1

Jason D Damman 713 Wedgewood Dr. Avon Lake, OH 44012 (419) 699

- 6010 jddamman@gmail.com

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F.R. Part 11, Jason Dennis Damman, a professional airline pilot, hereby applies for an exemption from the Federal Aviation Regulations (FARs) listed below to allow operation of my Small Unmanned Aircraft Sy stem (sUAS) commercially in airspace regulated by the Federal Aviation Administration ( FAA) so long as such operations are conducted with and under the conditions outlined herein or as may be established by the FAA as required by Section 333.

The requested exemption would permit Jason D Damman to pursue his commercial interests in providing services to clients using a DJI Phantom 3 in the following areas: real estate, marketing, land management/surveying, motion picture filming, special events, and search and rescue.

Jason D Damman has demonstrated the ability to safely and effectively fly the DJI Phantom 3 which will be used for all commercial and private purposes. Jason D Damman com plies with local ordinances and laws regarding the operation of sUAS, and adheres to all weather and environmental restrictions or limitations in reference to the operations of sUAS.

The following contains my list of regulations from which I am seeking exemption, my qualifications as an Operator, and a complete list of the responsibilities I assume as O perator; it also contains information regarding the aircraf

t, public benefit and safety features, and similar petitions requests granted.

Thank You for your Consideration, Jason D. Damman2

**TABLE OF CONTENTS**

GLOSSARY OF ABBREVIAT IONS................................................................................

.......... ......... . .. ...2 SUMMARY..............................................................................

................... ..... ........ . .... ..3 IN TRODUCTI ON AND INTERESTS OF PETI TI ONER................................................

.................................................. ........ .... . . ...3 BACKGROUND.....................................................................................

........ ........ ......... 3 BASI S FOR PETI TI ON......................................................................................................

... ........ .... ...4 NAME AND ADDRESS OF PETITIONER...........................

....................... ........ ....... .. 5 THE SPECIFI C SECTIONS OF 14 C.F.R. FROM WHI CH Jason Dennis Damman SEEKS EXEMPTION

.................................... ...... ...... 5 THE EXTENT OF RELIEF Jason Dennis Damman SEEKS AND THE REASON Jason Dennis Damman SEEKS THE RELIEF...........................

..................... ....... ... .... .8 THE REASONS WHY GRANTING Jason Dennis Damman 's REQUEST WOULD BE IN THE PUBLIC INTEREST ..............................

....... ........9 THE REASONS WHY GRANTING THE EXEMPTI ON WOULD NOT ADVERSELY AFFECT SAFETY...............................................

..................... ....... ......12 SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGI STER...

....... ...22 ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT Jason Dennis Damman's REQUEST...............

....... .... . ..22 CONCLUSION................................................................................

............... ....... ...... ...23 APPENDI CES........................................................................

..... ....... . 243

**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 Contro l Station GPS Global Positioning System LOL Loss of Link NAS National Airspace Sy stem NOTAM Notice to Airman PI C 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 Sy stem VFR Visual Flight Rules VLOS Visual L ine of Site VMC Visual Meteorological Conditions VTOL Vertical Takeoff and Landing4

**SUMMARY** Jason Dennis Damman seeks exemption from the requirements of 14 C.F.R §§, 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 the FAA Modernization and Reform Act o f 2012 (FMRA). This exemption will permit Jason Dennis Damman to operate an Unmanned Aircraft S ys tem (UAS) for the commercial purpose of conducting aerial video and photography of construction sites, real estate, and landscape over certain areas of the Uni ted States.

