1 **SUMMARY** Travis Ploman, 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 Sy stem pursuant to Section 333 of th e FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Travis Ploman to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography , real estate photograph y, and landscape o ver certain areas of the United States.

**INTRODUCTION AND INTERESTS OF THE PETITIONER** Travis Ploman provides his c lients with the high quality digital content for use in the marketing and sale of their real estate

. Travis Ploman has recreational/hobby experience in all aspects of aerial video and photograph y. The objective of Travis Ploman ’s aerial video and photograph y operations is to provide high q uality imaging for:

 Real Estate Videograph y and Photograph y
 Construction sites before , during and after
**BACKGROUND** Unmanned Aircraft Sy stems: DJIPhantom 3 Advanced UASs Travis Ploman seeks an exemption to operate DJIs ys tems for compensation or hire within the NAS. The DJ I Phantom 3 Advanced is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic ta blet or smartphone s ys tems. The DJIPhantom 3 Advanced has a maximum gross weight o f 2.82 pounds , a length of 23.2 inches, width of 23.2 inches, height of 11.8 inches, and a maximum speed of approximately

31 knots. The DJ I Phantom 3 Advanced UA is equipped with four main rotors; driven b y Li thium P oly mer battery

powered electric motors. The DJI Phantom 3 Advanced UA that will be operated b y Travis Ploman , will be registered in accordance with 49 U.S.C. 44103, Registration ofAircraft , as well as 14 C.F.R Part 47, Aircraft Registration , and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking

.

**BASIS FOR PETITION** Petitioner, Travis Ploman , 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 , hereb y petitions the Administrator to commercially operate the DJ I Phantom 3 Advanced UAS in the National Airspace S ys tem (NAS) , and for an exemption from the requirem ents 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).2

In consideration of the speed, weight, size, and limi ted operating area associated with the unmanned aircraft and its operation, Travis Ploman ’s operation of DJ I Phantom 3 Advanced UAS meets the con ditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in ac cordance with 14 C.F.R. Part 21, Subpart H. Accordingl y, Travis Ploman requests relief from Se ctions 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 onl y a pply to aircraft with an airworthiness certificate. Travis Ploman submits that the requested relief is prop er since an equivalent level of safety will be ensured. Travis Ploman will use experienced pers onnel or technicians to perform maintenance, alteratio ns, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested by Travis Ploman to the extent necessary to allow a Pilot in Command (PI C) holding a private pilot or higher level certificate, as well as an airman medical certifi cate, and who has demonstrated, that the PI C is able to safel y operate the DJIPhantom 3 Advanced UAS in a manner consistent with this exemption, including evasive and emergency

maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Travis Ploman seeks relief from Section 91.7(a), enti tled Civil aircraft airworthiness , because the DJ I Phantom 3 Advanced UAS do es not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Travis Ploman will ensure that the DJ I Phantom 3 Advanced UAS is in airworthy condition, prior to every

flight, by determining that the UAS is in compliance with the operating docum ents and that the aircraft is in a condition for safe flight. Travis Ploman also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , as the DJIPhantom 3 Advanced UA will not have a typi cal barometric altimeter onboard. Howev er, altitude information of the DJ I Phantom 3 Advanced UA will be provided to the PI C via 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 Travis Ploman operation of the DJ I Phantom 3 Advanced UAS within visual line o f sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121. Additionally , Travis Ploman seeks an exemption from the requirements of Section 91.151(b ) entitled Fuel requirements for flight in VFR conditions

. Travis Ploman submits that safety will not be affected by operation of DJ I Phantom 3 Advanced UA during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fl y for a total duration of approximately 16 m inutes to the first point of intend ed landing and, assuming normal cruising speed, to fly after that for at least 4 minutes. In accordance with 14 C.F.R. § 11.81, Travis Ploman pro vides the following information in support of its petition for exemption:3

**A. Name and**  **Address Of The Petitioner.** The name and address of the Petitioner and point of contact is: Travis Ploman 1853 Sunny

Ct Kronenwetter, WI 54455 715

- 573

- 0337 travisploman@gmail.com **B. The Specific Sections Of 14 C.F.R. from Which Travis**  **Ploman Seeks Exemption.** 
**1. Travis Ploman**  **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 (PI C) of an aircraft that is carrying passenge rs or property for compensation or hire; nor may that person, for compensation or hire, act as PI C of an aircraft. (b) A private pilot may , for compensation or hire, act as PI C of an aircraft in connection with any business or employ

ment if

— (1) The flight is only

incidental to that business or employ ment; and (2) The aircraft does not carry passengers or property

for co mpensation or hire.
**2. Travis Ploman**  **Seeks Exemption From The Requirements Of Section 91.7(a).** Section 91.7, entitled civil aircraft airworthiness , subsection (a), states the following: (a) No person may

operate a civil aircraft unless it is in an airworth y condition.

