January 4, 2016 Attn: 

### U.S. Department ofTransportation Docket Operations West Building Ground Floor, Room w12-140 1200NewJersey Ave, SE Washington, DC 20590

RE: BRENTCO AERlAL PATROL 

### REQUEST AN EXEMPTION FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 

### 91.7(a), 91.121, 91.15l(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & 

### (a)(2), AND 91.417(a) & 

### (b) CONCERNING COMMERCIAL OPERATION OF DJI Phantom 3 UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112·95)

Rick Vincent
President Brentco Aerial Patrol Inc.
5668 Perry Hills Dr. Canton, Ohio 44706
330-417-7007 Vincent@gobrainstorm.net

### TABLE OF CONTENTS Page GLOSSARY OF ABBREVIATIONS

...................................................................................3

SUMMARY

...........................................................................................................................4

INTRODUCTION AND INTERESTS OF PETITIONER

....................................................4



### BACKGROUND

....................................................................................................................4

BASIS FORPETITION

.........................................................................................................5

NAME AND ADDRESS OF PETITIONER.

........................................................................6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH THE ALTEK MEDIA GROUP SEEKS EXEMPTION

............................................................................................................7 THE EXTENT OF RELIEF THE ALTEKMEDIA GROUP SEEKS AND THE REASON THE ALTEK MEDIA GROUP SEEKS THE RELIEF

..............................................................!

### 0 THE REASONS WHY GRANTING THE ALTEKMEDIA GROUP'S REQUEST WOULD BE IN THE PUBLIC INTEREST

............................................................................................12 THE REASONS WHY GRANTING THE EXEMPTION TO THE ALTEKMEDIA GROUP WOULD NOTADVERSELYAFFECT SAFETY

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

...................25 ANY ADDITIONAL INFORMATION, VIEWS, ORARGUMENTS AVAILABLE TO SUPPORT THE ALTEKMEDIA GROUP'S REQUEST

..................................................25 CONCLUSION

.....................................................................................................................25 APPENDICES

.........................................................................................26

2

### AGL AOI ATC ATO AV CFR COA FAA FAR GCS GPS LOL NAS NOTAM PIC Section 333 

## so SOP UA UAS VFR VLOS VMC VTOL**-------------~--------**



### GLOSSARY OF ABBREVIATIONS

Above Ground Level Area ofInterest AirTraffic Control AirTraffic Organization Aerial Vehicle Code ofFederal Regulations Certificate ofAuthorization Federal AviationAdministration Federal Aviation Regulation GroundControl Station Global Positioning System LossofLink National Airspace System Notice to Airman Pilot In

### Command FAA Modernization and Reform Act of2012 (FMRA) Safety Observer Standard Openiting Procedures Unmanned Aircraft UnmannedAircraft System Visual FlightRules Visual Line ofSite Visual Meteorological Conditions Vertical Takeoffand Landing

3SUMMARY BRENTCO AERIAL PATROL seeks exemption from the reqmrements ot 14 C.F.R**~~** ol.IU(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System (DJI Phantom 3) pursuant to Section 333 ofthe FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit The ALTEK MEDIA GROUP to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography ofconstruction sites, residential and commercial real estate, civil landscapes and events overcertain areas oftheUnited States.**INTR~DUC'!~ON** 

### AND INTERESTSOFTHE PETITIQNJi:R Brentco Aerial Patrol has for over 40years provided their clients, which include oil & pipeline Companies, with expertise and knowledge in visual surveillance ofpipeline right ofways. In the Past we have provided our clients with aerial**vi~deo** and photography using commercial aircraft. The objective ofBAP and our UAS OJI Phantom 3aerial operations is to provide a more Affordable high quality production system forvideo ofpipeline rightofways.

BACKGROUND Unmanned Aircraft Systems: DJI Phantom 3, UAS BRENTCO AERIAL PATROL seeks an exemption 

### to operate DJI Phantom 3 system for compensation or hire within the NAS. The DJI Phantom 3 is vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The DJI Phantom 3 has a maximum gross weight of approximately 2.8 lb. while having a diagonal dimension of 23.2", a maximum speed of approximately 16.4'fps and a maximum flying height of400'. The DJI PlUmtom 3 is equipped with four mainrotors; driven by L}thium Polymerbatterypoweredelectric motors.

4The DJI Phantom 3 that 

### will be operated by BRENTCO AERIAL PATROL 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 andRegistration Marking.



### BASIS 

### FORPETITION Petitioner, BRENTCO AERIAL PATROL pursuant to the provisions ofthe Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administratorto commercially operate the DJI Phantom 3,UAS inthe 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, 91.15l(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b). In consideration of the speed, weh!ht.**siz~~-** and limited onernting area associated with the unmanned aircraft and its operation, BRENTCO AERIAL PATROL operation ofDJI Phantom 3 UAS meets the conditions ofFMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, SubpartH. Accordingly, BRENTCO AERIAL PATROL requests relief from Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for**mai11~~ll8llce** that onl¥ apply to aircraft withan airworthiness certificate. BRENTCO AERIAL PATROL**submj~ that't!t~**  requested relief is proper since an equivalent level ofsafety 