**INTRODUCTION AND INTERESTS OF THE PETITIONER** Jason Dennis Damman is a licensed and current Airline Transport Pilot with a current First Class medical certificate that would like to provide clients with expertise and knowledge in advanced technologies and solutions to increase efficiency , productivity and effectiveness. Jason Dennis Damman has been building and fl yi ng radio

- controlled airplanes and helicopters since 1990 and also has over 15 years of professional flying experience (Over 10, 000 hours of logged flight time) as an airline transport pilot, including 10 ye ars as Captain/PI C, with Expressjet Airlines on the Embraer 135/145 aircraft

. Jason Dennis Damman is highl y trained and experienced in airspace infrastructure, airport operatio ns, and aircraft flight patterns. The objective of Jason Dennis Damman’s aerial video and photograph y operation is to provide high quality imaging for a variety

of commercial, public, and residential uses, specifically targeting:

C o n s tr u c t i o n s i t e s b e f

ore and after Ap p r a i s a l s R e a l

- estate marketing M o t i o n P i c tur e F i l m i ng A e ri a l a c qu i s i t i o n s u s e d f o r i n s p e c t i o n s o f p ub l i c an d p ri v at e propert y/ structures. S e arc h an d R e s c u e o p e r at i o n s

**BACKGROUND** Unmanned Aircraft Sy stems: DJIPhantom 3 Advanced/P rofessional UASs Jason Dennis Damman seeks an exemption to operate DJ I sy stems for compensation or hire within the NAS. The DJ I Phantom 3 Advanced/Professional UASs are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Statio n (GCS) utilizing electronic tablet or smart phone systems. The DJ I Phantom 3 Advanced/Professional has a maximum gross weight of approximately 2 pounds 12 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 DJ I Phantom 3 Advanced/Professional UAs are equipped with four main rotors; driven by Li thium Poly

mer battery

powered electric motors. The DJ I Phantom 3 Advanced/Professional UAs that will be operated b y Jason Dennis Damman 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 Marking5

**BASIS FOR PETITION** Petiti oner, Jason Dennis Damman, 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 DJIPhantom 3 Advanced/Professional UASs in the National Airspace S ys tem (NAS), and for an exemption from the requirements of 14 C.F.R §§, 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, Jason Dennis Damman’s operation of DJ I Phantom 3 Advanced/Professional UASs meets the conditions of FMRA S ection 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingl y, Jason Dennis Damman 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 onl y appl y to aircraft with an airworthiness certificate. Jason Dennis Damman submits that the requested relief is proper since an equivalent level of safety will be ensured. Jason Dennis Damman wi ll 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 Lo g, and DJIPhantom 3 Advanced/Professional Instruction Manual). Furthermore, Jason Dennis Damman will document and maintain all maintenance records for the DJ I Phantom 3 Advanced/Professional UASs.

Jason Dennis Damman seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness , because the DJ I Phantom 3 Advanced/Professional UASs do not require

an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Jason Dennis Damman submits that he will ensure that the DJ I Phantom 3 Advanced/Profe ssional UASs 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 Lo g, and DJIPhantom 3 Advanced/Professional Instruction Manual), and that the aircraf

t are in a condition for safe flight.

Jason Dennis Damman also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , as the DJ I Phantom 3 Advanced/Professional UAs will not have a ty

pical barometric altimeter onboard. Ho wever, altitude information of the DJIPhantom 3 Advanced/Professional UAs will be provided to the PI C 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 Jason Dennis Damman 's operation of the DJ I Phantom 3 Advanced/Professional UASs within visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121.6

Additionally
, Jason Dennis Damman seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions

. Jason Dennis Damman submits that safety will not be affected by

operation of the DJ I Phantom 3 Advanced/Professional UAs during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly

for a total duration of approximately 13.5 minutes to the first point of intended landing and,

ass uming normal cruising speed, to fl y after that for at least 4.5 minutes.

In accordance with 14 C.F.R. § 11.81, Jason Dennis Damman provides the following information in support of its petition for exemption:

**A. Name And Address Of The Petitioner.** The name and address of the Petitioner and point of contact is: Jason Dennis Damman 713 Wedgewood Dr. Avon Lake, OH 44012 Email: jddamman@gmail.com

**B. The Specific Sections Of 14 C.F.R. From Which Jason Dennis Damman**  **Seeks Exemption.** 

**1**

**. Jason Dennis Damman**  **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.

**2**

**. Jason Dennis Damman**  **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 crui sing altitude or flight level of that aircraft, as the case may be, b y 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 m iles 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.7

**3**

**. Jason Dennis Damman**  **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, assumi ng normal cruising speed, to fly after that for at least 20 minutes.