**3. Travis Ploman**  **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

--4 (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 alti meter setting of an appropriate available station; or (iii) In the case of an aircraft not equipped wi th a radio, the elevation of the departure airport or an appropriate altimeter setting available before d eparture. **4. Travis Ploman**  **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, ass uming normal cruising speed, to fly after that for at least 20 minutes.
**5. Travis Ploman**  **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 thi s chapter[.]

**6. Travis Ploman**  **Seeks Exemption From The Requirements Of Section 91.407(a ) (**  **1)** Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration , subsection (a)(1), states the following: (a) No person may

operate any

aircraft that has undergone maintenance, preventive maintenance, reb uilding, or alteration unless

— (1) It has been approved for return to service b y a person authorized under §43 .7 of this chapter [ .]
**7. Travis Ploman**  **Seeks Exemption From The Requirements Of Sections 91.409(a)(1)**  **And 91.409(a)(2).** Section 91.409, entitled Inspections , subsection (a), states the following:5

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unles s, within the preceding 12 calendar months, it has had

-- (1) An annual inspection in accordance w ith part 43 of this chapter and has been approved for return to service b y a pers on 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. Travis Ploman**  **Seeks 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 alteration and records of the 100

- hour, annual, pro gressive, and other required or approved inspections, as appropriate, for each aircra ft (including the airframe) and each engine, propeller, rotor, and appliance o f 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.6 (iv) The current inspection status of the aircraft, including the time since the last inspection requir ed by the inspection program und er 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 b y § 43.9(d) of this chapter for each major alteration to the airframe and currentl y in stalled 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 b y other work or for 1 ye ar 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 regis tered 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 Travis Ploman**  **Seeks And The Reason Travis Ploman**  **Seeks The Relief.** 
**1. Extent Of Relief Travis Ploman**  **Seeks and the**  **Reason Travis Ploman**  **Seeks Relief From**  **Section 61.113(a) And (b)** Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command, is requested to the extent necessary to allow a PIC holding a private pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met certain flight

- hour and currency requirements, to conduct the p roposed UAS flight operations for compen sation 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 PI C of an aircraft in connection with any business or7

employ ment if: (1) The flight is on ly incidental to that business or employment; and (2) The aircraft does not carry passengers or property

for compensation or hire. As set forth more full y below, Travis Ploman submits that an equivalent level of safety will be maintained because no PI C wi ll be allowed to operate the DJ I Phantom 3 Advanced UAS unless that PI C has met certain flight

- hour and currency requirements, demonstrating that the PIC is ab le to safel y operate either the DJ I Phantom 3 Advanced UAS in a manner consistent with the operat ions specifications as described in this e xemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances fro m people, vessels, vehicles and structures. Further, Travis Ploman submits that all flights of the DJ I Phantom 3 Advanced UASs, conducted b y the PIC pursuant to the grant of this Petition: (1) will be incidental to Travis Ploman business; and (2) will not c arry passengers or property for compensation or hire.
**2. Extent Of Relief Travis Ploman**  **Seeks And The Reason Travis Ploman**  **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 Travis Ploman to determine that the DJ I Phantom 3 Advanced UASs are in airworthy

condition prior to ev ery flight b y ensuring that the UAS is in compliance with the operating documents. Travis Ploman seeks the requested relief because the DJ I Phantom 3 Advanced UAS does not require an airworthiness ce rtificate in accordance with 14 C.F.R. Part 2 1, Subpart H. Therefore, Travis Ploman will ens ure that the DJ I Phantom 3 Advanced UAS is in airworth y condition based upon its compliance with the operating documents prio r to every flight, and further, determine that the aircraft are in condition for saf e flight, as stated in the conditions and limitations below.
**3. Extent Of Relief Travis Ploman**  **Seeks And The Reason Travis Ploman**  **Seeks Relief From**  **Section 91.121** Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the DJ I Phantom 3 Advanced UAS, which utilize s a barometric pressure sen sor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PI C at the groun d control station (GCS). Sin ce the FAA requires that any altitude information concerning UAS operations be reported to ai r traffic control (ATC) in feet above ground level (AGL), Travis Ploman seeks the requested relief because the DJ I Phantom 3 Advanced 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 the8

