### Joseph St.Pierre /JS Airimage, 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) CONCERNING

COMMERCIAL OPERATION OF DJI PHANTOM 3 UNMANNED

AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Joseph St.Pierre / JS Airimage, LLC

2 1/2 Beacon Street

Suite 125 Concord, NH 03301

603-731-1385

Related documents attached

### UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION
FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: Joseph St.Pierre JS Airimage,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) CONCERNING COMMERCIAL
OPERATION OF DJI PHANTOM 3 UNMANNED AIRCRAFT SYSTEMS



### PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

October 16, 2015 Joseph St.Pierre JS Airimage,LLC
2 1/2 Beacon Street
Suite 125 Concord, NH 03301

603 731 1385SUMMARY

Joseph St.Pierre JS Airimage, 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 Joseph St.Pierre JS Airimage, LLC to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography of construction sites, real estate, agriculture, architectural design, Increase public knowledge of UAS,

tourism.

search and rescue and landscape over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Joseph St.PIerre JS Airimage, LLC would like to provide clients with a cost effective alternative to traditional helicopter or fix wing aerial photography which in the the past 10 years has become prohibitively expensive which impacts the petioners business of supplying aerial imagery in a cost effective manor to the market place. Joseph St.Pierre (PIC) has over 38 years of professional aerial video and photography experience and is well versed in airport operations, safe zone, air exclusion areas, and air safety. He has over 125hrs of experience piloting DJI’s Phantom models 2 and 3. Joseph St.Pierre is the sole proprietor of JS Airimage. LLC. The intent of this application is to obtain the 333 exemption in order to provide aerial imagery for the following:

Real-estate
Construction sites Aerial acquisitions used for inspections of public and private structures. Agriculture inspection Private events coverage Increase public knowledge of UAS and promote safe UAS operations Search and Rescue operations Architectural Design

TourismBACKGROUND

Unmanned Aircraft Systems: DJI Phantom 3 Professional UAS

Joseph St.Pierre JS Airimage, LLC, LLC seeks an exemption to operate DJI systems for

compensation or hire within the NAS. The DJI Phantom 3 Professional is a vertical

takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station

(GCS) utilizing electronic tablet or smart phone systems. The DJI Phantom 3

Professional has a maximum gross

weight of approximately 2 pounds 11 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 3Professional UA is equipped with four main rotors; driven by Lithium

Polymer battery powered electric motors.The DJI Phantom 3 Professional UA that will

be operated by Joseph St.Pierre /JS Airimage, LLC {PIC} will be registered in

accordance with 49 U.S.C. 44103,

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

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

Joseph St.Pierre /JS Airimage, LLC {PIC}, pursuant to the provisions of the Federal

Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate the DJI Phantom 3 Professional, 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, Joseph St.Pierre (PIC) /JS Airimage, LLC
DJI Phantom 3 Professional 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, Joseph St.Pierre (PIC) /JS Airimage, 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. Joseph St.Pierre (PIC) /JS Airimage, LLC submits that the requested relief is proper since an equivalent level of safety will be ensured. Joseph St.Pierre (PIC) /JS Airimage, LLC will use experienced personnel or technicians to perform maintenance, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Professional Instruction Manual). Furthermore, Joseph St.Pierre (PIC) /JS Airimage, LLC will document and maintain all maintenance records for the DJI Phantom

