UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, D.C.

Regulatory Docket No. ____________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

7202 Ventures, 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 2, DJI PHANTOM 3 AND DJI INSPIRE 1

UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112­95)

Submitted on November 17, 2015

7202 Ventures, LLC

7202 Scenic Oaks Cir

Austin, TX 78745

Tel: 512­524­9739

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TABLE OF CONTENTS

GLOSSARY OF ABBREVIATIONS 3

SUMMARY 4

INTRODUCTION AND INTERESTS OF THE

PETITIONER/BACKGROUND

4

BASIS FOR PETITION 5

A. Name And Address Of The Petitioner. 7

B. The Specific Sections Of 14 C.F.R. from Which D 7202

Ventures Seeks Exemption.

7

C. The Extent Of Relief 7202 Ventures Seeks And The Reason

7202 Ventures Seeks The Relief.

10

D. The Reasons Why Granting 7202 Ventures Request Would

Be In The Public Interest;

13

E. The Reasons Why Granting The Exemption Would Not

Adversely Affect Safety

15

F. A Summary That Can Be Published In The Federal Register 28

G. Any Additional Information, Views, Or Arguments

Available To Support 7202 Ventures Request.

28

CONCLUSION 28

2
GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

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

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing

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SUMMARY

7202 Ventures, 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 7202 Ventures,

LLC to operate an Unmanned Aircraft System (UAS) for the commercial purpose of

conducting aerial video and photography for wedding videography, real estate

photography, special events, film sets, and landscape over certain areas of the Unites States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

7202 Ventures, LLC (hereinafter referred to as “7202 Ventures”) provides its clients with

expertise and knowledge in advanced technologies and solutions to increase efficiency,

productivity and effectiveness. 7202 Ventures also provides its clients with the highest

quality digital content for use in their commercial, personal, and non-profit multimedia

projects. 7202 Ventures has professional experience in wedding and special event

videography and photography and is recognized as an expert this field. 7202 Ventures has

recreational/hobby experience in all aspects of aerial video and photography. The objective

of 7202 Ventures aerial video and photography operations is to provide high quality

imaging for a variety of wedding, commercial, public, and residential uses, specifically

targeting:

• Wedding Videography and Photography

• Motion Picture Filming

• Real Estate Videography and Photography

• Construction sites before and after

• Search and Rescue operations

• Increase public knowledge of UAS and promote safe UAS operations.

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 2, DJI Phantom 3, DJI Inspire 1 UASs

7202 Ventures seeks an exemption to operate DJI systems for compensation or hire within

the NAS. The DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 are vertical takeoff and

landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing

electronic tablet or smart phone systems. The DJI Phantom 2, DJI Phantom 3 has a

4
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 Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of

17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of

approximately 42 knots. The DJI Phantom 2, DJI Phantom 3, and DJI Inspire 1 UASs are

equipped with four main rotors; driven by Lithium Polymer battery powered electric

motors. The DJI Phantom 2, DJI Phantom 3, and DJI Inspire 1 UASs that will be operated by

7202 Ventures, LLC will be registered in accordance with 49 U.S.C. 44103, Registration of

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

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

BASIS FOR PETITION

Petitioner, 7202 Ventures, 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 2, DJI Phantom 3, DJI Inspire 1

UASs in the National Airspace System (NAS), and for an exemption from the requirements

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

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

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

unmanned aircraft and its operation, 7202 Ventures operation of DJI Phantom 2, DJI

Phantom 3, and DJI Inspire 1 UASs 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, 7202 Ventures 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.

7202 Ventures submits that the requested relief is proper since an equivalent level of

safety will be ensured. 7202 Ventures will use experienced personnel or technicians to

perform maintenance, alterations, or preventive maintenance on the UASs using the

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

Maintenance Log, and DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 Instruction Manual).

Furthermore, 7202 Ventures will document and maintain all maintenance records for the

DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs.