### will be ensured. BRENTCO AERIAL PATROL 

### will use experienced personnel or technicianstoperformmaintenance, alterations, orpreventive maintenance onthe UAS using the methods, techniques, and practices prescribed in the operating**docume~.Ji.e.,** Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual). Furthermore, BRENTCO AERIAL PATROL. will document and maintain all maintenancerecords fortheDJI Phantom 3 UAS. Relieffrom certain requirements of Section 61.113(a) and (b),**entitle~** Privatepilotprivileges and limitations: Pilot in command, is requested by BRENTCO AERIAL PATROL to the extent necessarytoallowa Pilotin Command (PIC) holding a privatepilotorhigher level certificate, as well as an airman medical certificate, and who has demonstrated, by meeting minimum**flight~** hour and currencyrequirements, thatthe PIC is able to safely operate the DJI Phantom 

### VAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

BRENTCO AERIAL PATROL seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the DJI Phantom 3 UAS do not reauire**anai~o~11ess** certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such,' BRENTCO AERIAL PATROL submits that they will ensure that the DJI Phantom 3 UAS is in an airworthy condition, prior to every flight, by determining that the UAS are in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual), and that the aircraft are in a conditionfor safe flight.BRENTCO AERIAL PATROL 

### also seeks an exemption from the requirements ofSection 91.121, entitled Altimeter Settings, 

### as the DJI Phantom 3 UAS will not have a typical barometric altimeter onboard. However, altitude information ofthe DJI Phantom 3 VAS 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 ofthe flight path. This altitude information, combined with BRENTCOAeRiALPATROL'5 

### operation of the DJI Phantom 3 UAS within visual line ofsight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121. Additionally, BRENTCO AERIAL PATROL 

### seeks an exemption from the requirements of Section 91.15l(b), entitled Fuel requirements

### for flight in VFR conditions.' BRENfCO AERIAL PATROL/ 

### submits that safety will not be affected by operation ofthe DJI Phantom 3 VAS during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration ofapproximately 23 minutes. Battery power indicators are also able to show exactly how much battery power is left, as well as how much time is neededtoreturn safelybackto point oftake off. In accordance with 14 C.F.R. § 11.81, BRENTCO AERIAL PATROL 

### informationin support ofits petitionfor exemption:


### A. Name And Address OfThe Petitioner. The name and address ofthe Petitioner and point ofcontact is:
Rick Vincent
President
BrenttoAerial Patrol Inc.
5668 Perry Hills Dr. Canton, Ohio44706**330-417~7007** Vincent@gobrainstorm.net

6 

### provides the following

### B. The Specific Sections Of 14 C.F.R. From Which BRENTCO AERIAL PATROL 

### Seeks**Exempti()~-:** 

### 1. BRENTCO AERIAL PATROL 

### 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)prescribethe following, inrelevant part: (a) No person who holds a private pilot certificate may act as a pilot in command (PIC) ofan aircraft that is carrying passengers or property for compensation or hire; normaythatperson, for compensation orhire, act as PIC ofan aircraft. (b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with anybusiness oremployment 

### if.- (I) The flight is only incidental to thatbusiness oremployment; and (2) The aircraft does not carry passengers orproperty for compensation orhire. 

### 2. BRENTCO AERIAL PATROL 91.7(a). 

### Seeks Exemption From The Requirements Of Section

Section91.7, entitled 

### Civilaircrqftairworthiness, subsection (a), statesthe following: (a)**Nopersonm~y** ()perate a civil aircraft unless 

### it is in an airworthy condition. 3. BRENTCO AERIAL PATROL 91.121. 

### Seeks Exemption From The Requirements Of Section

Section91.121, entitledAltimeter settings, subsection (a), states the following, inpart: (a) Eachperson operating an aircraft shall maintainthe cruising altitude orflight level ofthat 

### 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 100nautical miles ofthe aircraft; (ii) Ifthere is no station within the area prescribed in'paragraph (a)(l)(i) of this section, 

### the current reported altimeter setting ofan appropriate available station; or

(iii) In the case ofan aircraft not equipped with a radio, the elevation ofthe departure airport or an appropriate altimeter setting available before departure.

74. BRENTCO AERIAL PATROL 91.15l(b). 

### Seeks Exemption From The Requirements Of Section

Section91.151, 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 enoughfuel tofly to the firstpoint of intended landing and, assuming normal cruising speed, tofly after that for atleast20minutes. 5. BRENTCO AERIAL PATROL 91.405(a). 

### Seeks Exemption From The Requirement Of Section

Section 91.405, entitled

### Maintenance required, subsection (a), states the following: Each owneroroperator ofan aircraft- (a) Shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired asprescribedinpart43 ofthis chapter[.] 

### 6. BRENTCO AERIAL PATROL 91.407(a)(l) 

### Seeks Exemption From The Requirements Of Section

Section 91.407, entitled 

### Operation after maintenance, preventive maintenance, rebuilding, oralteration, subsection (a)(

### I), statesthe following: (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, oralterationunless-- (I) It has been approved for return to service by a person authorized under§ 43.7 ofthischapter[.] 