3 Professional UAS. Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested by Joseph St.Pierre (PIC) /JS Airimage, LLC to has the experienced pilot hrs to operate the DJI Phantom 3 UAS in a manner that is consistent with this exemption, including evasive and emergency maneuvers and maintaining FAA required distances from people, vehicles, vessels,and airports.Joseph St.Pierre (PIC) /JS Airimage, LLC seeks relief from Section 91.7(a), entitled Civil

aircraft airworthiness, because the DJI Phantom 3 Professional UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Joseph St.Pierre (PIC) /JS Airimage, LLC submits that he will ensure that the DJI Phantom 3 Professional UAS is in an airworthy condition, prior to every flight, by determining that the UASs are in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Professional Instruction Manual), and that the aircraft is in a condition for safe flight. Joseph St.Pierre (PIC) /JS Airimage, LLC also seeks an exemption from the requirements of Section 91.121,entitled Altimeter Settings, as the DJI Phantom 3 Professional UA will not have a typical barometric altimeter onboard. However, altitude information of the DJI Phantom 3 Professional UA will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined

with Joseph St.Pierre (PIC) /JS Airimage, LLC operation of the DJI Phantom 3
Professional UAS within visual line of sight, at or below 2 00 feet AGL, will ensure a level of safety equivalent to Section

91.121. Additionally, Joseph St.Pierre (PIC) /JS Airimage, LLC seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. Joseph St.Pierre (PIC) /JS Airimage, LLC submits that safety will not be affected by operation of the DJI Phantom 3 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 approximately 13.5 minutes

.

In accordance with 14 C.F.R. § 11.81, Joseph St.Pierre (PIC) /JS Airimage, LLC provides the following information in support of its petition for exemption:

A. Name And Address Of The Petitioner.

Joseph St.Pierre /JS Airimage,LLC
2 1/2 Beacon Street
Suite 125 Concord, NH 03301

603 731 1385 jsp247@gmail.comB. The Specific Sections Of 14 C.F.R. From Which Joseph St.Pierre (PIC) /JS Airimage, LLC Seeks Exemption.

1. Joseph St.Pierre (PIC) /JS Airimage, 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 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.

2. Joseph St.Pierre (PIC) /JS Airimage, LLC Seeks Exemption From The Requirements Of Section91.7(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. Joseph St.Pierre (PIC) /JS Airimage, 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 level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

—

(1) Below 18,000 feet MSL, to-- (i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure. 4. Joseph St.Pierre (PIC) /JS Airimage, 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 following: (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. Joseph St.Pierre (PIC) /JS Airimage, LLC Seeks Exemption From The Requirement
Of Section 91.405(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. Joseph St.Pi erre JS Airimage, 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 level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating-- (1) Below 18,000 feet MSL, to-- (i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure. 4. Joseph St.Pi erre JS Airimage, 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 following: (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. Joseph St.Pierre JS Airimage, 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 that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.]6. Joseph St.Pierre (PIC) /JS Airimage, LLC Exemption From The Requirements Of Section91.407(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. Joseph St.Pierre (PIC) /JS Airimage, LLC Seeks Exemption From The Requirements Of Sections91.409(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. Joseph St.Pierre (PIC) /JS Airimage, LLC Exemption From The Requirements Of
Sections 91.417(a) 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 (2) 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

— (i) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of completion of the work performed; and (iii) The signature, and certificate number of the person approving the

aircraft for return to service.(2) Records containing the following information: (i) The total time in service of the airframe, each engine, each propeller, and

each rotor. (ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety 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 Joseph St.Pierre (PIC) /JS Airimage, LLC Seeks And The Reason Joseph St.Pierre (PIC) /JS Airimage, LLC Seeks

The Relief.

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command, is requested to the extent necessary to allow a PIC holding a private pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met certain flight-hour and currency requirements, to conduct the proposed UAS flight operations for compensation or hire.This relief is 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.

As set forth more fully below, Joseph St.Pierre (PIC) /JS Airimage, LLC submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the DJI Phantom 3 Professional UAS unless that PIC has met certain flight-hour and currency requirements, demonstrating that the PIC is able to safely operate either the DJI Phantom 3 Professional in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures. Further, Joseph St.Pierre (PIC) /JS Airimage, LLC submits that all flights of the DJI

Phantom 3 Professional UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to Joseph St.Pierre (PIC) /JS Airimage, LLC business; and (2) will not carry passengers or property for compensation or hire.

