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June 29, 2015
Docket Operations, M-30 U.S. Department ofTransportation (DOT) 1200 New Jersey Avenue, SE Room W12-140 West Building Ground Floor Washington, DC 20590-0001 8245 YMCA Plaza Drive Baton Rouge, LA 70810 225.767.5/25

RE: Aero-Data Corporation LLC's Petition for Exemption from Federal Aviation Regulations for the Purpose ofOperating an Unmanned Aircraft System
Dear Sir or Madam:

Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA) and 14 C.F.R. Part 11, Aero-Data Corporation LLC seeks an exemption from Federal Aviation Regulations to allow the commercial use ofthe DJI Phantom 3 Professional Unmanned Aircraft System (UAS) for the purpose ofaerial surveys within the National Airspace System (NAS).
The FAA has granted exemptions to Hawk Aerial, LLC (Exemption No. 13306A) and InTec of San Antonio, LP (Exemption No. 11867) for the use ofthe DJI Phantom 3 for similarpurposes. By approving these exemptions, the FAA will allow a safe and risk adverse method to collect aerial data. The battery-powered UAS described herein is smaller and lighter than fixed-wing aircraft. It operates at lower altitudes with no people onboard. Its use will diminish the likelihood ofdeath or serious injury to persons in the air or onthe ground and the likelihood of damage to structures. The UAS offers little orno threat to national security.

In addition, Aero-Data Corporation LLC requests permission to assist first responders who may require assistance. We will remain subject to all limitations outlined herein as we do so.
The name and contact information ofthe applicant is as follows:
Aero-Data Corporation LLC 8245 YMCA Plaza Drive Baton Rouge, Louisiana 70810-0919

We are prepared to modify or amend anypart ofthis request to meet an equivalent level of safety. We look forward to working with your office. Please contact Randall Grip at 225.767.5725 orrgrip@aero-data.com ifyou require any additional information or clarifications. .-

**-~**Exemptions Requested: Aero-Data Corporation is requesting this waiver as it applies to the following FARs: § 45.23(b) § 45.27(a) § 61.113(a) and (b) § 61.315(a) and (c) § 91.7 (a) § 91.9(b)(2) and (c) § 91.103(b)(2) § 91.105 § 91.109 § 91.119(b) and (c) § 91.121 § 91.151 § 91.203 (a)(1) § 91.405 (a) § 91.407 (a)(l) § 91.409 (a)(1) & (a)(2) § 91.417 (a) & (b)
Introduction and Interests ofthe Petitioner
Since 1983, Aero-Data Corporation LLC (hereinafterreferred to as "Aero-Data") has provided quality services including: aerial photography acquisition, orthophoto production , planimetric mapping, topographic mapping, geographic information systems, volumetric calculations, and photo interpretation to clients throughout the United States. Our clients include many industry leaders in energy, mining, and chemical manufacturing. We have provided services to local and state government as well as to the following federal agencies: the U.S. Geological Survey, the U.S. Environmental Protection Agency, the U.S. Soil Conservation Service, the U.S. Department ofJustice and the U.S. Army Corps ofEngineers.

Aero-Data seeks an exemption to operate the DJI Phantom 3 Professional UAS for compensation
orhire within the NAS to provide professional aerial photographs, videos, andphotogrammetry services to our clients. Background
TheUAS The DJI Phantom 3 Professional UAS is comprised ofa quad-rotor unmanned aircraft and a handheld ground control station. The specifications ofthe UAS are as follows:
Gross Weight (includingbattery andpropellers): 1280 g Diagonal Size (includingpropellers): 590 mm Maximum Ascent Speed: 5 m/s Maximum Descent Speed: 3 m/s Vertical Hover Accuracy:+/- 0.1 m