**4**

**. Jason Dennis Damman**  **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[.]

**5**

**. Jason Dennis Damman**  **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 pers on may

operate any

aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

-- (1) It has been approved for return to service b y a person authorized under § 43.7 of this chapter[.]

**6**

**. Jason Dennis Damman**  **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 b y 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

**7**

**. Jason Dennis Damman**  **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

a ircraft for return to service.

(2) Records containing the following information: (i) The total time in service of the airframe, each engine, each propeller, and each rotor. (ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safet y directives including, for each, the method of compliance, the AD or safet y directi ve 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 current ly 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 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 re gistered 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.9

**C. The Extent Of Relief Jason Dennis Damman Seeks And The Reason Jason Dennis Damman Seeks The**  **Relief.**

**1. Extent Of Relief Jason Dennis Damman**  **Seeks And The Reason Jason Dennis**  **Damman 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 Jason Dennis Damman t o determine that the DJ I Phantom 3 Advanced/Professional UASs are in airworthy condition prior to every

flight by ensuring that the UAS is in compliance with the operating documents (i.e. , Monthly Maintenance Lo g, and DJ I Phantom 3 Advanced/Professional Instruction Manual). Jason Dennis Damman seeks the requested relief because the DJ I Phantom 3 Advanced/Professional l UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Jason Dennis Damman will ensure that the DJIPhantom 3 Advanced/Professional UASs are in airworth y condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJ I Phantom 3 Advanced/Professional Instruction Manual) prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated in the conditions and limitations below

**2. Extent Of Relief Jason Dennis Damman**  **, Seeks From Section 91.121.** Relief from Section 91.121, entitled Altimeter settings, may be requ ired to allow flight operations of the DJIPhantom 3 Advanced/Professional 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 PI C at the ground control station (GCS). Since the FAA requires that an y altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), Jason Dennis Damman seeks the requested relief because the DJ I Phantom 3 Advan ced/Professional UA’s altimeter may beset on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight. Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply

with the applicable conditions and limitations stated below. As more full y set forth herein, an equivalent level of safety will be maintained since the DJIPhantom 3 Advanced/Professional UAs are equipped with a barometric pressure sensor and GPS equipment, which automaticall y ensures that a ground level pressure setting will be established prior to each flight, and provides the PI C with altitude information of the UA on the heads

- up display of the GCS.

**3. Extent Of Relief Jason Dennis Damman**  **Seeks And The Reason Jason Dennis**  **Damman 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 pow ered DJ I Phantom 3 Professional UAs 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 fl y af ter that for at least 4.5 minutes.10

Jason Dennis Damman 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 Professional UAs will severel y constrain the practicality of any aerial video or still photo flight operations that Jason Dennis Damman proposes to conduct pursuant to this Petition. Significantl y, as set forth below, the technical specifications of the DJ I Phantom 3 Professional UASs, the DJIPhantom 3 Advanced /Professional operating documents, and Jason Dennis Damman’s proposed operating limitations, ensure that Jason Dennis Damman will safel y operate the battery powered DJIPhantom 3 Advanced/Professional UAs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly

for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

**4 . Extent Of R**  **elief Jason Dennis Damman**  **Seeks And The Reason Jason Dennis**  **Damman 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 appl y to aircraft with an airworthiness certificate, Jason Dennis Damman requests relief from these Sections because the DJ I Phantom 3 Advanced/Professional UASs do not require airworthiness certificates. As set forth more fully below, the DJI Phantom 3 Advance d/Professional UASs meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingl y, Jason Dennis Damman 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 Jason Dennis Damman Aerial Operations Manual, Monthly Maintenance Log, and DJ I Phantom 3 Advanced/Professional Instruction Manual). Furthermore, Jason Dennis Damman will document and maintain all maintenance records for the DJ I Phantom 3 Advanced/Professional UASs.