2. Extent Of Relief Joseph St.Pierre (PIC) /JS Airimage, LLC Seeks And The Reason Joseph St.Pierre (PIC) /JS Airimage, 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 Joseph St.Pierre (PIC) /JS Airimage, LLC to determine that the DJI Phantom 3 ProfessionalUAS is in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., the Joseph St.Pierre (PIC) /JS Airimage, LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Professional Instruction Manual) prior to every flight, and further, determine that the aircraft are in condition for safe flight,

as stated in the conditions and limitations below.3. Extent Of Relief Joseph St.Pierre (PIC) /JS Airimage, LLC Seeks And The Reason Joseph St.Pierre (PIC) /JS Airimage, LLC Seeks Relief From Section 91.121. Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the DJI Phantom 3 Professional UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), Joseph St.Pierre (PIC) /JS Airimage, LLC seeks the requested relief because the DJI Phantom 3 Professional UA’s altimeter may beset on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply with the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level of safety will be maintained since the DJI Phantom 3 Professional UA is equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the PIC with altitude information of the UA on the heads-up display of the GCS.

4. Extent Of Relief Joseph St.Pierre (PIC) /JS Airimage, LLC Seeks And The Reason 4. Extent Of Relief Joseph St.Pierre (PIC) /JS Airimage, LLC Seeks And The Reason Joseph St.Pierre (PIC) /JS Airimage, LLC Seeks Relief From Section 91.151(b). Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to allow flights of the battery powered DJI Phantom 3 Professional UA during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), 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. Joseph St.Pierre (PIC) /JS Airimage, LLC seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered DJI Phantom 3
Professional UAS will severely constrain the practicality of any aerial video or still photo flight operations that Joseph St.Pierre (PIC) /JS Airimage, LLC proposes to conduct pursuant to this Petition. Seeks Relief From Section 91.151(b). Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to allow flights of the battery powered DJI Phantom 3 Professional UA during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), 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.TABLE OF CONTENTS

Page

SUMMARY .........................................................................................................3

INTRODUCTION AND INTERESTS OF PETITIONER .................................................3

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

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

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

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH Joseph St.Pi erre JS Airimage, LLC
SEEKS EXEMPTION ...........................................................................................7

THE EXTENT OF RELIEF Joseph St.Pi erre JS Airimage, LLC SEEKS AND THE REASON Joseph St.Pierre JS Airimage, LLC SEEKS THE RELIEF ............................................1 0

THE REASONS WHY GRANTING Joseph St.Pi erre JS Airimage, LLC REQUEST WOULD
BE IN THE PUBLIC INTEREST .............................................................................1 4

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT
ADVERSELY AFFECT SAFETY.............................................................................1 6

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER .........................28

CONCLUSION ...................................................................................................30

APPENDICES....................................................................................... .............315. Extent Of Relief Joseph St.Pierre (PIC) /JS Airimage, LLC Seeks And The Reason Joseph St.Pierre (PIC) /JS Airimage, 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 with an airworthiness certificate, Joseph St.Pierre (PIC) /JS Airimage, LLC requests relief from these Sections because the DJI Phantom 3 Professional UAS do not require airworthiness certificates. As set forth more fully below, the DJI Phantom 3 Professional UAS meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, Joseph St.Pierre (PIC) /JS Airimage, LLC will use trained technicians to perform maintenance, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the Joseph St.Pierre (PIC) /JS Airimage, LLC Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual). Furthermore, Joseph St.Pierre (PIC) /JS Airimage,
LLC will document and maintain all maintenance records for the
DJI Phantom 3 UAS

.D. The Reasons Why Granting Joseph St.Pierre (PIC) /JS Airimage, 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 Joseph St.Pierre (PIC) /JS Airimage, LLC to safely, efficiently, and economically perform aerial video and photography of construction sites, real estate, and landscape over certain areas of the United States. Additionally, use of the DJI Phantom 3 Professional UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of Joseph St.Pierre (PIC) /JS Airimage, LLC proposed operation of the DJI Phantom 3 UAS will be realized without implicating any privacy

issues.