### 7. BRENTCO AERIAL PATROL 91.409(a)(1)And 91.409(a)(2). 

### Seeks Exemption From The Requirements Of Sections

Section91.409, entitled

### Inspections, subsection (a), statesthefollowing: (a) Except as provided 

### in paragraph (c) ofthis section, no person may operate an aircraftunless, withinthe preceding 12 calendarmonths, ithas had

-- (1) An annual inspection in accordance with part 43 ofthis chapter and has been approved for returnto service by a person authorizedby§ 43.7 ofthis chapter; or (2) An inspection for the issuance ofan airworthiness certificate in accordance withpart21 ofthischapter.

88. BRENTCO AERIAL PATROL 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 oroperator shall keep the following records for theperiods specified in paragraph (b) ofthis section: (1) Records of the maintenance, preventive maintenance, 

### and alteration and records of the 1 00-hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance ofanaircraft. The records mustinclude-- (i) A description (or reference to data acceptable to the Administrator) ofthe workperformed; and (ii)The date ofcompletion ofthe workperformed; and (iii)The signature, and certificate number ofthe person approving the aircraft forreturn to service. (2) Records containing thefollowing information: (i) The total time in service ofthe airframe, each engine, each propeller, and eachrotor.

(ii) The current status oflife-limited parts ofeach airframe, engine, propeller, rotor, and appliance.

(iii) The time since last overhaul ofall items installed on the aircraft which are required to beoverhauled on a specified time basis. (iv) The current inspection status ofthe 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 ofapplicable airworthiness directives (AD) and safety directives including, for each, the method ofcompliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date whenthe next action isrequired.

(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.

9(b) The owner or operator shall retain the following records for the periods prescribed: (1) The records specified inparagraph (a)(1) ofthis section shall be retained until the work is repeated or superseded by other work or for I year after the work is performed. (2) The records specified in paragraph (a)(2) ofthis section shall be retained and transferred withthe aircraftatthetimethe aircraftis sold. (3) A list ofdefects 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 forreturnto service.



### C.

### The**Ext~!ll.QI~!!!ef** BRENTCO AERIAL PATROL ' SeeksAndTheReason

1. Extent Of Relief BRENTCO AERIAL PATROL Seeks And The Reason BRENTCO AERIAL PATROL Seeks ReliefFrom Section 61.113(a) And (b). Relieffrom Section 6l.ll3(a) and (b) entitled Privatepilotprivileges 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 proposedUAS flight operations for compensation orhire. This reliefis 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 oremployment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft doesnotcarrypassengers orproperty for compensation orhire. As set forth more fully below, BRENTCO AERIAL PATROL ,submits that an equivalent level of safety will be maintained because no l'lC will 

### be allowed to operate the DJI Phantom 3 UAS unless that PIC has met certain flight-hour and currency requirements, demonstrating that the PIC 

### is able to safely operate either the DJI Phantom 3 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, BRENTCO AERIAL PATROL submits that 

### all flights of the DJI Phantom**3~** UAS, conductedby the PIC pursuant to the grant ofthis Petition: (1) will be incidental to BRENTCOAERIAL PATROL business; and 

### (2) will not carry passengers or property for compensation or hire.

10**------------~-----------.**

2. Extent Of Relief BRENTCO AERIAL PATROL Seeks And The Reason BRENTCO AERIAL PATROL Seeks ReliefFrom Seetion91.7(a). " Relief from Section 91.7(a1**~ntitled** 

### Civil aircrqft airworthiness, is requested to the extent requiredto allow BRENTCO AERIAL PATROL to determine thatthe DJI Phantom 3 UAS are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., th.e BRENTCO AERIAL PATROL Aerial Operations Manual, Monthly Maintenance Log, and DJI Phuntom 3 InstructionManual). BRENTCO AERIAL PATROL seeks the requested reliefbecause the DJI Phantom 3 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, BRENTCO AERiAL PATROL will ensure that the DJI Phantom 3 UAS are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJl Phantom 3) prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated inthe conditions and limitations below.

3. Extent Of Relief BRENTCO AERIAL PATROL Seeks And ,The Reason BRENTCO AERIAL PATROL Seeks ReliefFrom Section 91.121. Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the DJI Phantom 3 

### VAS, 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._operation~be_xeported** to air traffic control (ATC) in feet above ground level (AGL), BRENTCO AERIAL PATROL ,seeks the requested reliefbecause the DJI Phantom 3 UA's altimeter may be set on the ground to zero feet AGL, rather than the local barometricpressure orfield altitude, before eachflight. Considering the limited altitude ofthe proposed operations, relieffrom 14 CFR 91.121 is sought to the extentnecessaryto comply with the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level of safety will be maintained since the DJI Phantom 3 UAS are equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established priorto each flight, and provides the PIC with altitude information ofthe UA onthe heads-up displayofthe GCS.

4. Extent Of Relief BRENTCO AERIAL PATROL Seeks And The Reason BRENTCO .AERIAL PATROL Seeks ReliefFrom Section 91.151(b). Relief from Section 91.15l(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to allow flights ofthe battery powered DJI Phantom 3 UAS during daylight hours in visual meteorological conditions**(VM<;)~** under visual flight rules (VFR), for a total duration of 23 minutes. BRENTCO AERIAL PATROL seeks the requested relief because without an exemption from Section 91.15l(b), the flight time duration of the



## .. 11battery powered DJI Phantom 3 UAS will severely constrain the practicality ofany aerial video or still photo flight operations that BRENTCO AERIAL PATROL ··-proposes to conduct pursuant tothis Petition. Significantly, as set forth below, the technical specifications ofthe DJI Phantom 3 UAS, the DJI Phantom 3 operating documents, and BRENTC07\ERIALPATROL proposed operating limitations, ensure that BRENTCOAERfA-LPATR6L. will safely operate the battery powered DJI Phantom 3 UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enoughbatterypowerto fly for a total duration of23 minutes.