2Horizontal Hover Accuracy: +/- 1.5 m Maximum Speed: 16 m/s

The DJI Phantom 3 Professional has a Return to Home Feature that returns the aircraft to its launch site inthe event ofa lowbattery orthe loss ofthe remote controller signal. A full list of all specifications is located inthe Appendix ofthe manufacturer's manual. (The manual is available for review at http://www.dji.com/product/phantom-3/download) Operation ofthe UAS Aero-Data has a Flight Operation Manual ("FOPM") that is intended to provide an equivalent level ofsafetyto the Federal Aviation Regulations from which Aero-Data seeks exemption. Aero-Data will provide an electronic orhardcopy ofthe FOPM to the Pilot in Command ("PIC") and each observer. The PIC will make sure that each flight is in compliance withthe FOPM, the DJI Phantom 3 Professional User's Manual and applicable FARs.
Aero-Data's Flight Operation Manual 1. The minimum crew for UAS operation will consist ofa PIC andthe Visual Observer (VO). 2. The PIC musthold at least a FAAprivate pilot certificate or sport pilot certificate to operate the UAS. 3. The PIC musthold a current FAA medical certificate or a valid U.S. driver's license. 4. The PIC will be proficient in flying the DJI Phantom 3 Professional UAS and have at least 25 hours offlying time ofthe UAS in a manner consistent withhow the UAS will be operated under this exemption. 5. Priorto each flight, the PIC will conduct a pre-flight inspection in accordance withthe manufacturer's user manual to determine ifthe UAS is in condition for a safe flight. 6. After maintenance or alterations to the UAS, the PIC and VO will perform a functional test flight before conducting further operations. 7. Before operating the UA overprivate or controlled-access property, the PIC will obtain permission from the owner or controller ofthe property. 8. Priorto flight, the PIC will give a briefing to crew regarding the plannedUAS operation. All personnel involved in the operation mustbe present. 9. The UA will be operated within the Visual Line ofSight (VLOS) ofthe PIC and VO at all times. 10. The PIC and VO mustbe able to communicate verbally at all times. 11. The PIC and VO are not allowed to text or email during operations. 12. Flights will be conducted onlyin daylight hours. 13. Flights will be conducted onlyin visual meteorological conditions. 14. The UA will notbe operated inrain, snow, or fog conditions. 15. The UA will be kept clear from clouds at all times. 16. The PIC will notbegin a flight unless there is enoughpower for the UA to conductthe intended operation and still have a reserve batterypower ofno less than 25%. 17. The UA will not be operated at an altitude greater than 400 feet above ground level (AGL). 18. The speed ofthe UA will not exceed 25 miles perhour. 19. The UA will not be operated from a moving vehicle.

320. The UA will remain clear and give wayto all manned aircraft. 21. The UA will remain at a distance ofat least 5 nautical miles ofany airport orheliport unless a letter ofagreement from the airport's management is obtained. 22. Flights will not be conducted over denselypopulated areas. 23. Flights will be operated at a lateral distance ofat least 100 feet from people, structures, vehicles, and vessels not associated withthe operation, unless property owner 

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orperson has given authorizationpriorto the flight. 24. The PIC will abort the flight inthe event ofanunpredicted obstacle or emergency. 25. The PIC will report anyincident, accident or flight operation that transgresses the lateral
orvertical boundaries ofthe operational area to the FAA's UAS Integration Office within 24 hours. 26. The PIC will report any accidents involving the UA to the National Transportation Safety Board. Basis for Petition
Aero-Data, pursuantto the provisions ofthe Federal Aviation Regulations (FAR) (14 C.F.R. § 11.61) andthe FAA Modernization and Reform Act of2012 ("FMRA"), Section 333, Special Rules for Certain UnmannedAircraftSystems ("Section 333"), herebyrespectivelypetitions the Administrator to operate the DJI Phantom 3 Professional within the NAS and for an exemption from the requirements ofTitle 14 Code ofFederal Regulations§§ 45.23(b), 45.27(a), 61.113(a) and (b), 61.315(a) and (c), 91.7 (a), 91.9(b)(2) and (c), 91.103(b)(2), 91.105, 91.109,91.119 (b) and (c), 91.121, 91.151,91.203 (a)(l), 91.405 (a), 91.407 (a)(l), 91.409 (a)(l) & (a)(2), 91.417 (a) & (b).
Section 45.23(b) Display ofMarks Aero-Datarequests relieffrom Section 45.23(b) because the DJI Phantom 3 Professional UAS does nothave a cabin, cockpit, orpilot station upon whichthe markings canbe placed.