proposed operations, relief from 14 CFR 91.121 is sought to the exte nt 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 DJ I Phantom 3 Advanced UA is equipped with a barometric pressure sensor and GPS equip ment, which automatically ensures that a ground level pressure setting will be establ ished 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 Travis Ploman**  **Seeks and the**  **R eason**  **Travis Ploman 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 DJ I Phantom 3 Advanced UA during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 16 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4 minutes. Travi s Ploman seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered DJ I Phantom 3 Advanced UAs will severel y constrain the practicality of any aerial video or still photo flight operations that Travis Ploman proposes to conduct pursuant to this Petition.

**5. Extent Of Relief Travis Ploman**  **Seeks And The Reason Travis Ploman**  **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) onl y apply to aircraft with an airworthiness certificate, Travis Ploman requests relief from these S ections because the DJ I Phantom 3 Advanced UAS do not require airworthiness certificates. As set forth more fully below, the DJI Phantom 3 Advanced UAS meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingl y, Travis Ploman will use trained technician s to perform maintenance, alterations, o r preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS operating documents Furthermore, Travis Ploman will document and maintain all maintenance rec ords for the DJ I Phantom 3 Advanced UASs. **D. The Reasons Why Granting Travis Ploman**  **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 b y allowing Travis Ploman to safely , efficientl y, and economically perform aerial video and photography for real estate, special events, and landscape over certain areas of the United States. Additionally , use of the DJ I Phantom 3 Advanced UAS will decrease congestion of the NAS, red uce pollution, and provide9

significant benefits to the econom y. Notabl y, the benefits of Travis Ploman propos ed operation of the DJ I Phantom 3 Advanced UAS will be realized without implicating any privacy issues.
**1. The Public Will Benefit From Decreased Congestion Of The NAS.**  The DJ I Phantom 3 Advanced UA are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilize d to obtain aerial imagery . By

reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJIPhantom 3 Advanced 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, b y reducing the number of manned aircraft operating in the NAS, congestion around airports caused b y arriving and departing aircraft will be reduced. The DJ I Phantom 3 Advanced UA does not require an airport to takeoff or land. Likewise, a reduction of manned aircr aft conducting aerial video and photograph y 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 Advanced UAS** 
**.** Conducti ng aerial acquisitions with the DJIPhantom 3 Advanced UAS , instead of manned aircraft, will greatly benefit the public by drasticall y reducing the levels of air and noise pollution generated during traditional ae rial video and still photography flight operations. By

using battery

pow er and electric motors, DJIPhantom 3 Advanced UAS produ ce no air pollution, and is the most viable environmentally conscious alternative to the cabin clas s, six cylinder internal combustion engine aircraft that are typ ically utilized fo r aerial video and photograph y, while burning approximately 20

- 30 gallons per hour o f leaded aviation fuel. The DJIPhantom 3 Advanced UA , while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UA is propelled b y battery powered electric motors, rather than an internal combustion engine. By using DJ I Phantom 3 Advanced UAS t o perform aerial acquisitions , the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned airc raft flight operations, will be substantially re duced or completely

eliminated. Aside from the la ck of flight crew members loc ate d onboard the aircraft, the DJ I Phantom 3 Advanced UA (wei ghing 2.82 respectivel y, at maximum gross weight with length of 23.2 inches respectivel y, width of 23.2 inches respectively , and w ith no fuel on board), has less phy sical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typicall y conduc t similar operations (weighing approximately

6,000 pounds with a wingspan of approximatel y 42 feet, a length of 34 feet, and a fuel capacity

o f 180 gallons). **3. Performing Aerial Video and Photography Operations With The**  **DJI Phantom 3 Advanced UASs Will Benefit**  **the Economy.**  In addition to being safe and efficient, the DJ I Phantom 3 Advanced UAS are also an economical alternative to u sing manned aircraft to conduct similar aerial operations. As such, operation of DJ I Phantom 3 Advanced UAS will allow United States based10

companies, like Travis Ploman , to remain competitive and contribute to growth of the U.S. economy . Specifically , with the rising cost of aviation fuel and the Environmental Prote ction Agency