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

privileges and limitations: Pilot in command, is requested by 7202 Ventures to the extent

necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level

certificate, as well as an airman medical certificate, and who has demonstrated, by meeting

minimum flight- hour and currency requirements, that the PIC is able to safely operate the

DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs in a manner consistent with this

exemption, including evasive and emergency maneuvers and maintaining appropriate

distances from people, vessels, vehicles and structures.

7202 Ventures seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness,

because the DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs do not require an

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, 7202

Ventures submits that he will ensure that the DJI Phantom 2, DJI Phantom 3 and DJI Inspire

1UASs are 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 2, DJI Phantom 3, and DJI Inspire 1 Instruction Manual), and that the aircraft are

in a condition for safe flight.

7202 Ventures also seeks an exemption from the requirements of Section 91.121, entitled

Altimeter Settings, as the DJI Phantom 2, DJI Phantom 3, and DJI Inspire 1 UAS will not have

a typical barometric altimeter onboard. However, altitude information of the DJI Phantom

2, DJI Phantom 3 and DJI Inspire 1UASs 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 7202 Ventures operation of the DJI Phantom 2, DJI Phantom 3 and DJI

Inspire 1 UASs within visual line of sight, at or below 500 feet AGL, will ensure a level of

safety equivalent to Section 91.121.

Additionally, 7202 Ventures seeks an exemption from the requirements of Section

91.151(b), entitled Fuel requirements for flight in VFR conditions. 7202 Ventures submits

that safety will not be affected by operation of the DJI Phantom 2, DJI Phantom 3 and DJI

Inspire 1 UASs 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 to the first point of intended landing and, assuming normal

cruising speed, to fly after that for at least 4.5 minutes.

In accordance with 14 C.F.R. § 11.81, 7202 Ventures provides the following information in

support of its petition for exemption:

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A. Name And Address Of The Petitioner.

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

7202 Ventures, LLC

7202 Scenic Oaks Cir

Austin, TX 78745

Tel: (512) 524-9739

Email: texasdrones@gmail.com

B. The Specific Sections Of 14 C.F.R. from Which 7202 Ventures Seeks

Exemption.

1. 7202 Ventures 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. 7202 Ventures Seeks Exemption From The Requirements Of Section 91.7(a).

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

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

3. 7202 Ventures Seeks Exemption From The Requirements Of Section 91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part:

7
(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. 7202 Ventures 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. 7202 Ventures 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. 7202 Ventures Seeks Exemption From The Requirements Of Section 91.407(a)(1)

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

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

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

maintenance, rebuilding, or alteration unless--

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

§43.7 of this chapter[.]

8
7. 7202 Ventures 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:

(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. 7202 Ventures 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, 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.

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(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 7202 Ventures Seeks And The Reason 7202

Ventures Seeks The Relief.

1. Extent Of Relief 7202 Ventures Seeks And The Reason 7202 Ventures 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 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

10
employment; and (2) The aircraft does not carry passengers or property for compensation

or hire.

As set forth more fully below, 7202 Ventures submits that an equivalent level of safety will

be maintained because no PIC will be allowed to operate the DJI Phantom 2 UAS or DJI

Phantom 3 UAS or DJI Inspire 1 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 2 or DJI Phantom 3 or DJI Inspire 1 UAS 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, 7202 Ventures submits that all flights of the DJI Phantom 2, DJI Phantom 3 and, DJI

Inspire 1 UASs, conducted by the PIC pursuant to the grant of this Petition: (1) will be

incidental to 7202 Ventures business; and (2) will not carry passengers or property for

compensation or hire.

2. Extent Of Relief 7202 Ventures Seeks And The Reason 7202 Ventures 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 7202 Ventures to determine that the DJI Phantom 2, DJI Phantom 3 and

DJI Inspire 1 UASs are in airworthy condition prior to every flight by ensuring that the UAS

is in compliance with the operating documents (i.e., the 7202 Ventures Aerial Operations

Manual, Monthly Maintenance Log, and DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1

Instruction Manual).

7202 Ventures seeks the requested relief because the DJI Phantom 2, DJI Phantom 3, and

DJI Inspire 1 UASs do not require an airworthiness certificate in accordance with 14 C.F.R.