### 5. Extent Of Relief BRENTCO AERIAL PATROL 

### Seeks And The Reason BRENTCO AERIAL PATROL ' 

### Seeks ReliefFrom Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & 

### (a)(2), And91.417(a) & (b). Since Sections 91.405(a), 91.407{a)(l), 9l.409(a)(l)&(a)(2),**an~** 91.417(a) 

### & (b) only apply to aircraft with an airworthiness certificate, BRENTC6AERJAL-PATROL requests relief from these Sections because the DJI Phantom 3 UAS do notrequire airworthiness certificates. As set forth more fully below, the DJI Phantom 3 UAS meet the conditions ofFMRA Section 333 for operation without an airworthiness certificate. Accordingly,

- .... BRENTCO -AERIAL PATROL will use trained technicians to perform maintenance, alterations, or prevehtive maintenance on the UAS using the methods, techl}iques, and practices prescribed in the UAS operating documents (i.e., BRENTCO AERIAL PATROL Aerial Operations Man1J!!l_,_ Monthly fv!aintenance Log, and DJI Phantom 3 Instruction Manual). Furthermore, BRENTCO AERIAL PATROL will document andmaintainall maintenancerecords forthe DJI Phantom 3 UAS.



### D. The Reasons Why Granting BRENTCO AERIAL PATROL 

### Request Would Be In The PublicInterest; ThatIs, How ItWould BenefitThePublicAs A Whole. Granting the present Petition will further the public interest by allowing BRENTCO AERIAL PATROL to safely, efficiently, and economically perform aerial video and photography

------- --- -- ... Pipelines and pipeline right ofways. Additionally, use of the DJI Phantom 3 UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of BRENTCO AERIAL PATROL

. proposed operation of the DJI Phantom 3 UAS will be realized without implicating any privacy issues.



### 1. ThePublicWillBenefitFromDecreased Congestion Of

### TheNAS. The DJI Phantom 3 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
12amount ofmanned aircraft needed to perform aerial acquisitions, an exemption allowing the use ofa DJI Phantom 3 UAS would reduce the amount ofmanned aircraft in the NAS, reduce noise and air**pollution~** as well as increasethe safety oflife andproperty inthe air and onthe 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 3 U

AS 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 airtraffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. ThePublicWill BenefitFromTheSafetyAnd Efficiency 

### OfTheDJIPhantom3 UAS. Conducting aerial acquisitions with the DJI Phantom 3 UAS, instead ofmanned aircraft, will greatly benefit the public by drastically reducing the levels ofair and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, the DJI Phantom 3 UAS 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 andphotography, while burning approximately 20-30 gallons per hour ofleaded aviation fuel. The DJI Phantom 3 UAS, while reducing the carbon footprint ofaerial acquisitions, also eliminates noise pollution, as the UAS are propelled bybattery powered electricmotors, ratherthan an internal combustionengine. By using the DJI Phantom 3 UAS to perform aerial acquisitions, the substantial risk to life and property inthe air and onthe ground, which isusually associated with traditional manned aircraft flight operations, will be substantially reduced orcompletely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI Phantom 3 UAS (weighing approximately 2.8 pounds at their maximum gross weight with diagonal dimension of 23.2 inches, and with no fuel on board), has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan ofapproximately 42 feet, a length of34 feet, and a fuel capacity of 180 gallons). 3. PerformingAerialVideo and PhotographyOperationsWithTheDJIPhantom3 UAS WlllBenefitTheEconomy. 

### In addition to being safe and efficient, the DJI Phantom 3 UAS are also an economical alternative to using manned aircraft to conduct similar aerial operations. As**sue~** operation of the DJI Phantom 3 UAS will allow United States based companies, like' BRENTCO AERIAll PATROL •, to remain competitive and contribute to growth ofthe U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency ("EPA") regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery powered DJI Phantom 3 UAS is one such technology that not only allows companies greater operational

13

,.flexibility compared to manned aircraft, but provides such flexibility without the high operational cost ofatraditional manned aircraft. By operating the DJI Phantom 3 UAS, companies such as BRENTCO AERIAL PATROL can remain competitive and profitable, and therefore, provide greaterjob stability to employees and contractors, which will ultimately contribute to growth ofthe U.S. economy. Improved financial performance ofU.S. companies, through commercial use ofthe DJI Phantom 3 UAS, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both inthe United States and abroad.



### 4. ThereAreNo PrivacyIssues. Similar to the manned aerial acquisition flight operations that have been conducted for decades, BRENTCO AERIAL PATROL proposed operation of the DJI Phantom 3 UAS will not implicate any privacy issues. Specifically, the DJI Phantom 3 UAS will be operated only in compliance with operating documents (i.e., 1 BRENTCO AERIAL PATROL' Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 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.P.R.§ 91.119. 