(“EPA”) regulatory

actions phasing out leaded aviation fuels, U.S. owned and operat ed companies must adopt new and alternative technology in order to remain competitive. Op erating th e battery powered DJIPhantom 3 Advanced UAS is on e such technology

that not only allows companies greater operational flexibility compared t o manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft

. By operating the DJ I Phantom 3 Advanced UAS, companies such as Travis Ploman , can remain competitive and pro fitable, and therefore, provide greater job stability

to employees and contractors, whic h will ultimately contribute to growth of the U.S. economy . Improved financial perform ance of U.S. companies, through commercial use of the DJ I Phantom 3 Advanced UAS, provides a stable workforce th at increases consumer spending; improve s local, state, and federal tax revenues; and allows compani es 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, Travis Ploman , proposed operation of the DJ I Phantom 3 Advanced UASs will not implicate any

privacy issues. Speci ficall y, the DJIPhantom 3 Advanced UASs will be operated on ly

in compliance with operating documents which requires property owner involvement and in accord ance 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**  **Travis Ploman Seeks Exemption.**  **1. Reasons Why DJI Phantom 3 Advanced**  **UA Meet The Conditions Of The FAA**  **Modernization and Reform Act of 2012 (FMRA) Section 333.**  In consideration of the size, weight, speed, and li mited operating area associate with the unmanned aircraft and its operation, Travis Ploman operation of the DJ I Phantom 3 Advanced UAS meet the condition s 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 t o 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. In seeking this exemption, Travis Ploman submits that the DJ I Phantom 3 Advanced UAS can operate safel y i n the NAS p ursuant to FMRA Section 333, as demonstrated by : (a) the characteristics of the DJ I Phantom 3 Advanced UAS; (b) the pilot certification requirement; and (c) the specific operating limitations.11 **a. The Specifications Of The DJI Phantom 3 Advanced**  **UAS Demonstrate Its**  **Safe Characteristics.** The DJ I Phantom 3 Advanced UAS do es 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 Advanced**  **UAS**
**.** The technical specifications of the DJ I Phantom 3 Advanced UAS are set forth by the DJ I Phantom 3 Advanced user manual , attached hereto as Exhibit A

. **ii. The DJI Phantom 3 Advanced**  **UAS A**  **utonomous Flight And Navigation Modes Enable The UAS To**  **Remain Within A Defined Operational Area.**  The DJ I Phantom 3 Advanced UAS may be operated in both manual and fully autonomous flight modes. A complet e description of the flight and navigational modes of the DJ I Phantom 3 Advanced UAS is provided at page 11 of the DJ I Phantom 3 Advanced User Manuals, attached hereto as Exhibit A

. **iii. The DJI Phantom 3 Advanced**  **UAS Are Designed For Automatic**  **Retur n To Home Point Or Hover In The**  **Event Of Loss Of The Control Link Or Navigation.**  When the Control L ink is lost, the DJIPhantom 3 AdvancedUA will remain stationary , in flight, for 3 seconds or more. If, after 3 seconds, the DJIPhantom 3 Advanced UAs do not reacquire control link data from the GCS, the UAs will assume that the Control L ink is lost and the UAs will return to the home position ( i.e., failsafe mode) via GPS, and will desc end to the takeoff position and shutdown. A complete description of the Failsafe Functions of the DJIPhantom 3 Advanced at pages 12 through 14 of the DJ I Phantom 3 Advanced User Manuals, attached hereto as Exhibi t A

. **iv. DJI Phantom 3 Advanced**  **GCS And Its Operation.**  A complete description of the operation and specifications of the DJ I Phantom 3 Advanced GCS and flight control software is pro vided at pages 34 throu gh 47 of the DJ I Phantom 3 Advanced User Manual. DJ I Phantom 3 Advanced User Manuals are attached hereto as Exhibit A