Part 21, Subpart H. Therefore, 7202 Ventures will ensure that the DJI Phantom 2, DJI

Phantom 3 and DJI Inspire 1 UASs are in airworthy condition based upon its compliance

with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2, DJI

Phantom 3 and DJI Inspire 1 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 7202 Ventures Seeks And The Reason 7202 Ventures Seeks Relief

From Section 91.121.

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Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight

operations of the DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs, which utilize a

barometric pressure sensor, GPS equipment, and a radio communications telemetry data

link to downlink altitude information from the UA to the PIC at the ground control station

(GCS). Since the FAA requires that any altitude information concerning UAS operations be

reported to air traffic control (ATC) in feet above ground level (AGL), 7202 Ventures seeks

the requested relief because the DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UA’s

altimeter may be set on the ground to zero feet AGL, rather than the local barometric

pressure or field altitude, before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is

sought to the extent necessary to comply 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 2, DJI Phantom 3 and DJI Inspire 1 UASs are equipped with a

barometric pressure sensor and GPS equipment, which automatically ensures that a

ground level pressure setting will be established prior to each flight, and provides the PIC

with altitude information of the UA on the heads-up display of the GCS.

4. Extent Of Relief 7202 Ventures Seeks And The Reason 7202 Ventures 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 2, DJI

Phantom 3 and DJI Inspire 1 UASs 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. 7202 Ventures seeks the requested relief because without an exemption

from Section 91.151(b), the flight time duration of the battery powered DJI Phantom 2, DJI

Phantom 3 and DJI Inspire 1 UASs will severely constrain the practicality of any aerial

video or still photo flight operations that 7202 Ventures proposes to conduct pursuant to

this Petition.

Significantly, as set forth below, the technical specifications of the DJI Phantom 2, DJI

Phantom 3 and DJI Inspire 1 UASs, the DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1

operating documents, and 7202 Ventures proposed operating limitations, ensure that 7202

Ventures will safely operate the battery powered DJI Phantom 2, DJI Phantom 3 and DJI

Inspire 1 UASs during daylight hours in visual meteorological conditions (VMC), under

visual flight rules (VFR), with enough battery power to fly for a total duration of 13.5

12
minutes to the first point of intended landing and, assuming normal cruising speed, to fly

after that for at least 4.5 minutes.

5. Extent Of Relief 7202 Ventures Seeks And The Reason 7202 Ventures 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, 7202 Ventures requests relief from these

Sections because the DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs do not require

airworthiness certificates. As set forth more fully below, the DJI Phantom 2, DJI Phantom 3

and DJI Inspire 1 UASs meet the conditions of FMRA Section 333 for operation without an

airworthiness certificate. Accordingly, 7202 Ventures will use trained technicians to

perform maintenance, alterations, or preventive maintenance on the UASs using the

methods, techniques, and practices prescribed in the UAS operating documents (i.e., the

7202 Ventures Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2,

DJI Phantom 3 and DJI Inspire 1 Instruction Manual). Furthermore, 7202 Ventures will

document and maintain all maintenance records for the DJI Phantom 2, DJI Phantom 3 and

DJI Inspire 1 UASs.

D. The Reasons Why Granting 7202 Ventures Request Would Be In The

Public Interest

Granting the present Petition will further the public interest by allowing 7202 Ventures to

safely, efficiently, and economically perform aerial video and photography for wedding

films, real estate, special events, film sets, and landscape over certain areas of the United

States.

Additionally, use of the DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs will decrease

congestion of the NAS, reduce pollution, and provide significant benefits to the economy.

Notably, the benefits of 7202 Ventures proposed operation of the DJI Phantom 2, DJI

Phantom 3 and DJI Inspire 1 UASs will be realized without implicating any privacy issues.

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

The DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs are battery powered and serve

as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized

to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform

13
aerial acquisitions, an exemption allowing the use of a DJI Phantom 2, DJI Phantom 3 or DJI

Inspire 1 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. The DJI Phantom

2, DJI Phantom 3 and DJI Inspire 1 UAs do not require an airport to takeoff or land.