### E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A**Le!~l** 

### ()fSafety At Least EqualTo That Provided By The RuleFromWhich BRENTCO AERIAL PATROL 

### Seeks Exemption. 1. Reasons Why The DJI Phantom 3 UAS Meet The Conditions Of 

### The FAA Modernization andReform Act of2012 (FMRA) Section 333. In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, BRENTCO-AERIAL PATROL operation of the DJI Phantom 3 UAS meet the conditions ofPMRASection 333, and will notrequire an airworthiness certificate inaccordance with 14 C.P.R. Part 21, SubpartH. 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 ofthe NAS orthe public, orotherwise pose a threat to national security. Specifically, PMRA Section 333 states the following, inpart: (a) In General.--Notwithstanding any other requirementof this subtitle, andnot later than 180days after the date of enactment of thisAct, the Secretary of Transportation shall determine 

### ifcertain unmanned aircraft systems may operate safely in the national airspace system before completion of theplan and ru/emaking required by section 332 of thisActorthe guidance requiredbysection 334 of thisAct.

14(b) Assessment ofUnmannedAircraft Systems.--In making the determination under subsection (a), the Secretary shalldetermine, ata minimum-- (1) which types of unmannedaircraftsystems, 

### if any, as a result of their size, weight, speed, operational capability, proximity to airports andpopulated areas, andoperation within visual line of sightdo notcreate a hazardto users ofthe national airspace system or the public orpose a threat to national security; and (2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 oftitle 49, United States Code, is required for the operation ofunmanned aircraft systems identified underparagraph (1). (c) Requirementsfor Safe Operation.--/fthe Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirementsfor the safe operation ofsuch aircraftsystems in the nationalairspace system. In seeking this**exemptio~** BRENTCO AERIAL PATROL submits that the DJI Phantom 3 UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics ofthe DJI Phantom 3 

### VAS; (b) the pilot certification requirement; and (c) the specific operatinglimitations.



### a. TheSpeeifications OfTheDJIPhantom3 UAS DemonstrateIts Safe Characteristics. The DJI Phantom 3 UAS does not create a hazard to users oftheNAS orthepublic, orotherwise pose a threatto national securityconsideringits size, weight, speed, and operationalcapability. i.

### Technical Specifications OfTheDJIPhantom3 UAS. The technical specifications ofthe DJI Phantom 3 

### VAS are set forth by the DJI Phantom 3 User Manual, attachedhereto as Appendix A. ii.

### TheDJIPhantom 3 UAS GlobalPositioningModes EnableTheUAS ToRemain Wi.hinA Defined OperationalArea. The DJI Phantom 3 

### VAS maybeoperated inbothmanual and global positioning flight modes. A complete description ofthe flight and navigational modes ofthe DJI Phantom 3 

### VAS is provided at pages 11 ofthe DJI Phantom 3 UserManual attached hereto as Appendix A. iii.

### TheDJIPhantom3 UAS AreDesigned ForAutomaticReturnToHomePoint OrHoverInTheEventOfLoss OfTheControlLinkOrNavigation. When the Control Link is lost, the DJI Phantom 3 UAS will remain stationary, in flight, for 3 seconds ormore. If, after 3 seconds, the DJI Phantom 3 UAS does notreacquire control link data from the GCS, the UAS will assume that the Control Link is lost and the will return to the home position (i.e., failsafe mode) viaGPS, and will descend tothetakeoffpositionand shutdown.

15A complete description ofthe Failsafe Functions ofthe DJI Phantom 3 UAS are set forth at pages 12 through 14 ofthe DJI Phantom 3 User Manual, attached hereto asAppendix A. 

### iv. The DJI Phantom 3 GCS And Its Operation. A complete description ofthe operation and specifications ofthe DJI Phantom 3 GCS and flight control software is provided at pages 23 through 29 ofthe DJI Phantom 3 User Manual. DJI Phantom 3 UserManual is attached hereto as Appendix A. 

### b. FlightOperations OfDJIPhantom 3 UAS Is Limited To The Line OfSight OfA Certificated Pilot in Command With ASafety Observer. The ALTEKMEDIA GROUP video production staffwill be the onlypersons to act as a pilot in command (PIC) ofthe DJI Phantom 3 UAS. Additionally, a safety observer will assist him at all times during flight time.


### c. Flights OfDJI Phantom 3 UAS Will Be Conducted PursuantTo Specific Operating Limitations. In seekingthisexemption, BRENTCO AERIAL PATROL proposes to commercially operate DJI Phantom 3 UAS forthe specialpurpose ofconducting aerial video andphotography overcertain areas ofUnited States, pursuant

### to the following specific operatinglimitations. 1. Operations authorized by this grant ofexemption will be limited to the following aircraft described in the operating documents, rotorcraft UAS weighing less than 

### 55 pounds maximum gross weight: DJI Phantom 3 Unmanned Aircraft Systems. Proposed operations ofany other aircraft will require a new petition or a petition to amendthis grant.

2. UAS operations under this exemption will be limited to conducting operations for thepurpose ofaerial video and photography. 3. The UAS may notbe flown atanindicated airspeed exceeding 20knots. 4. The UA mustbe operated at an altitude ofno more than 400 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 feetAGL. 

### 5. The UAS must be operated within visual line of sight (VLOS) ofthe 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.

16-------------------.