.12 **b. Flight Operations of**  **DJI Phantom 3 Advanced UAS**  **Are Limited to**  **the Line Of S**  **ight of**  **A Certificated Pilot in Command**  **with A Safety Observer.**  Travis Ploman will only

utilize certificated pilots who possess a current and valid airman medical certificate to act as a pilot in command (PI C) of the DJ I Phantom 3 Advanced UAS . Additionally , a safety observer will assist all pilots during flight time. **c. Flights o**  **f DJI Phantom 3 Advanced**  **UASs Will Be Conducted Pursuant To**  **Specific Operating Limitations.** In seeking this exemption, Travis Ploman p roposes to commerciall y operate DJ I Phantom 3 Advanced UAS for the speci al purpose of conducting aerial video and ph otograph y over certain areas of United St ates, pursuant to the following specific operating limitations: 1. Operations authorized by this grant of exemption w ill be limited to the following aircraft described in the operating documents , rotorcraft UASs we ighing less than 55 pounds maximum gross weight: DJ I Phantom 3 Advanced Unmanned Aircraft Sy stem . Proposed o perations of an y other aircraft will require a new petition or a petition to amend this grant. 2. UAS operations under this exemption will be l imited to conducting operations for the purpose of aerial video and photography. 3. The UAS may

not be flown at an indicated airspeed exceeding 50 knots. 4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL), as indi cated by the proced

ures specified in the operating documents unless a special request is made and approved b y 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 PI C at all times. T his requires the PIC to be able to use human vision unaided by an y device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate. 6. The use of first person view (FPV) b y the PI C 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 PI C alway s maintains VLOS capability

. The SO and PIC must be able to communicate verbally at all times. Electronic messaging or t exting is not permitted during fli ght operations. The PI C must be designated before the flight and cannot transfer his or her designation for13 the duration of the flight. The PI C must ensure that the SO can perform the functions prescribed in the operating documents. 8. The SO must not perform any other duties beyon d assisting the PI C with seeing and avoiding other air traffic and other ground b ased obstacles/obstructions 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 request. If a discrepancy exists between the conditions and limitations c ontained in the grant of exemption and the procedures outlin ed in the operating documents, the conditions and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, the operato r must follow the procedures as outlined in its operating documents. The op erator may update or revise its operating documents. It is the operator’s respons ibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revise d 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 b asis upon which the FAA granted the exemption, then the operator must petition fo r amendment to its grant of exemption . The FAA’s UAS Integration Offi ce (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operating documents. 10. Prior to each flight the PI C must inspect th e UAS to ensure that it is in a condition for safe flight. If the in spection reveals a condition that affects the safe operation of the UAS, the aircraft is proh ibited 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 properl y documented in the aircraft records. 11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacem ent of a flight critical component, must undergo a functional test f light. The PI C who conducts the functional test flight must make an entry in the aircraft records. 12. The pre

- flight inspection must account for all pot ential discrepancies, e.g. inopera ble components, items, or equipm ent, not already covered in the relevant sections of the operating documents. 13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul; replacement, inspection, and life limit requirements. 14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the op erating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must14 be noted in the aircraft records, including tot al time in service, description of work accomplished, and the signature of the authorized 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 aircraft record of the corrective action taken against discrepancies discovered between inspections. 17. The PI C must possess at least a private pilot certificate and at lea st a current third

- class medi cal certificate. 18. The operator may

not permit any

PIC to o perate unless the PI C meets the operator’s qualification criteria and demonstrate s the ability to safel y operate the UAS in a manner consistent with how the UAS will be operated under the exempt ion, including evasive and emer gency maneuvers and maintaining appropriate distances from persons, vessel s, vehicles and structures. PIC qualification flight hours must be logged in a m anner 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. H owever, training operations may onl y be conducted during dedicated trai ning sessions. During training, proficiency , and experience

- building flights, all p ersons not essential fo r flight operations are considered nonparticipants, and the PI C 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. A ll operations must be conducted under v isual meteorological conditions (VMC). If flight at night is required, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized. 20. The UA may

not operate within 5 nautical miles o f an airport reference point as denoted on a current FAA

- published aerona utical 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 manag ement must be made available to the Administrator upon request. 21. The UA may

not be operated less than 500 feet below o r less than 2,00 0 feet horizontally

from a cloud or when visibility is les s than 3 statute miles from the PI C. 22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in accordance with the operating documents.15 23. The PI C must abort the flight in the ev ent of unpredicted obstacles or emergencies in accordance with the operating documents. 24. The PI C is prohibited from beginning a flight unless (con s idering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and lan d the UA with 25% battery power remaining.

25 . All aircraft operated in accordance with the exemption mus t be identif ied by serial number, registered in accordance w ith 14 C.F.R. part 47, and have identification (N

- Number) markings in acc ordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable.