Aero-Data submits an equivalent level ofsafety canbe achievedbymarking the bodyofthe UAS withthe serial number andN-number. The lettering oftheN-number will be as large as possible.
Section 45.27(a) Location ofmarks; nonfixed-wing aircraft Aero-Datarequests relieffrom Section 45.27(a) because the DJI Phantom 3 Professional UAS does not have a cabin, fuselage, boom ortail, upon whichthe markings canbe displayed.

Aero-Data submits an equivalent level ofsafety canbe achievedbymarking the bodyofthe UAS with the serial number andN-number. The lettering oftheN-number will be as large as possible.
Section 61.113(a) and (b) Private pilot privileges and limitations: Pilot in command Aero-Datarequests relieffrom Section 61.113(a) and (b) to the extent necessaryto allow a person who holds a private pilot certificate to operate the UAS for compensation or hire.

Aero-Data submits that a private pilot can achieve an equivalent level ofsafety as a commercial pilotbecause the risk in operating the UAS is significantly lowerthan the risk associated withthe

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### operation ofa manned aircraft. The UA does not carry a pilot orpassengers. The UA is smaller, lighter, and easier to maneuver than manned aircraft. The UA will be operated within a limited area ofoperation. Furthermore, Aero-Data will ensure that the PIC is proficient in flying the DJI Phantom 3 Professional and that the PIC has at least 25 hours offlying time ofthe UAS in a manner consistent with how the UAS will be operated under this exemption.
Section 61.315(a) and (c) What are the privileges and limits ofmy sport pilot certificate? 

### Aero-Data requests relieffrom Section 61.315(a) and (c), which states that a sport pilot cannot operate an aircraft for compensation or hire.
Aero-Data submits that a sport pilot can achieve an equivalent level ofsafety as a commercial pilot because the risk in operating the UAS is significantly lowerthan the risk associated with the operation ofa manned aircraft. The UA does not carry a pilot orpassengers. The UA is smaller, lighter, and easier to maneuver than manned aircraft. The UA will be operated within a limited area ofoperation. Furthermore, Aero-Data will ensure that the PIC is proficient in flying the DJI Phantom 3 Professional and that the PIC has at least 25 hours offlying time ofthe UAS in a manner consistent with how the UAS will be operated under this exemption.
Airworthiness Certificates 

### In consideration ofthe size, weight, speed, and limited operating area associated with the UAS and its operation, the DJI Phantom 3 Professional meets the conditions ofSection 333 and will not require airworthiness certification in accordance with 14 C.F.R. Part 21, Subpart H, or any associated noise certification and testing requirements ofPart 36.
Section 91.7(a) Civil aircraft worthiness 

### Aero-Data requests relieffrom Section 91.7(a), which states that "nopersonmay operate a civil aircraft unless it is in an airworthy condition", because the DJI Phantom 3 Professional UAS does notrequire an airworthiness certificate in accordance with 14 C.F.R., Part 21, Subpart H.
Aero-Data submits the PIC will ensure the UAS is in condition for safe flight, by determining the UAS is in compliance with the DJI Phantom 3 Professional UAS User Manual and Aero-Data's Flight Operations Manual. The PIC will discontinue the flight ifunairworthymechanical conditions occur.
Section 91.9(b)(2) and (c) Civil aircraft flight manual, markings, and placard requirements 

### Aero-Data requests relieffrom Section 91.9(b)(2) because the UAS does not have the room or capacityto store the flight manual onboard the aircraft. Aero-Data submits an equivalent level of safety canbe achieved bykeeping the flight manual with the PIC at the ground control point, during operation ofthe UAS. The flight manual will be made available to the Administrator or law enforcement upon request.