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 ofthe flight. The PIC must ensure that the SO can perform the functions prescribed in the operating documents. 8. The SO must not perform any otherduties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is not permittedtooperatethe cameraorotherinstruments. 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 inthe grant ofexemption 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. Ifthe 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 ofexemption. The FAA's UAS Integration Office (AFS-80) may be contacted if questions arise regarding updates or revisions to the operating documents.

10. Priorto each flight the PIC must inspect the UAS to ensurethat itis in a condition for safe flight. Ifthe inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operatinguntil the necessary maintenance has beenperformed 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 beproperly documented inthe aircraft records.

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 anentryinthe aircraftrecords. 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 ofthe operating documents. 13. The operator must follow the UAS manufacturer's aircraft/component, maintenance, overhaul,..replacement, inspection, and life limitrequirements.
1714. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status ofreplacement/overhaul component parts must be noted in the aircraft records, including total time in service, description of work accomplished, andthe signature ofthe authorizedpersonreturning the UAS to service. 15. Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins. 16. The authorized person must make an entry in the aircraft record ofthe corrective actiontakenagainstdiscrepancies discoveredbetween inspections. 17. The PIC must possess at least a private pilotcertificate and at least a currentthirdclass 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 howthe UAS will be operated underthe 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. 

### § 61.5l(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.P.R.§ 91.119. 19. 

### VAS 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 ofoperations. Flights under special visual flight rules (SVFR) are not authorized. 20. The UA may not operate within 

### 5 nautical miles ofan airport reference point as denoted on a current FAA-published aeronautical chart unless a letter ofagreement with that airport's management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator's COA. The letter of agreement with the airport management must be made available to the Administrator uponrequest. 21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud orwhen visibility is less than 3 statute miles from thePIC. 22. Ifthe 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 withthe operating documents.
1823. The PIC must abort the flight in the event ofunpredictedobstacles oremergencies inaccordance withthe 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% batterypowerremaining. 25. The operator must obtain an AirTraffic Organization (ATO) issued Certificate of Waiver orAuthorization (COA) priorto conducting any operations underthe 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 inaccordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponderrequirements. 26. All air(fraft operated in accordance withthe exemption mustbe identifiedby serial number, registered in accordance with 14 C.P.R. part 47, and have identification (NNumber) markings in accordance with 14 C.P.R. part 45, Subpart C. Markings must be as large aspracticable. 27. Before conducting operations, the radio frequency spectrum used for operation and control ofthe UA must comply with the Federal Communications Commission (FCC) orother appropriate government oversight agency requirements. 28. The documents required fewer than 14 C.P.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station ofthe UAS any time the UAS is operating. These documents must be made available to the Administrator or any law enforcement official uponrequest. 29. The UA must remain clear and**yi~ld** the right ofway to all manned aviation operations and activities at all times. 30. The UAS maynot 

### be operatedbythe PIC from any moving device orvehicle. 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 ofan 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 ofthe UA, flight operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/controller ofsuch vessels, vehicles or structures has granted permission and the PIC has made a safety assessment ofthe risk of operating closer to those objects and-determined that it does not present an undue hazard, and;
19c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present anundue hazardtothose personsper §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. 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 ofthe operational area as defined bythe applicable COA must bereported 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 ontheNTSB Web site: www.ntsb.gov.

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would NotAdversely Affect Safety. BRENTCO AERIAL PATROL submits that the equivalent level ofsafety established by Section 61.113(a) and (b) will bemaintained because no PIC will be allowed to operate the DJI Phantom 3 UAS unless that PIC has demonstrated, by meeting minimum flight"hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering BRENTCO AERIAL PATROL proposed area of operations, and the operating limitations set forth-above; the parallel nature of private pilot aeronautical knowledge requirements to those ofcommercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI Phantom 3 UAS, BRENTCO AERIAL PATROL GROUP submits that the additional manned airmanship experience 

### _of a cotplllercially certificated pilot would not correlate to the airmanship skills necessary for BRENTCO AERIAL PATROL 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 Nos. 11062, 11063, 11064,11065,11066, 11067, 11080,11109, 11110, 11112, 11136, 11138, 11150, 11153,11156,11158,11159,11160, 11161). BRENTCO AERIAL PATROL will not allow any PIC to operate the DJI Phantom 3 UAS unless that PIC has demonstrated, by meeting minimum**flight~hour** requirements or the DJI Phantom 3 UAS training and currencyrequirements, thatthe PIC is able to safely operatethe DJI Phantom 3 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 andlogged, in a mannerconsistentwith 14 C.F.R. § 61.5l(b), 25 hours oftotal time**~.a** UAS rotorcraft pilot (with a minimum of

### 5hours ofthose


### 20hours as a UAS pilot operatingthe same make and model ofUAS to be usedfor operations under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings inthepreceding90 days (forcurrencypurposes}. 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 BRENTCO AERIAl. PATROL 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 ofmotion picture filming (or similaroperations), the PIC musthave accumulated and logged, in a manner consistent with 14 CFR 61.5l(b), 25 hours oftotal 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 of5 hours as a UAS pilot operating the same make and model ofUAS to be used for operations under the exemption. For clarification, the FAA considers these minimumhourrequirements to be inclusive ratherthanadditive; i.e. 5 hours make andmodel time may be included in the 10 hours ofmulti-rotortime and the 10 hours may be included in the total 25 hours ofUAS 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 ExemptionNo. 11062 are appropriate topractice andbuildproficiency 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 accomplishtherequired flight time. Duringtraining, proficiency, and experience-building flights the PIC is required to operate the UA with appropriate distances in accordance with 14 C.F.R91.119.
ExemptionNo. 11138 at page 15. Accordingly, BRENTCO AERIAL PATROL will ensure safe operations by not allowing any PIC to operate the DJI Phantom 3 UAS unless that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 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 All Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety.