Likewise, a reduction of manned aircraft conducting aerial video and photography missions

would result in fewer aircraft that must be handled by air traffic control 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 2, DJI

Phantom 3 and DJI Inspire 1 UASs.

Conducting aerial acquisitions with the DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1

UASs, instead of manned aircraft, will greatly benefit the public by drastically reducing the

levels of air and noise pollution generated during traditional aerial video and still

photography flight operations. By using battery power and electric motors, the DJI

Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs 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 2, DJI Phantom 3 and DJI Inspire 1 UASs, while reducing the carbon footprint of

aerial acquisitions, also eliminates noise pollution, as the UASs are propelled by battery

powered electric motors, rather than an internal combustion engine.

By using the DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs 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 2, DJI Phantom 3 and DJI Inspire 1 UASs (weighing

approximately 2 pounds 11 ounces and 6 pounds 7.5 ounces respectively, at their

maximum gross weights with lengths of 16 inches and 17.3 inches respectively, widths of

16 inches and 17.7 inches respectively, 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).

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3. Performing Aerial Video and Photography Operations With The DJI Phantom 2, DJI

Phantom 3 and DJI Inspire 1 UASs Will Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1

UASs are also an economical alternative to using manned aircraft to conduct similar aerial

operations. As such, operation of the DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs

will allow United States based companies, like 7202 Ventures, 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 2,

DJI Phantom 3 and DJI Inspire 1 UASs 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 2, DJI Phantom 3 and DJI Inspire 1 UASs, companies such as

7202 Ventures, 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 2, DJI Phantom 3 and DJI Inspire 1 UASs, 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, 7202 Ventures, LLC proposed operation of the DJI Phantom 2, DJI Phantom 3 and

DJI Inspire 1 UASs will not implicate any privacy issues. Specifically, the DJI Phantom 2, DJI

Phantom 3 and DJI Inspire 1 UASs will be operated only in compliance with operating

documents (i.e., the 7202 Ventures, LLC Aerial Operations Manual, Monthly Maintenance

Log, and DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 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.

15
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 7202 Ventures Seeks Exemption.

1. Reasons Why The DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs 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, 7202 Ventures operation of the DJI Phantom 2, DJI

Phantom 3 and DJI Inspire 1 UASs 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 rulemaking

required by section 332 of this Act or the guidance required by section 334 of this

Act.

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under

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

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

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

areas, and operation within visual line of sight do not create a hazard to users

of the national airspace system or the public or pose a threat to national

security; and

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

airworthiness certification under section 44704 of title 49, United States

Code, is required for the operation of unmanned aircraft systems identified

under paragraph (1).

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(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, 7202 Ventures submits that the DJI Phantom 2, DJI Phantom 3

and DJI Inspire 1 UASs can operate safely in the NAS pursuant to FMRA Section 333, as

demonstrated by: (a) the characteristics of the DJI Phantom 2, DJI Phantom 3 and DJI

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

limitations.

a. The Specifications Of The DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1

UASs Demonstrate Its Safe Characteristics.

The DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs 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 2, DJI Phantom 3 and DJI

Inspire 1 UASs.

The technical specifications of the DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs are

set forth by the DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 Specifications and Data

Sheet, attached hereto as Appendix A, B and C.

ii. The DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs Autonomous

Flight And Navigation Modes Enable The UASs To Remain Within A Defined

Operational Area.

The DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs may be operated in both manual

and fully autonomous flight modes. A complete description of the flight and navigational

modes of the DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs is provided at pages

25-35 of the DJI Phantom 2 and pages 12-16 and 45-50 of the DJI Inspire 1 User Manuals,

attached hereto as Exhibit D and E.

iii. The DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs Are Designed For

Automatic Return To Home Point Or Hover In The Event Of Loss Of The

Control Link Or Navigation.