5Aero-Data requests relieffrom Section 91.9(c) because the UAS cannotbe marked in accordance with Part 45. The UAS does not have a cabin, cockpit, orpilot station upon which the markings can be placed. Aero-Data submits an equivalent level ofsafety can be achievedbymarking the UAS with the serial number and theN-number. The lettering oftheN-numberwill be as large as possible.
Section 91.103(b)(2) Preflight Action Aero-Datarequests relieffrom Section 91.103(b)(2), whichrequires the PIC to be familiar with the runway lengths at airports ofintended use, and takeoffand landing distance information.
The operation ofthe UAS does not require an airport for takeoffand landing. Aero-Data submits
an equivalent level ofsafety can be achievedbyhaving the PIC check weather conditions and the takeoffand landing distances from the ground control pointbefore flight.
Section 91.105 Flight crewmembers at station Aero-Datarequests relieffrom Section 91.105, which requires crewmembers to be at theirproper stations with their safetyharnesses fastened while enroute and during takeoffand landing, unless the absence is necessaryto perform duties necessary for the operation ofthe aircraft or in connection withphysiological needs.
This requirement cannot be met, because the UA does nothave flight crewmembers onboard the aircraft. Aero-Data submits an equivalent level ofsafety canbe maintained byhaving the PIC land the UAbefore attending to any emergent orphysiological needs.
Section 91.109 Flight instruction; Simulated instrument flight and certain flight tests Aero-Datarequests relieffrom Section 91.109, which requires that "nopersonmayoperate a civil aircraft (except a manned free balloon) that is beingused for flight instruction unless that aircraft has fully functioning dual controls."
This requirement cannotbe metbecause the UAS does nothave dual controls. Aero-Data submits an equivalent level ofsafety can be achievedby ensuring the PIC is proficient in flying the DJI Phantom 3 Professional and that the PIC has at least 25 hours offlying time ofthe UAS in a manner consistent withhow the UAS will be operated under this exemption. The PIC will be familiar with the DJI Phantom Professional UAS User Manual and Aero-Data's Flight Operations Manual.
Section 91.119(b) and (c) Minimum safe altitudes: General Aero-Datarequests relieffrom Section 91.119(b) and (c), whichrequire the aircraft to be maintained at an altitude ofat least 1000 feet over congested areas and 500 feet over sparsely populated areas, and at a distance ofat least 500 feet from anyperson, vessel, vehicle, or structure.
Aero-Data will operate the UA at orbelow 400 feet AGL. Aero-Data submits an equivalent level ofsafety can be metbecause unlike manned aircraft, the UA operates without combustible fuel and with no people onboard, thus reducing the likelihood ofdeath or serious bodilyinjury to persons in the air or onthe ground, as well as reducing the risk ofdamage to vessels, vehicles,

6and structures. Aero-Datawill obtainprior consent from the property owner andpersons onthe groundbefore operations.
Section 91.121 Altimeter Settings Aero-Data requests relieffrom Section 91.121, because the UAS does not have a typical barometric altimeter onboard.

Aero-Data submits that an equivalent level ofsafety canbe metbecause the altitude ofthe UAS will be provided to the PIC through the UAS's GPS equipment andradio communications telemetry data link, which downlinks altitude information from the UA to the Ground Control System for active monitoring ofthe flight path. This information will be sufficient for the PIC to maintain the UA at an altitude below the 400 AGL limitations. In addition, the PIC will only operate the UA in a visual line ofsight.
Section 91.151 Fuel Requirements for flight in VFR conditions Aero-Datarequests relieffrom Section 91.151, which requires that no personbegin a flight under VFR conditions unless there is enough fuel to fly to the first intendedpoint oflanding and after that for 30 minutes.

Aero-Data submits that the terminating the flight with 25% ofthe batterypowerremaining will provide an equivalent level ofsafety. Furthermore, the DJI Phantom 3 Professional UAS has a Low BatteryReturn to Home Feature, inwhich the operator is promptedto return the aircraft home or land it immediately. The UA will landitselfautomatically ifthe remaining battery power is only sufficient for the aircraft to descend from its current altitude.
Section 91.203(a)(1) Civil Aircraft: Certifications required Aero-Data requests relieffrom Section 91.203(a)(1), which states that no person may operate a civil aircraft without a current airworthiness certificate, because the DJI Phantom 3 Professional UAS does notrequire an airworthiness certificate in accordance with 14 C.F.R., Part 21, Subpart H.

Aero-Data submits that the Pilot in Command (PIC) will ensure the UAS is in airworthy condition prior to every flight, by determining the UAS in in compliance withthe DJI Phantom 3 Professional UAS User Manual and Aero-Data's Flight Operations Manual.
Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2) and 91.417(a) & (b) Aero-Data request relieffrom Sections: 91.405(a), 91.407(a)(l), 91.409(a)(1) & (a)(2), and 91.417 (a) & (b), as these sections set forth requirements for maintenance that only applyto aircraft with an airworthiness certificate.