**D. The Reasons Why Granting Jason Dennis Damman**  **Request Would Be In The Public Interest; That Is, How It Would Benefit The Public As A**  **Whole.**
Granting the present Petition will further the public interest by allowing Jason Dennis Damman to safel y, efficiently , and economically perform aerial video and photograph y of construction sites, real estate, and landscape over certain areas of the United States. A dditionally , use of the DJ I Phantom 3 Advanced/Professional UASs will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the econom y. Notabl y, the benefits of Jason Dennis Damman 's proposed operation of the DJIPhantom 3 Advanced/Professional UASs will be realized without implicating any privacy issues.11

**1. The Public Will Benefit From Decreased Congestion Of The NAS.** The DJ I Phantom 3 Advanced/Professional UAs 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 aerial acquisitions, an exemption allowing the use of a DJI Phantom 3 Advanced/Professional UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground. Furthermore, 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/Professional UAs do not require an airport to takeoff or land. L ikewise, a reduction of manned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations.

**2. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 3 Advanced/Professi**  **onal UASs.** Conducting aerial acquisitions with the DJIPhantom 3 Advanced/Professional UA S s, instead of manned aircraft, will greatl y 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 DJIPhantom 3 Advanced/Professional UASs produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder inter

nal combustion engine aircraft that are ty pically utilized for aerial video and photograph y, while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The DJIPhantom 3 Advanced/Professional UAs, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAs are propelled by battery powered electric motors, rather than an internal combustion engine. By using the DJ I Phantom 3 Advanced/Professional 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 DJ I Phantom 3 Advanced/Professional UAs (weighing approximately 2 pounds 12 ounces, at their maximum gross weights with lengths and widths of 16 inches , and with 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 ty picall y 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).12

**3. Performing Aerial Video and Photography Operations With The DJI Phantom 3 Professional UASs Will Benefit The Economy.**  In addition to being safe and efficient, the DJ I Phantom 3 Advanced/Professional UASs are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJIPhantom 3 Advanced/Professional UASs will allow United States based companies, like Jason Dennis Damman , to remain competitive and contribute to growth of the U.S.

econom y. 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 compet itive. Operating the battery powered DJ I Phantom 3 Advanced/Professional 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 DJIPhantom 3 Advanced/Professional UASs, companies and individuals such as Jason Dennis Damman , can remain competitive and profitable, and therefore, provide greater job stability to employees and contra ctors, which will ultimately contribute to growth of the U.S.

econom y. Improved financial performance of U.S. companies, through commercial use of the DJI Phantom 3 Advanced/Professional UASs, provides a stable workforce that increases consumer spending; i mproves 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, Jason Dennis Damman 's proposed operation of the DJI Phantom 3 Advanced/Professional UASs will not implicate any privacy issues. Specificall y, the DJ I Phantom 3 Advanced/Professional UASs will be operated

on ly in compliance with operating documents (i.e., Monthly Maintenance Log, and DJ I Phantom 3 Advanced/Professional Instruction Manual) which requires property owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.13

**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 Jason Dennis Damman**  **Seeks Exemption.**

**1. Reasons Why The DJI Phantom 3 Advanced/Professional**  **UAs Meet The Conditions Of**  **The FAA Modernization and Reform Act of 2012 (FMRA) Section 333.** 
In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, Jason Dennis Damman operation of the DJ I Phantom 3 Professional UASs meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in a ccordance 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 otherw ise pose a threat to national security. Specificall y, 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, operati onal capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security; and (2 ) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1). (c) Requirements for Safe Operation.

--If th e 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.14

In seeking this exemption, Jason Dennis Damman submits that the DJ I Phantom 3 Advanced/Professional UASs can operate safel y in the NAS pursuant to FMRA Section 333, as demonstrated b y: (a) the characteristics of the DJ I Phantom 3 Advanced/Professional UASs; (b) the pilot certification requirement; and (c) the specific operating limitations.

**a. The Specifications Of The DJI Phantom 3 Advanced/Professional**  **UASs Demonstrate Its Safe Characteristics.**  The DJ I Phantom 3 Advanced/Professional 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 3**  **Advanced /Professional**  **UASs.** The technical specifications of the DJ I Phantom 3 Advanced/Professional UASs are set forth b y the DJIPhantom 3 Advanced/Professional Specifications, attached hereto as Exhibit A.