17
When the Control Link is lost, the DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs will

remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 2, DJI

Phantom 3 and DJI Inspire 1 UAs do not reacquire control link data from the GCS, the UAs

will assume that the Control Link is lost and the UAs will return to the home position (i.e.,

failsafe mode) via GPS, and will descend to the takeoff position and shutdown.

A complete description of the Failsafe Functions of the DJI Phantom 2 UAS are set forth at

pages 27 through 29 and for the DJI Inspire 1 at pages 13 through 15 of the DJI Phantom 2

and DJI Inspire 1 User Manuals, attached hereto as Exhibit D and E.

iv. The DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 GCS And Its Operation.

A complete description of the operation and specifications of the DJI Phantom 2 and DJI

Inspire 1 GCS and flight control software is provided at pages 32 through 43 of the DJI

Phantom 2 User Manual and pages 40 through 47 of the DJI Inspire 1 User Manual. DJI

Phantom 2 and DJI Inspire 1 User Manuals are attached hereto as Exhibits D and E.

b. Flight Operations Of DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1UASs Are

Limited To The Line Of Sight Of A Certificated Pilot inCommand With A Safety

Observer​.

7202 Ventures will only utilize certificated pilots who possess a current and valid airman

medical certificate to act as a pilot in command (PIC) of the DJI Phantom 2, DJI Phantom 3

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

time.

c. Flights Of DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs Will Be Conducted

Pursuant To Specific Operating Limitations.

In seeking this exemption, 7202 Ventures proposes to commercially operate DJI Phantom

2, DJI Phantom 3 and DJI Inspire 1 UASs 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 2, DJI Phantom 3 and DJI Inspire 1 Unmanned Aircraft

Systems. Proposed operations of any other aircraft will require a new petition or a petition

to amend this grant.

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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 500 feet above ground level

(AGL), as indicated by the procedures specified in the operating documents unless a special

request is made and approved by ATC. All altitudes reported to ATC must be in feet AGL.

5. The UAs must be operated within visual line of sight (VLOS) of the PIC at all times. This

requires the PIC to be able to use human vision unaided by any device other than corrective

lenses, as specified on the PIC’s FAA-issued airman medical certificate.

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted.

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the

VLOS requirement as long as the PIC always maintains VLOS capability. The SO and PIC

must be able to communicate verbally at all times. Electronic messaging or texting is not

permitted during flight operations. The PIC must be designated before the flight and cannot

transfer his or her designation for the duration of the flight. The PIC must ensure that the

SO can perform the functions prescribed in the operating documents.

8. The SO must not perform any other duties beyond assisting the PIC with seeing and

avoiding other air traffic and other ground based 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 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.

10. 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.

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11. 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.

12. 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.

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 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.

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 PIC must possess at least a private pilot certificate and at least a current third- class

medical certificate.

18. 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.

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

operations must be conducted under visual meteorological 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 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

20
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.

21. The UA may not be operated less than 500 feet below or less than 2,000 feet

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

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

predetermined location within the planned operating area and land or be recovered in

accordance with the operating documents.

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

accordance with the operating documents.

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

weather conditions) there is enough power to fly at normal cruising speed to the intended

landing point and land the UA with 25% battery power remaining.

25. The operator must obtain an Air Traffic 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.

26. 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 (NNumber) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as

large as practicable.

27. Before conducting operations, the radio frequency spectrum used for operation and

control of the UA must comply with the Federal Communications Commission (FCC) or

other appropriate government oversight agency requirements.

28. 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.

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

and activities at all times.

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

31. 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

21
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).

32. All operations shall be conducted over private or controlled-access property with

permission from the landowner/controller or authorized representative. Permission from

land owner/controller or authorized representative will be obtained for each flight to be

conducted.

33. Any incident, accident, or flight operation that 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.

7202 Ventures 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 2, DJI

Phantom 3 and DJI Inspire 1 UASs unless that PIC has demonstrated, by meeting minimum

flight-hour and currency requirements, that the PIC is able to safely operate the DJI

Phantom 2 or DJI Phantom 3 or DJI Inspire 1 UAS in a manner consistent with the

exemption, including evasive and emergency maneuvers and maintaining appropriate

distances from people, vessels, vehicles and structures.