21**--------~----~--** ---

The equivalent level ofsafetyestablished by Section 91.7(a) will be maintained because prior to every flight, BRENTCO AERIAL PATROL will ensure that the DJI Phantom 3 UAS is in an airworthy condition based upon the VAS's compliance with its operating documents and as stated inthe conditions and limitationsherein. Additionally, the FAA has previously granted relief from Section 91.7(a) specific to 

### VAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 

### llllO, 11112, 11136, 11138, 11150, 11153,1115.6,11157,11158,11159,11160, 11161).

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety. The equivalent level of safety established by Section 91.121 will be maintained because the altitude information ofthe DJI Phantom 3 UAS will be provided to the PIC via GPS equipment and a radio communications telemetry data link, which downlinks from the 

### VA to the OCS for active__monitoring ofthe flight path and altitude. This altitude information, combined with The BRENTCO AERIAL PATROL's operation ofthe DJI Phantom 3 UAS within visual line ofsight, at orbelow 500 feet AGL, will ensure a level ofsafety 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 initiationpoint isautomaticallyestablishedbythe UAS atground level. The FAA has previously granted relieffrom 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 OfSection 91.151(b) Would Not Adversely Affect Safety. A grant ofthis exemption would ensure an equivalent level ofsafety established by 14 C.F.R. Section 91.151(b) as a result of(1) the technical specifications ofthe DJI Phantom 3 UAS; (2) the limitations on the proposed flight operations; and (3) the location ofthe proposed flight operations. Accordingly, BRENTCO AERIAL PATROL

.will ensure that it will safely operate the battery powered DJI Phantom 3 UAS during daylight hours in VFR conditions, with enough batterypowerto fly for a total duration of23 minutes. Here, as in Exemption No. 11109, the technical specifications ofthe DJI Phantom 3 UAS; the limitations on the proposed flight operations; and the location ofthe proposed operations, will ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Phantom 3 UAS provide audible andvisual warnings tothe PIC at the GCS when the UAS experiences low battery voltage, the ftrst warning occurring at approximately 33%remaining**bat!~ry** power, and again at approximately 10% remaining battery


### 22power. At the critically low battery level, the DJI Phantom 3 UAS will descend and land automatically. Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations ofthe UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).



### 6. Reasons Why An Exemption From The Requirements Of Sections 91.40S(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, BRENTCO AERIAL PATROL 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)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) will be met because BRENTCO AERIAL PATROL' will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., BRENTCO AERIAL PATROL Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual). Furthermore, BRENTCO AERIAL PATROL ·will document and maintain all maintenance records for the DJI Phantom 3 UAS. Since theJ)JI Phantom 3 UAS will be Inspected as prescribed by the operating documents, BRENTCO AERIAL PATROL will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(l), and 91.409(a)(2). A copy of the DJI Phantom 3 User Manuals are attached hereto as Appendix A and B; a copy ofthe DJI Phantom 3 UAS Maintenance LOG is attached hereto as Appendix C. Likewise, the exemption sought will not adversely affect safety because BRENTCO AERIAL PATROL 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 ofsafety established by Sections 91.407, 91.417(a) and 91.417(b), because allmaintenance ofthe DJI Phantom 3 UAS will be performed by trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log. Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected whenthe technical characteristics and operatinglimitations ofthe UAS are considered.
23Inconsideration of' BRENTCO AERIAL PATROL

.proposed operating limitations, theoperating documents, and the technical aspects ofthe DJI Phantom 3 UAS, BRENTCO AERIALPATROL submits that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(l) 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. TheFAA May PrescribeAny OtherConditions ForSafe Operation. In accordance with Section 333 ofthe FAA Modernization and**Refof!t.!_~ct** of 2012 (FMRA) and 14 C.F.R. 

### § 21.16 entitled Special Conditions,

. BRENTCO AERIAL PATROL 'requests that the FAA prescribe special conditions for the intended operation ofthe DJI Phantom 3 UAS, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.15l(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation ofthe 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 ofthe NAS orthepublic, or otherwise pose athreatto 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 ofthe UAS intheNAS. Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. 

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



### 2461.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) 

### & (b).


### • A SummaJ1That Can

__**~e** 

### Published In The Federal Register, stating: The Rules FromWhich BRENTCO AERIAL PATROL ,

### Seeks Exemption:

BRENTCO AERIAL PATROL 

### seeks exemption from the requirements of14 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)(l) & 

### (a)(2), and91.417(a) & 

### (b). 

### A Brief Description Of The Nature Of The Exemption Seeks: BRENTCO AERIAL PATROL



### This exemption will 

### permit BRENTCO AERIAL PATROL 

### to commercially operate an Unmanned Aircraft System (UAS) for the purpose qfconducting aerial video and photography overcertain areas of the UnitedStates.