**ii. The DJI Phantom 3 Advanced/Professional**  **UASs Autonom ous**  **Flight And Navigation Modes Enable The UASs To Remain Within A**  **Defined Operational Area.**  The DJ I Phantom 3 Advanced/Professional UASs may be operated in both manual and full y autonomous flight modes. A complete description of the flight and navigation al modes of the DJ I Phantom 3Advanced/Professional UASs is provided at pages 39

- 47 of the DJ I Phantom 3 Advanced/Professional User Manual, attached hereto as Exhibit B.

**iii. The DJI Phantom 3 Advanced/Professional**  **UASs Are Designed For**  **Automatic Return 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 Advanced/Professional UA S s will remain stationary , in flight, for 3 seconds or more. If, after 3 seconds, the DJ I Phantom 3 Advanc ed/Professional 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 descend to the takeoff position and shutdown. A

complete description of the Failsafe Functions of the DJ I Phantom 3 Advanced/Professional UAS are set forth at page 14 of the DJ I Phantom 3 Advanced/Professional User Manual, attached hereto as Exhibit B.15

**iv. The DJI Phantom 3 Advanced/Professional**  **GCS An d Its**  **Operation.** A complete description of the operation and specifications of the DJ I Phantom 3 Advanced/Professional GCS and flight control software is provided at pages 35 through 39 of the DJ I Phantom 3 Advanced/Professional User Manual. DJ I Phantom 3 Advanced/Professional User Manual is attached hereto as Exhibit B.

**b. Flight Operations Of DJI Phantom**  **3 Advanced/** **Professional UASs Are Limited To**  **The Line Of Sight Of A Pilot in Command With A Safety Observer.**  Jason Dennis Damman will only uti lize pilots who have at least 25 hours flight time to act as a pilot in command (PI C) of the DJ I Phantom 3 Advanced/Professional UASs. Additionally , a safety observer will assist all pilots during flight time.

**c. Flights Of DJI Phantom 3 Advanced/Professional**  **UASs Will Be Conducted**  **Pursuant To Specific Operating Limitations.** In seeking this exemption, Jason Dennis Damman proposes to commercially operate DJ I Phantom 3 Advanced/Professional UASs for the special purpose of conducting aerial video and photograph y 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 les s than 55 pounds maximum gross weight: DJ I Phantom 3 Advanced/Professional Unmanned Aircraft Sy stems. Proposed operations 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 limited to conducting operations for the purpose of aerial video and photograph y.
3. The UAs may

not be flown at an indicated airs peed exceeding 30 knots.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL), as ind icated b y the procedures 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. This requires the PI C to be able to use human vision unaided b y an y device other than corrective lenses, as specified on the PI C’s FAA

- issued airman medical certificate.16

6. The use of first person view (FPV) b y the PI C or safet y observer (SO) is not perm itted.

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC alway s maintains VLOS capability . The SO and PI C 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 PI C must ensure that the SO can perform the functions prescribed in the operatin g documents.

8. The SO must not perform any other duties beyond assisting the PI C 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 d ocuments 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 outline d 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 rev ise 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 extensio n or amendment to the grant of exemption. If the operator determines that an y 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 PI C 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 pre flight inspection. All maintenance and alterations must be properl y documented in the aircraft records.17

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 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 potential discrepancies, e.g. inoperable components, item s, 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, replacem ent, inspection, and life limit requirements.

14. The operato r 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 PI C must have completed at least 25 hours of flight time.

18. The operator may

not permit any

PIC to operate unless the PI C 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 approp riate 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 PI Cs are permitted under the terms of the exemption. However, training operations may onl y 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 PI C mus t operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. §91.119.18

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 conditi ons (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 2 nautical miles of an airport reference point as denoted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required b y the operator’ 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 400 feet below or less than 2,000 feet horizontally

from a cloud or when visibility is less than 3 statute mile s 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.

23. The PI C must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents.

24. The PI C is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fl y 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 (N

- Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable.19

27. Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply w ith 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 an y law enforcement official upon request.

29. The UA must remain clear and yi eld the right of way to all manned aviation operations and activities at all times.

30. The UAS may

not be operated b y 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 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 suc h vessels, vehicles or structures has granted permission and the PI C 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 PI C, SO, operat or trainees or essential persons do not present an undu e hazard to those persons per § 91.119(a).