26 . 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 document s must be made available to the Administrator or an y law enforcement official upon request. 27 . The UA must remain clear an d yield the right o f way to all manned aviation operations and activities at all times.
28 . The UAS may

not be operated b y the PIC from any moving device or vehicle.
29 . Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than the PI C, SO, operator trainees or essential persons), vessels, vehicles, and structures unless: a. Barriers or structures are present that suffic iently protect nonparticipating persons from the UA and/or debris i n the event of an accident. The operator must ensure that nonparticip ating persons remain under such protection. If a situation arises where nonp articipating persons leave such protection and are wi thin 500 feet of the UA, flight operations must cease imme diately and/or; b. The aircraft is operated near vessels, v ehicles or structures where the owner/controller of such vessels, veh icles or structures has granted permission and the PI C has made a s afety assessment of the risk of operating closer to those ob jects and determined that it does not p resent an undue hazard, and; c. Operations nearer to the PI C, SO, operato r trainees or essential persons do not present an undue hazard to those persons per § 91.119(a). 32. All operations shall be conducted over pri vat e or controlled

- access property with permission from the land owner/controller or authorized representative. Permission from land16 owner/controller or authorized representative will be obtained for each flight to be conducted.
30 . Any incident, accident , or flight operation that transgresses the lateral or vertical boundaries of the operational area a s 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 Natio nal Tr ansportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

.

**2 . 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, Travis Ploman requests that the FAA prescribe special conditions for the intended operation of the DJ I Phantom 3 Advanced UAS , which contain such safety standards that the Administrator finds necess ary to establish a level of safety equivalent to that es tablished 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 wi ll permit safe operation of the UAs for the limited purpose of conducting aerial video and photograph y over certain areas of the United States for compensation or hire. FMRA Section 333 sets forth the requirements for considering whe ther 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 with out airworthiness certification in accordance with any requirements that mus t be establishe d 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 DJ I Phantom 3 Advanced 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 Co nditions, states the following: If the FAA finds that the airworthiness regulations of this subcha

pter 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 amen dments thereto for the product. The special conditions are issued in accordance w ith Part 11 of this chapter and contain such safety s tandards for the aircraft, airc raft engine or propeller as the FAA finds necessary

to establish a level of safety equivalent to that esta blished 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 Travis Ploman intended operation of the DJ I Phantom 3 Advanced UAS , which contain such s afety st andards that the Administrator finds necessary to establish a lev el 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).17

**F. A Summary That Can Be Published In The Federal Register, stating: The Rules From Which**  **Travis Ploman Seeks Exemption:**  Travis Ploman 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 Travis Ploman**  **Seeks:** This exemption will permit Travis Ploman to commercially operate an Unmanned Aircraft System (UAS) for the pur pose of conducting aerial video and photography over certain areas of the United States. **G. Any Additional Information, Views, or**  **Arguments Available To Support Travis Ploman**  **Request.** This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transpo rtation to determine if certain UAS may operate safel y in the NAS. As such, Travis Ploman 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 othe rwise pose a threat t o national security ; and further, provides the authority for such UAS to operate without airworthines s certification. As discussed in detail above, Travis Ploman will operate the DJI Phantom 3 Advanced UAS safel y in the NAS, without creating a hazard to us ers of the NAS, or the public, or otherwise pose a threat to national security. **CONCLUSION** As set forth herein, Travis Ploman 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 DJ I Phantom 3 Advanced UAS commercially , without an airworthiness certificate, for th e limited purpose of conducting aerial video and photography over certain areas of the United States. By

grant ing this Petition, the FAA Administrator will be fulfilling the Congressional mandate of th e FAA Modernization and Reform Act of 2012, while also advanci ng the interests of the public, by allowing Travis Ploman to safel y, efficientl y, and economicall y oper ate the DJIPhantom 3 Advanced UASs commerciall y within the NAS.
**WHEREFORE** , in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, Travis Ploman 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 Travis Ploman to operate the DJ I Phantom 3 Advanced18

UAS commerciall y for the purpose of conducting aerial video and photography over certain areas of the United States. Dated: 7/9/15 Travis Ploman

_________________________ Travis Ploman 1853 Sunny

Court Kronenwetter, WI 54455 715

- 573

- 0337 Appendices:
A

- DJ I Phantom 3 Advanced Manufacturer’s User Manual DJIPhantom 3 Advanced Manual web address http://download.dji

innovations.com/downloads /phantom_3/en/Phantom_3_Advanced_User_Manual_v1.2_en.pdf