation s may only be conducted during dedicated training sessions. During training, proficiency, and

ex perience

- building flights, all persons not essential for flight
18. O perations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119.
19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorological condition s (VMC). If flight at night is required, a special request will be made at the FAA offi ce 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 po int 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
conduc ted in accordance with a NOTAM as required by the operator’s COA. The letter of agreement wi th the airport management must be made available to the Administrator upon request.
21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the
PIC.
22. If the UA loses communications or loses its GPS si gnal, it must return to a pre

determined location within the planned operating area and land or be recovered in
accordance with the operating documents.
23. The PIC must abort the flight in the event of unpredict ed obstacles or emergencies
in accordance with the operating documents.
24. 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.
25. The operator must obtain an Air Traffic Organizati on (ATO) iss ued Certificate of Waiver or Authorization (COA) prior to conducting an y operations under the grant of exemption. This COA will also require the operator to requ est a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hou rs prior to the operation. All operations shall be conducted in accordanc e with airspace requ irements in the ATO issued COA including class of airspace, altitude level and potential transponder requirements.
26. All aircraft operated in accordance with the exemptio n must be identified by serial number, registered in accor dance with 14 C.F.R. part 47, and have identification (N

- Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable.
27. Before conducting operations, the radio frequency spectrum used for operation

an d control of the UA must comply with the Federal Communicat ions Commission (FCC) or other appropriate government oversight agency requirements.28. The documents required fewer than 14 C.F.R. 91.9 a nd 91.203 must be available

to the PIC at the Grou nd Control Station of the UAS any time the UAS is operating. These documents must be made available t o the Administrator or any
law enforcement official upon request.
29. The UA must remain clear and yield the right of way to all manned aviation

o perations and activities at all times.
30. The UAS may not be operated by the PIC from any moving device or vehicle. 31.
31. Flight operations must be conducted at least 500 feet from all non participating persons (persons other than the PIC, SO, operat or trainees or essential persons),

ves sels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently pr otect nonparticipating

persons from the UA and/or debris in the event of an accident. The operator must
ensure tha t nonparticipating persons remain under such protectio n. If a situation

a rises where nonparticipating persons leave such protection and are wit hin 500 feet of the UA, flight operations must cease immediately and/or;
b. The aircraft is operated near vessels, ve hicles or structures where the owner/controller of such vessels, vehicles or structures has gran ted 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;

c. Operations nearer to the PIC, SO, operator traine es or essential persons do

not present an undue hazard to those persons per § 91.119(a).
32. All operations shall be conducted over private or controlled

- access property w ith 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 tra nsg resses the lateral or vertical boundaries of the operational area as defined by the applicab le COA must be reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours.
Acc idents must be reported to the National Transportation Safety Board ( NTSB) per instructions c ontained on the NTSB Web site: www.ntsb.gov.

2. Reasons Why a n Exemption From The Requireme nts Of Section 61.113(a) a nd (b) Would Not Adversely Affect Safety.

ANNA BOLSHAKOVA 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

, DJI Phantom 2 Vision+

, and DJI Inspire 1 UASs unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is a ble to sa fely operate the D JI Phantom 3

, DJI Phantom 2 Vision+

, or DJI Inspire 1 UAS in a manner consistent
with the ex emption, including evasive an d emergency maneuvers and maintaining appropriate
distances from people, vessels, vehicles and structures.

Considering ANNA B OLSHAKOVA’ S proposed area of operations, the operating limitations set forth

- above, and the airmanship skill s necessary to safely operate theDJI Phantom 3

, DJI Phantom 2 Vision+

, or DJI Inspire 1 UAS, ANNA BOLSHAKOVA submits

that the additional manned airmanshi p experience of a commercially certificated pilot would not
correlate to the airmanshi p skills necessary for BLAKE J COPP INGER’ 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 resp ects, to those presented herein.

ANNA BOLSHA KOVA will not allow any PIC to operate the DJI Phantom 3

, DJI Phantom 2
Vision+

, or DJI Inspire 1 UAS unless that PI C has demonstrated, by meeting minim um flight

hour requirements or the DJI Phantom 3

, DJI Phantom 2 Vision+

, or DJI Inspire 1 UAS training
and currency requirements, that the PIC is able to safely operate the DJI Phantom 3

, DJI
Phantom 2 Vision+

, or DJI Inspire 1 UAS in a manner consistent with this exemption, including
evasive and emer gency mane uvers and maintaining appropriate distances from people, vess els,
vehicles and structures. Specifically, the PIC must have accumulated and logged, in a ma nner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pi lot (with a
minimum of 5 hours of those hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes).

CONCLUSION

ANNA BOLSHAKOVA 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 w ill permit safe operation of the DJI Phantom 3

, DJI Phantom 2 Vision+

, and DJI Inspire 1 UASs commerci ally,
without an airworthiness certificate, for the limited purpose of conducting aerial vide o and photog raphy over certain areas of the United States. By granting this Petiti on, the FAA
Admini strator 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 ANNA
BOLS HAKOVA to safely, efficiently, and economically operate the DJ I Phantom 3 and DJI Inspire 1 UASs commercially within the NAS. WHEREFORE, in accordance with the Federal
Av iation Regulations and the FAA Modernization and Reform Act of 2012, Section 333 , ANNA BOLSHAKOVA respectfully requests that the Administrator g rant 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 Leading Edge to operate the DJI Phantom 3

, DJI Phantom 2 Vision+

, and DJI Inspire 1 UASs commercially for the purpose of conductin g aerial video and photography over certain areas of the United States.

Dated: June 21 , 2015

Submitted by

ANNA BOLSHAKOVA