32. All operations shall be conducted over private or controlled

- access property with permission from the land owner/controller or authorized representative. Per

mission from land owner/controller or authorized representative will be obtained for each flight to be conducted.20

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 r eported 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 91.7(a) Would Not Adversely Affect S**  **afety.** The equivalent level of safety established b y Section 91.7(a) will be maintained because prior to every

flight, Jason Dennis Damman will ensure that the DJI Phantom 3 Advanced/Professional UAS is in an airworthy condition based upon the UAS’s compli ance with its operating documents and as stated in the conditions and limitations herein. Additionally
, the FAA has previousl y 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, 110 64, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

**3. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely**  **Affect Safety.** The equivalent level of safety established b y Section 91.121 will be maintained because the altitude information of the DJ I Phantom 3 Advanced/Professional UAs will be provided to the PI C 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 Jason Dennis Damman 's operation of the DJ I Phantom 3 Advanced/Professional UAs within visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information will be generated b y GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automaticall y established by the UASs at ground level. The FAA has previousl y 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, 1106 7, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

**4. 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 DJ I Phantom 3 Professional UASs; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations . Accordingl y, Jason Dennis Damman will ensure that it will safely operate the battery

powered DJ I Phantom 3 Advanced/Professional UAs during daylight hours in VFR conditions, with enough battery power to fly

for a total duration of 13.5 minutes to the fir st point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.21

Here, as in Exemption No. 11109, the technical specifications of the DJ I Phantom 3 Advanced/Professional UASs; the limitations on the proposed f light 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 DJIPhantom 3 Advanced/Professional UASs provide audible and vis ual warnings to the PI C 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 DJ I Phantom 3 Advanced/Professional UASs will descend and land automaticall y. Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversel y affected when the technical characteristics and operating limit ations 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 previousl y 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, 111 58, 11159, 11160, 11161).

**5. 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, Jason Dennis Damman 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 Jason Dennis Damman 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., Monthly Maintenance L og, and DJ I Phantom 3 Advanced/Professio nal Instruction Manual). Furthermore, Jason Dennis Damman will document and maintain all maintenance records for the DJ I Phantom 3 Advanced/Professional UASs.

Since the DJ I Phantom 3 Advanced/Professional UASs will be inspected as prescribed b y the operat ing documents, Jason Dennis Damman will maintain the equivalent level of safety established b y Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI Phantom 3 Advanced/Professional User Manual is attached hereto as Exhibit B; a copy of the DJ I Phantom 3 Advanced/Professional UAS Maintenance LOG is attached hereto as Exhibit C. Li kewise, the exemption sought will not adversely affect safet y because Jason Dennis Damman will use trained technicians to perform maintenance, alterations or Prevent ive maintenance on the UAS using the methods, techniques, and practices prescribed b y 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 DJIPhantom 3 Advanced/Professional UASs will be performed b y trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log.22

Significantl y, previous exemptions granted b y 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 adversel y affected when the technical characteristics and operating limitations of the UAS are considered.

In consideration of Jason Dennis Damman 's proposed operating limitations, the operating documents, and the technical aspects of the DJ I Phantom 3 Advanced/Professional UASs, Jason Dennis Damman submits that safety will not be adversel y affected b y granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted relief specific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11 066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

**6. 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, Jason Dennis Damman requests that the FAA prescribe special conditions for the intended operation of the DJ I Phantom 3 Advanced/Professional UASs, which contain such safety standards that the Admin istrator 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 photograph y over certain areas of the United States for compensation or hire. FMRA Section 333 sets forth the requirements for considering wheth er 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 DJ I Phantom 3 Advanced/Professional UASs, since the airworthiness regulations of 1 4 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 amendme nts thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent to that established in the regulations. (See 14 C.F.R. § 21.16.)23