1. The Public Will Benefit From Decreased Congestion Of The NAS. The DJI Phantom 3 Professional and UA is 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 Phantom 3 Professional UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution,

as well as increase the safety of life and property in the air and on the ground. Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. TheDJI Phantom 3 Professional UA does not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handled by air traffic control during the ground,takeoff, departure, arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 3 Professional UAS.Conducting aerial acquisitions with the DJI Phantom 3 Professional 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 using battery power and electric motors, the DJI Phantom 3 ProfessionalUAS produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically utilized for aerial video and photography, while burning approximately 20-30 gallons per hour of leaded aviation fuel. The DJI Phantom 3 Professional UAS, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAS are propelled by battery powered electric motors, rather than an internal combustion engine.By using the DJI Phantom 3 Professional UAS to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI Phantom 3 Professional UA (weighing approximately 3 pounds 11 ounces,at their maximum gross weights with lengths of 16 inches, widths of 16 inches, and with no fuel on board), has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar 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).

3. Performing Aerial Video and Photography Operations With The DJI Phantom 3 Professional UAS Will Benefit The Economy. In addition to being safe and efficient, the DJI Phantom 3 Professional UAS are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom 3 Professional UAS will allow United States based companies, like Joseph St.Pierre (PIC) /JS Airimage, LLC, to remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery powered DJI Phantom 3 Professional UAS is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft.

By operating the DJI Phantom 3 Professional UAS, companies such as Joseph St.Pierre (PIC) /JS Airimage, 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 use of the DJI Phantom 3 Professional UAS, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the United States and abroad.4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for decades, Joseph St.Pierre JS Airimage, LLC proposed operation of the DJI Phantom 3 UAS will not implicate any privacy issues. Specifically, the DJI Phantom 3 Professional UAS will be operated only in compliance with operating documents (i.e., the Joseph St.Pierre (PIC) /JS Airimage, LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Professional Instruction Manual) which requires property owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which Kent H. Shore Seeks Exemption. 1. Reasons Why The DJI Phantom 3 Professional UAS 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, Joseph St.Pierre JS Airimage, LLC operation of the DJI Phantom 3 Professional 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 security. Specifically, FMRA Section 333 states the following, in part:

(a) In General.--Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the plan

and rule making 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 airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1).

(c) Requirements for Safe Operation.--If the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system.

In seeking this exemption, Joseph St.Pierre (PIC) /JS Airimage, LLC submits that the DJI Phantom 3 Professional UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI Phantom 3 Professional and DJI Inspire

1 UASs; (b) the pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The DJI Phantom 3 Professional 1 UAS
Demonstrate Its Safe Characteristics.

The DJI Phantom 3 Professional UAS do not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability.

i. Technical Specifications Of The DJI Phantom 3 UAS. The technical specifications of the DJI Phantom 3 Professional UAS are set forth by the DJI Phantom 3 Professional Specifications and Data Sheet, attached hereto as

Exhibit A.ii. The DJI Phantom 3 Professional UAS Autonomous Flight And Navigation Modes Enable The UASs To Remain Within A Defined Operational Area.

The DJI Phantom 3 Professional UAS may be operated in both manual and fully autonomous flight modes. A complete description of the flight and navigational modes of the DJI Phantom 3 Professional UAS is provided at pages 25-35 of the DJI Phantom 3 Professional User Manuals, attached hereto as Exhibit B.

iii. The DJI Phantom 3 Professional UAS Is Designed For Automatic
Return To Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation. When the Control Link is lost, the DJI Phantom 3 Professional UA will

remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 3 Professional UA do not reacquire control link data from the GCS, the UAS will assume that the Control Link is lost and the UAS will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown. A complete description of the Failsafe Functions of the DJI Phantom 3 Professional UAS are set forth at pages 27 through 29 of the DJI Phantom 3 Professional User Manuals, attached hereto as Exhibit B.