Considering 7202 Ventures 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 2 or DJI Phantom 3 or DJI Inspire 1 UAS,

7202 Ventures, LLC submits that the additional manned airmanship experience of a

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

7202 Ventures, LLC specific proposed flight operations.

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

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

22
Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136,

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

7202 Ventures will not allow any PIC to operate the DJI Phantom 2, DJI Phantom 3 or DJI

Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight-hour

requirements or the DJI Phantom 2 or DJI Phantom 3 or DJI Inspire 1 UAS training and

currency requirements, that the PIC is able to safely operate the DJI Phantom 2 or DJI

Phantom 3 or DJI Inspire 1 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 of UAS to be used

for operations under the exemption). In addition to the hour requirements, the PIC must

accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes).

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 7202 Ventures proposed operations. The Administrator 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

23
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.

Accordingly, 7202 Ventures will ensure safe operations by not allowing any PIC to operate

the DJI Phantom 2 or DJI Phantom 3or DJI Inspire 1 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 2 or DJI Phantom 3 or DJI Inspire 1 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, 7202 Ventures will ensure that the DJI Phantom 2 or DJI Phantom 3 or

DJI Inspire 1 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 91.121Would 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 2, DJI Phantom 3 and DJI Inspire 1 UASs 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 7202 Ventures operation of the DJI

Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs 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 point is automatically established by the UASs at

ground level.

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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 2,

DJI Phantom 3 and DJI Inspire 1 UASs; (2) the limitations on the proposed flight operations;

and (3) the location of the proposed flight operations. Accordingly, 7202 Ventures will

ensure that it will safely operate the battery powered DJI Phantom 2, DJI Phantom 3 and DJI

Inspire 1 UASs 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 2, DJI

Phantom 3 and DJI Inspire 1 UASs; 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 2, DJI Phantom 3 and DJI Inspire 1 UASs 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 2, DJI

Phantom 3 and DJI Inspire 1 UASs 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).

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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, 7202 Ventures 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

7202 Ventures 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 7202 Ventures Aerial Operations Manual,

Monthly Maintenance Log, and DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 Instruction

Manual). Furthermore, 7202 Ventures will document and maintain all maintenance records

for the DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs.

Since the DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs will be inspected as

prescribed by the operating documents, 7202 Ventures 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 2 and DJI Inspire 1 User Manuals are attached hereto as Exhibit D and E; a

copy of the DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UAS Maintenance LOG is

attached hereto as Exhibit F.

Likewise, the exemption sought will not adversely affect safety because 7202 Ventures 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 2, DJI Phantom 3 and DJI Inspire 1 UASs 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 7202 Ventures proposed operating limitations, the operating

documents, and the technical aspects of the DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1

UASs, 7202 Ventures submits that safety will not be adversely affected by granting

26
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, 7202 Ventures requests that the FAA

prescribe special conditions for the intended operation of the DJI Phantom 2, DJI Phantom

3 and DJI Inspire 1 UASs, 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. 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

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 2, DJI Phantom 3 and DJI Inspire 1 UASs, 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.

27
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 2,

DJI Phantom 3 and DJI Inspire 1 UASs, 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 7202 Ventures Seeks Exemption:

7202 Ventures 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 7202 Ventures Seeks:

This exemption will permit 7202 Ventures 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

7202 Ventures 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, 7202 Ventures 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, 7202 Ventures will operate the DJI Phantom 2,

DJI Phantom 3 and DJI Inspire 1 UASs safely in the NAS, without creating a hazard to users

of the NAS, or the public, or otherwise pose a threat to national security.

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CONCLUSION

As set forth herein, 7202 Ventures 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 2, DJI Phantom 3 and DJI Inspire 1 UASs 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 FAA

Administrator will be fulfilling the Congressional mandate of the FAA Modernization and

Reform Act of 2012, while also advancing the interests of the public, by allowing 7202

Ventures to safely, efficiently, and economically operate the DJI Phantom 2, DJI Phantom 3

and DJI Inspire 1 UASs commercially within the NAS.