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for Jason Dennis Damman ’s intended operation of the DJI Phantom 3 Advanced/Professional UASs, which contain such safet y 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**  **Jason Dennis Damman Seeks Exemption:**  Jason Dennis Damman seeks exemption from the requirements o f 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 Jason Dennis Damman**  **Seeks:** This exemption will permit Jason Dennis Damma n 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 Jason Dennis Damman**  **'s 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 safel y in the NAS. As such, Jason Dennis Damman 's 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 otherwis e pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification. As discussed in detail above, Jason Dennis Damman will operate the DJ I Phantom 3 Advanced/Professional UASs safel y in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security

.24

**CONCLUSION**

As set forth herein, Jason Dennis Damman 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 DJIPhantom 3 Advanced/Professional UASs commerciall y, without an airworthiness certificate, for the limited purpose of conducting aerial video and photograph y over ce rtain 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, b y allowing Jason Dennis Damm an to safel y, efficiently , and economicall y operate the DJIPhantom 3 Advanced/Professional UASs commercially within the NAS.

**WHEREFORE** , in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, Jason Dennis Damman respectfull y 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 Jason Dennis Damman to operate the DJ I Phantom 3 Advanced/Professional UASs commerciall y for the purpose of conducting aerial video and photography over certain areas of the United States.

Dated: August 18 , 2015

Respectfully submitted, Jason Dennis Damman25

Jason Dennis Damman 713 Wedgewood Dr. Avon Lake, OH 44012 (419) 699

- 6010 Email: jddamman@gmail.com

Appendices:

A

– DJ I Phantom 3 Advanced/Professional Specifications Data Sheet B

– DJ I Phantom 3 Advanced/Professional Manufacturer’s User Manual C

– Monthly

Maintenance L og26

APPENDIX

– A **DJI Phantom 3 Advanced/Professional TECHNICAL SPECIFICATIONS** 

Jason Dennis Damman only utilizes safe and reliable UASs. DJ I is an industry leader in small UAS production. DJIUASs 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 PI C via the linked monitor (smart phone/t ablet devices)

1.1 DJIPhantom 3 Advanced/Professional 1.1.1 Aircraft 1.1.1.1 Supported Battery

– DJ I 4480mAH LiPo Battery 1.1.1.2 Weight (Battery

& Propellers Included)

– 2lbs 12oz 1280g 1.1.1.3 Hover Accuracy

(Ready to Fl y)

– Vertical: 0.1m; Horizontal: 1m 1.1.1.4 Max Flight time

- Approximately 23 minutes 1.1.1.5 Max Tilt Angel

- 35 1.1.1.6 Max Ascent Speed

– 5m/s 1.1.1.7 Max Descent Speed

– 3m/s 1.1.1.8 Max Flight Speed

– 16m/s (NOT RECOMMENDED) 1.1.1.9 Operating Temperature

- 0oC

- 40oC 1.1.1.10 Max Flight Altitude

- 6000m 1.1.1.11 GPS Mode

- GPS/GL ONASS

1.1.2 Gimbal 1.1.2.1 Controllable Range

– Pitch:

- 90 +30

1.1.3 Camera 1.1.3.1 Sensor

- Sony

EXMOR 1/2.3" 1.1.3.2 Lens

- FOV 94o 20mm (35mm format equivalent) f/2.8 1.1.3.3 Effective Pixels

– 12.4M 1.1.3.4 Resolution

– 4384x3288 4.1.3.5 HD Video Recording

– 4K, 1080p & 720p 4.1.3.6 Image Max Size

- 4000 x 3000

1.1.4 Remote Controller 1.1.4.1 Operating Frequency

– 2.400GHz

– 2.483GHz 1.1.4.2 Communication Distance (unobstructed)

- 2000m 1.1.4.3 Battery

- 6000 mAh L iPo 2s 1.1.4.4 Transmitter Power

– FCC: 20dbm CE: 16 dbm 1.1.4.5 Working Voltage

– 1.2 A @7.4 V27

APPENDIX

– B

The DJ I Phantom 3 Advanced/Professional Manufacturer’s User Manual can be found at :
http://www.dji.com/product/phantom

- 3/download28

APPENDIX

– C

**MONTHLY MAINTENANCE LOG Month:_________ Year:_________**  Date Discovered Date Corrected Discrepancy Mx Action Performed

Software Update

Airframe Propellors

Camera/Gimbal

Landing Gear

Other