iv. The DJI Phantom 3 Professional GCS And Its Operation. A complete description of the operation and specifications of the DJI Phantom 3 Professional GCS and flight control software is provided at pages 32 through 43 of the

DJI Phantom 3 Professional User Manual. DJI Phantom 3 Professional User Manuals

are attached hereto as Exhibits B.

b. Flight Operations Of DJI Phantom 3 Professional UAS Are Limited To the Line Of Sight additionally, a safety observer will assist flight operations dictated by the assignment to secure the safety of persons and or structures on the ground.

c. Flights Of DJI Phantom 3 Professional UAS Will Be Conducted Pursuant To Specific Operating Limitations.In seeking this exemption, Joseph St.Pierre (PIC) /JS Airimage, LLC proposes to commercially operate DJI Phantom 3 Professional UAS for the special purpose of conducting aerial video and photography over certain areas of United States, pursuant to the following specific operating limitations:

1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: DJI Phantom 3 Professional Unmanned Aircraft Systems. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant.

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

3. The UAS may not be flown at an indicated airspeed exceeding 20 knots.

4. The UA must be operated at an altitude of no more than 2 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

.

6 . The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track 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 exemption, then the operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if questions arise regarding updates or revisions to the operating documents.7 . 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 Station must be included in the preflight inspection. All maintenance and alterations must be properly

documented in the aircraft records.

8 . Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraft records.

9 .The pre-flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents.

10 . The operator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements.

11 . The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature of the authorized person returning the
UAS to service.

12 . Each UASs operated under this exemption must comply with all manufacturer Safety Bulletins.

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

14 . The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator’s PICs are permitted under the terms of the exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience-building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. §

91.119.15 . UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized.

16 . The UA may not operate within 5 nautical miles of an airport reference point as denoted on a current FAA-published aeronautical chart unless a letter of 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.

17 . The UA may not operate within 5 nautical miles of an airport reference point as denoted on a current FAA-published aeronautical chart unless a letter of 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. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in accordance with the operating documents.

19 . The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents.

20 . 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 30 % battery power remaining.21 . The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requirements.

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

24 . The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

25 . The UA must remain clear and yield the right of way to all manned aviation operations and activities at all times.

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

27 . Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, and;c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a).

28 . 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.

29 . Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

.

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety.

Joseph St.Pierre (PIC) /JS Airimage, 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 Phantom 3 Professional UAS unless that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 Professional UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

Considering Joseph St.Pierre (PIC) /JS Airimage, LLC 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 Phantom 3 Professional UAS, Joseph St.Pierre (PIC) /JS Airimage, LLC submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary forJoseph St.Pierre (PIC) /JS Airimage, LLC specific proposed flight operations.The FAA has previously granted relief from Section 61.113(a) and (b) specific toUAS, 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).Joseph St.Pierre (PIC) /JS Airimage, LLC will not allow any PIC to operate the DJI Phantom 3 ProfessionalUAS unless that PIC has demonstrated, by meeting minimum flight-hour requirements or the DJI Phantom 3 Professional UAS training and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 Professional UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot operating the same make and model ofUAS 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).

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during Joseph St.Pierre JS Airimage, LLC proposed operations. TheAdministrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations
for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi-rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight-hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the petitioner’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience-building flights can also be conducted under the grant of exemption to accomplish the required flight time. During training, proficiency, and experience-building flights the PIC is required to operate the UA with appropriate
distances in accordance with 14 C.F.R 91.119.Exemption No. 11138 at page 15. Accordingly, Joseph St.Pierre (PIC) /JS Airimage, LLC will ensure safe operations by not allowing any PIC to operate the DJI Phantom 3 Professional UAS unless that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 Professional UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