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

Modernization and Reform Act of 2012, Section 333, 7202 Ventures 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 2, DJI Phantom 3 and DJI Inspire 1 UASs commercially for the purpose of

conducting aerial video and photography over certain areas of the United States.

Dated: November 17, 2015

Respectfully submitted,

Todd McCaskey, President

7202 Ventures, LLC

7202 Scenic Oaks Cir

Austin, TX 78745

Tel: 512-524-9739

Appendices:

A – DJI Phantom 2 Specifications Data Sheet

B – DJI Phantom 3 Specifications Data Sheet

C – DJI Inspire 1 Specifications Data Sheet

D – DJI Phantom 2 & DJI Phantom 3 Manufacturer’s User Manual

E – DJI Inspire 1 Manufacturer’s User Manual

F – Monthly Maintenance Log

29
30
APPENDIX – A

DJI PHANTOM 2 TECHNICAL SPECIFICATIONS

7202 Ventures 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. DJI Phantom 2

1.1 Aircraft

1.1.1 Supported Battery – DJI 5200mAH LiPo Battery

1.1.2 Weight (Battery & Propellers Included) – 2lbs 11.810oz (1242g)

1.1.3 Hover Accuracy (Ready to Fly) – Vertical: .8m; Horizontal: 2.5m

1.1.4 Max Yaw Angular Velocity - 2000/s

1.1.5 Max Tilt Angel - 350

1.1.6 Max Ascent Speed – 6m/s

1.1.7 Max Descent Speed – 2m/s

1.1.8 Max Flight Speed – 15m/s (NOT RECOMMENDED)

1.2 Gimbal

1.2.1 Working Current – Static: 750mA; Dynamic: 900mA

1.2.2 Control Accuracy - ±0.030

1.2.3 Controllable Range – Pitch: -900- 00

1.2.4 Maximum Angular Speed – Pitch: 900/s

1.3 Camera

1.3.1 Operating Temperature Range - 320F - 1040F (00C - 400C)

1.3.2 Sensor Size – 1/2.3”

1.3.3 Effective Pixels – 14M

1.3.4 Resolution – 4384x3288

1.3.5 HD Video Recording – 1080p30 & 720p

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1.3.6 Recording Field of View - 1100/850