Aero-Data submits that the requested reliefis proper since an equivalent level ofsafety will be ensured. Aero-Data will perform maintenance, preventative maintenance and/or alterations on the UAS using the methods specified in the manufacturer's manual. After any maintenance or alterations, Aero-Datawill perform a functional test flight before conducting further operations. Aero-Data will document and maintain all maintenance records on the UAS. Aero-Data will comply with all ofthe manufacturer's safetybulletins.

7The Reasons Why Granting Aero-Data's Exemption Would Benefit the Public as a Whole
1. The Public Will Benefit by the Aerial Data Collected. Aero-Dataperforms aerial surveymissions in support ofthe government as well as such industries as forestry, mining, energy, and chemical manufacturing. These industries will use the aerial data acquiredbyAero-Data's UAS in monitoring coastal erosion and wetlands loss, levee inspections, managing standhealth, volumetric determinations, right ofway analysis, and environmental impact studies. These proposed uses not onlyprovide economic benefits to the public, but they also increase the public's safety.
2. The Public Will Benefit by Decreasing Congestion ofthe NAS. Aero-Data's use ofthe UAS would decrease the congestion ofthe NASbyreducing the number ofmanned aircraft needed to obtain aerial imagery. Because the UAS does not require an airport for takeoffand landing, its use would lessen the burden on air traffic control.
3. The Public Will Benefit from a Reduction in Pollution. Aero-Data currently uses a fixed-wing aircraft for aerial surveys. Our aircraft burns 16 gallons ofleaded aviation fuel perhour. By granting the present Petition, Aero-Data would lessen our carbon imprint. The DJI Phantom 3 Professional UAS is battery-operated andhas an electric motor. It produces no airpollution and little noise pollution.
4. The Public Will Benefit from an Increase in Safety. Unlike manned aircraft, the UA operates without combustible fuel and with no people onboard. Aero-Data's use ofthe UAS for aerial surveys will diminish the likelihood ofdeath or serious bodilyinjuryto persons in the air onthe ground, as well as reduce the risk ofdamage to structures.
5. The Public Will Benefit Economically. With the rising cost ofaviation fuel and the EPA's regulatory actions phasing out leaded aviation fuels, American companies like Aero-Data need to seek out new technologies, like unmanned aircraft, to remain viable and competitive. By operating the UAS, Aero-Data will remain profitable and be able to offerjob stabilityto its employees. A stable workforce promotes consumer spending, which in tum increases tax revenues for local, state and federal governments.
6. There Are No Privacy Issues. Aero-Data's operation ofthe UAS will not implicate any privacy issues, because the flights will only occur overprivate I and or controlled-access property, with the landowner's prior consent and knowledge. Summary
Aero-Data Corporation LLC seeks an exemption from the requirements of 14 C.F.R. 

### §§ 45.23(b), 45.27(a), 61.113(a) and (b), 61.315(a) and (c), 91.7 (a), 91.9(b)(2) and (c), 91.103(b)(2), 91.105, 91.109, 91.119 (b) and (c), 91.121, 91.151, 91.203 (a)(l), 91.405 (a), 91.407 (a)(1), 91.409 (a)(l) & (a)(2), 91.417 (a) & (b).

8A BriefDescription ofthe Nature ofthe Exemption Aero-Data Corporation LLC Seeks: This exemption will permit Aero-Data Corporation LLC to operate an Unmanned Aircraft System (UAS) commercially for the purpose ofaerial surveys within the National Airspace System (NAS).
Conclusion
Aero-Data Corporation LLC seeks an exemption pursuantto 14 C.F.R. §11.61 and Section 333 ofthe FAA Modernization and Reform Act of2012, to permit safe operation ofthe DJI Phantom 3 Professional UAS commercially, without an airworthiness certificate, for the special purpose of conducting aerial surveying operations. By granting this petition, the FAA Administrator will be fulfilling the Congressional mandate ofSection 333 ofthe FAA Modernization and Reform Act of2012 to expedite approval ofcertain UAS within the NAS, while also advancing the interests ofthe public. Sincerely,

Randall Grip Vice President Aero-Data Corporation LLC 8245 YMCA Plaza Drive Baton Rouge, Louisiana 70810-0919 225.767.5725 rgrip@aero-data.com

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