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

The equivalent level of safety established by Section 91.7(a) will be maintained because prior to every flight, Joseph St.Pierre (PIC) /JS Airimage, LLC will ensure that the DJI Phantom 3Professional UAS is in an airworthy condition based upon the UAS’s compliance with its operating documents and as stated in the conditions and limitations herein.Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112,11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety. The equivalent level of safety established by Section

91.121 will be maintained because the altitude information of the DJI Phantom 3 Professional 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 Joseph St.Pierre (PIC) /JS Airimage, LLC operation of the DJI Phantom 3Professional UA within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation pointis automatically established by the UASs at ground level.

The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely Affect Safety.A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJI Phantom 3 Professional UAS; (2) the limitations on the proposed flight operations; and (3)the location of the proposed flight operations. Accordingly, Joseph St.Pierre (PIC) /JS Airimage, LLC will ensure that it will safely operate the battery powered DJI Phantom 3 Professional UA during daylight hours in VFR conditions, 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. Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 3 Professional UAS; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Phantom 3 Professional UAS provide audible and visual warnings to the PIC at the GCS when the

UAs experiences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery power. At the critically low battery level, the DJI Phantom 3 UAS will descend and land automatically. Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156,11157, 11158, 11159, 11160, 11161).

6. Reasons Why An Exemption From The Requirements Of Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety. In seeking this exemption, Joseph St.Pierre (PIC) /JS Airimage, 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 Joseph St.Pierre (PIC) /JS Airimage, LLC will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., the Joseph St.Pierre (PIC) /JS Airimage, LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Professional Instruction Manual). Furthermore, Joseph St.Pierre (PIC) /JS Airimage, LLC will document and maintain all
maintenance records for the DJI Phantom 3 Professional UAS.Since the DJI Phantom 3 Professional UAS will be inspected as prescribed by the operating documents, Joseph St.Pierre (PIC) /JS Airimage, LLC will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI Phantom 3 Professional User Manuals are attached hereto as Exhibit A and B; a copy of the DJI Phantom 3 Professional UAS Maintenance LOG is attached hereto as Exhibit C. Likewise, the exemption sought will not adversely affect safety because Joseph St.Pierre JS Airimage, LLC will use trained technicians to 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), because all maintenance of the DJI Phantom 3 Professional UAS will be performed by trained technicians.

Maintenance 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 Joseph St.Pierre (PIC) /JS Airimage, LLC proposed operating limitations, the operating documents, and the technical aspects of the DJI Phantom 3 Professional UASs, Joseph St.Pierre JS Airimage, 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, Joseph St.Pierre JS Airimage, LLC requests that the FAA prescribe special conditions for the intended operation of the DJI Phantom 3Professional UAS, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21,Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a),91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAs for the limited purpose of conducting aerial video and photography over certain areas of the United States for compensation or hire. FMRASection 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification in accordance with any requirements that must be established for the safe operation of the UAS in the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of the DJI Phantom 3 Professional UAS, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special Conditions, states the following: If the FAA finds that the airworthiness regulations of this subchapter do not contain 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 engine or propeller as the FAA finds necessary to establish a level of safety equivalent to that established in the regulations. See 14 C.F.R. § 21.16. Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for Leading Edge’s intended operation of the DJI Phantom 3 Professional UAS, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 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).

F. A Summary That Can Be Published In The Federal Register, stating: The Rules From Which Joseph St.Pi erre JS Airimage, LLC Seeks Exemption: Joseph St.Pierre JS Airimage, LLC seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a) (1) & (a)(2), and 91.417(a) & (b). A Brief Description Of The Nature Of The Exemption Joseph St.Pierre JS Airimage, LLC Seeks:This exemption will permit Joseph St.Pierre JS Airimage, LLC to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States

.G. Any Additional Information, Views, Or Arguments Available To Support Joseph St.Pierre (PIC) /JS Airimage, LLC 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, Joseph St.Pierre (PIC) /JS Airimage, LLC request for exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above.