1.4 Transmitter

1.4.1 Operating Frequency – 5.728GHz – 5.85GHz

1.4.2 Communication Distance (unobstructed) – FCC Compliance: 800m

1.4.3 Receiver Sensitivity (1%PER) - -93dBm

1.4.4 Transmitter Power – FCC Compliance: 100mW

1.4.5 Working Voltage – 120mA@3.7V

1.5 Range Extender

1.5.1 Operating Frequency – 2412-2462MHz

1.5.2 Communication Distance (unobstructed) – 500-700m

1.5.3 Transmitter Power – 20dBm

1.5.4 Power Consumption – 2W

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APPENDIX – B

DJI PHANTOM 3 TECHNICAL SPECIFICATIONS

7202 Ventures 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)

2. DJI Phantom 3

2.1 Aircraft

2.1.1 Supported Battery – DJI 6000mAh LiPo 2S

2.1.2 Weight (Battery & Propellers Included) – 1280 g

2.1.3 Hover Accuracy (Ready to Fly) – Vertical: 10cm; Horizontal: 1m

2.1.4 Max Ascent Speed – 5m/s

2.1.5 Max Descent Speed – 3m/s

2.1.6 Max Flight Speed – 16m/s (ATTI mode, no wind)

2.2 Gimbal

2.2.1 Controllable Range – Pitch: -90 0+ 30 0

2.2.2 Stabilization – 3-zxis (pitch, roll, yaw)

2.3 Camera

2.3.1 Sensor – Sony EXMOR

2.3.2 Sensor Size – 1/2.3”

2.3.3 Effective Pixels – 12.4M

2.3.4 Video Recording Mode – 4096x2160p, 3840x2160p, 1920x1080p, 1280x720p

2.4 Remote Controller

2.4.1 Operating Frequency – 2.400GHz – 1.483GHz

2.4.2 Max Distance – 2000m

2.4.3 Receiver Sensitivity (1%PER) -101dBm+/-2dBm

2.4.4 Transmitter Power (EIRP) – FCC: 20dBm, CE: 16dBm

2.4.5 Working Voltage – 12A@7.4V

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APPENDIX – C

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

7202 Ventures 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)

3. DJI Inspire 1

3.1 Aircraft

3.1.1 Model – T600

3.1.2 Weight (Battery Included) – 6lbs 7.5291oz (2935g)

3.1.3 Hovering Accuracy (GPS Mode) – Vertical: 0.5m; Horizontal: 2.5m

3.1.4 Max Angular Velocity– Pitch: 3000/s; Yaw:1500/s

3.1.5 Max Tilt Angle - 350

3.1.6 Max Ascent Speed – 5m/s

3.1.7 Max Descent Speed – 4m/s

3.1.8 Max Speed – 22m/s (ATTI mode, no wind – NOT RECOMMENDED)

3.1.9 Max Flight Altitude – 4500m

3.1.10 Max Wind Resistance – 10m/s

3.1.11 Max Flight Time – Approximately 18 minutes

3.1.12 Motor Model – DJI 3510

3.1.13 Propeller Model– DJI 1345

3.1.14 Operating Temperature Range – 140F to 1040F (-100C to 400C)

3.1.15 Dimensions – 17 1⁄4” x 173⁄4” x 12”

3.2 Gimbal

3.2.1 Model – ZENMUSE X3

3.2.2 Output Power (with camera) – Static: 9W: In Motion: 11W

3.2.3 Operating Current – Static: 750mA; In Motion: 900mA

3.2.4 Angular Vibration Range - ±0.030

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3.2.5 Mounting – Detachable

3.2.6 Controllable Range – Pitch: -900to +300; Pan: ±3200

3.2.7 Mechanical Range – Pitch: -1250to 450; Pan: ±3300

3.2.8 Max Controllable Speed – Pitch: 1200/s; Pan:1800/s

3.3 Camera

3.3.1 Name – X33.2.3.2 Model – FC350

3.3.3 Total Pixels – 12.76M

3.3.4 Effective Pixels – 12.4M

3.3.5 Image Max Size – 4000x3000

3.3.6 ISO Range – 100-3200

3.3.7 Field of View -940

3.3.8 CMOS - Sony EXMOR 1/2.3”

3.3.9 HD Video Recording – UHD(4K): 4096x2160p24/25,

3840x2160p24/25/30; FHD: 1920x1080p24/25/30/48/50/60; HD:

1280x720p24/25/30/48/50/60

3.3.10 Operating Temperature Range -320F - 1040F (00C - 400C)

3.4 Transmitter

3.4.1 Name– C1

3.4.2 Operating Frequency – 5.728-5.850GHz; 2.400-2.483GHz

3.4.3 Communicating Distance (unobstructed) – 2000m

3.4.4 Output Power – 9W

3.4.5 Operating Temperature Range -140F to 1040F (-100C to 400C)

3.4.6 Battery – 600mAh LiPo 2S

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APPENDIX – D

DJI PHANTOM 2 & DJI PHANTOM 3 MANUFACTURER’S USER MANUALS

User manuals can be found at:

DJI PHANTOM 2 :

http://download.dji-innovations.com/downloads/phantom_2/en/PHANTOM2_User_Manu

al_v1 .4_en.pdf

DJI PHANTOM 3:

https://dl.djicdn.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual__

V1.6.pdf

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APPENDIX – E

DJI INSPIRE 1 MANUFACTURER’S USER MANUAL

User manual can be found at:

http://download.dji-innovations.com/downloads/inspire_1

/en/Inspire_1_User_Manual_v1 .2_en.pdf

37
APPENDIX – F

38