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without

airworthiness certification. As discussed in detail above, Joseph St.Pierre (PIC) /JS Airimage, LLC will operate the DJI Phantom 3 Professional 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, Joseph St.Pierre (PIC) /JS Airimage, LLC seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI Phantom 3 Professional UAS commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography over certain areas of the United States. By granting this Petition, the FAAAdministrator will be fulfilling the Congressional mandate of the FAA Modernization andReform Act of 2012, while also advancing the interests of the public, by allowing Joseph St.Pierre (PIC) /JS Airimage, LLC to safely, efficiently, and economically operate
the DJI Phantom 3 Professional UAS commercially within the NAS. WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, Joseph St.Pierre (PIC) /JS Airimage, 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 Leading Edge to operate the DJI Phantom 3 Professional UAS commercially for the purpose of conducting aerial video and photography over certain areas of the United
States.

Dated: October 16, 2015 Submitted by, Joseph St.Pierre

Joseph St.Pierre (PIC) /JS Airimage, LLC
2 1/2 Beacon Street #125 Concord, NH 03301

603-731-1385Appendices: A – DJI Phantom 3 Professional Specifications Data Sheet

B – DJI Phantom 3 Professional Manufacturer’s User ManualAPPENDIX – A
DJI PHANTOM 3 PROFESSIONAL TECHNICAL SPECIFICATIONS Kent H Shore only utilizes safe and reliable UASs. DJI is an industry leader in small
UAS production. DJI UASs are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be

set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJI software provides real-time altitude and location information to the PIC via the linked monitor (smart phone/tablet devices)

1.1 DJI Phantom 3 Professional

1.1.1 Aircraft 1.1.1.1 Supported Battery – DJI 5200mAH LiPo Battery 1.1.1.2 Weight (Battery & Propellers Included) – 2.82lbs (1280g) 1.1.1.3 Hover Accuracy (Ready to Fly) – Vertical: .5m; Horizontal: 1.5m 1.1.1.4 Max Yaw Angular Velocity - 200 0 /s 1.1.1.5 Max Tilt Angel - 35 0 1.1.1.6 Max Ascent Speed – 5m/s 1.1.1.7 Max Descent Speed – 3m/s 1.1.1.8 Max Flight Speed – 16m/s (NOT RECOMMENDED)
1.1.2 Gimbal 1.1.2.1 Working Current – Static: 750mA; Dynamic: 900mA 1.1.2.2 Control Accuracy - ±0.03 0 1.1.2.3 Controllable Range – Pitch: -90 0 - 0 0 1.1.2.4 Maximum Angular Speed – Pitch: 90 0 /s
1.1.3 Camera 1.1.3.1 Operating Temperature Range - 32 0 F - 104 0 F (0 0 C - 40 0 C)
1.1.3.2 Sensor Size – 1/2.3”

1.1.3.3 Effective Pixels – 14M

1.1.3.4 Resolution – 4384x3288 4.1.3.5 HD Video Recording – 1080p30 & 720p 4.1.3.6 Recording Field of View - 110 0 /85 0

1.1.4 Transmitter 1.1.4.1 Operating Frequency – 5.728GHz – 5.85GHz 1.1.4.2 Communication Distance (unobstructed) – FCC Compliance: 800m 1.1.4.3 Receiver Sensitivity (1%PER) - -93dBm 1.1.4.4 Transmitter Power – FCC Compliance: 100mW 1.1.4.5 Working Voltage – 120mA@3.7V 1.1.5 Range Extender 1.1.5.1 Operating Frequency – 2412-2462MHz 1.1.5.2 Communication Distance (unobstructed) – 500-700m1.1.5.3 Transmitter Power – 20dBm 1.1.5.4 Power Consumption – 2W

APPENDIX – B
DJI Phantom 3 Professional Manufacturer’s User Manual

Attachment Provided as PDF