### • Any Additional Information, Views, Or Arguments Available To Support BRENTCO AERIAL PATROJ. •:; 

### Request.

ThisPetitionis made pursuanttothe FAAModernizationand Reform Act of2012 (FMRA) Section 333, which directs the Secretary of**T!_an~p()rtation** to determine ifcertain UAS may operate safely inthe NAS. As such, BRENTCO AERIAL PATROL ,request for exemption may be granted pursuant to the authority ofFMRA Section 333 and 14 C.F.R. Part 11, as set forth above. FMRA Section 33 3 sets forth the requirements for considering whether a UAS will create a hazard to users ofthe NAS or the public, or otherwise pose a threat to national security; and further, providesthe authority for suchUAS to operate without airworthiness certification. As discussed in detail above, BRENTCO AERIAL PATROL will operate the DJI Phantom 3 UAS safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwisepose a threat to national security. 

### CONCLUSION As set forth herein, BRENTCO AERIAL PATROL seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA), which will permit safe operation of the DJI Phantom 3 UAS commercially, without an airworthiness certificate, for the limited purpose ofconducting 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 BRENTCO AERIAL PATROL to safely, efficiently, andeconomically operatethe DJI Phantom 3 UAS commerciallywithinthe NAS

. 

# .. 25WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of2012, Section 333, BRENTCO AERIAL PATROL ,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)(l), 91.409(a)(l) & (a)(2), and 91.417(a) 

### & (b), andpermit Leading Edge to operate the DJI Phantom 3 UAS commercially for the purpose ofconducting aerial video and photography over certain areas ofthe United States. Dated: January 4, 2016 Respectfully submitted,

Rick Vincent President Brentco Aerial Patrol Inc.
5668 Perry Hills Dr. Canton, Ohio 44706 330-417-7007 Vincent@gobrainstorm.netTwo DJI Phantom 3s to be operated. Registration numbers N3334V and N3335V. Operations initially in the vicinity ofSullivan Indiana 47882 (34V), and Lima Ohio
45806 (35V).FORM APPROI/ED OMS No. 2120·0042
UNITED STATES OF AMERtCA DEPARTMENT OF TfiANSPORTATlON FEDEI'IAL AVIAT10N AOMINISTAATIOIII-MIKE MOHROMEY AEROIIAUTICAL CENTEf! AIRCRAFT REGISTRATION APPUCATION UNITED STATES 

# N REGISTRATION NUMBER 

### 3335V
& MODEL 

### Phantom 3 Standard P5ADCH13060149 TYPE OF REGISTRATION (Check one boX) 0 t Individual 0 2. Partnership**~** 3. Corporation 0 4. Co-owner CERT ISSUE

NAME OF APPLICANT (Person(s) Shown on evidence of ownership. If individual. give last name. first name. and


### Brentco Aerial Patrol, Inc.

5868 Perry Hills DR SW Number and street**------------------~-·-·----·------------+···----·---1** P.O. SOX: CITY ZIP 

### Canton Ohio
0 CHECK HERE IF YOU ARE ONLY REPORTiNG A CHANGE OF Aljji)RI:SS ATIENTION1 Read the following statement before signing this apJrliclLrtioin. This portion MUST be completed. A lalse or (lishOnest answer to any question in this appli<'.ation may be grounds for punishmernt by fine and I or i"o/!pri!;IOOflnent (U.S. Code, Tille 18, Sec. 1001). CERTIFICATION CERTIFY: (1) That the above ailcralt is owned by the undersigned appliCant. who is a citizen {including OQrporatiOns)

of the Unl!e<:l States. (For voting trust, give name of trustee:---------·-----------·----··,'-

..--·- CHECK ONE AS APPROPRIATE:
a. 0 A resident alien, with alien registratiOn (Form 1-151 or Form 1·551) No. ----·-- --···-------!----··· b. [.] A non-citizen corporation O<ganize<:l and doing buSiness under the laws of and satd a!<crafl <S OO:sed and primarily lJ.Seld 'r the \.!Med St!<leS**~-"""·**.........**'""""'""'.....,...,_,..~-~--......-.----,_,--...,** (21 That the aircraft is 1'101registered

### under'lhe

### iaws ·G'f anY**~·**couriuY; and (3e) That legal evidence of ownership is attached or hes been filed wl!h the Federal Aviation Administration. or:12/23/2015



### Type Reservation ModeS Code Reserved Date RenewalDate PurgeDate Pending Number Change DateChange Authorized Reserving Party Name Street City State Zip Code County Country FAA Registry- Aircraft- N-Number Inquiry 

# FAA REGISTRY N-Number InquiryResults

N3335V has Reserved/Multiple Records



### Fee Paid 50722017 12/08/2015 None 01/08/2017 None
None 

## Reserved N-Number

BRENTCO AERIAL PATROL INC 5668 PERRY HILLS DR SW CANTON OHIO 44706-3340 STARK UNITED STATES 

## DeregisteredAircraft Deregistered Aircraft I of 1

SerialNumber ManufacturerName
Model 15076464 

### CESSNA 150M YearManufacturer 

### None Reason for Cancellation 

### Destroyed Type Registration 

### Corporation"' Aircraft Description**Certm~t~.lss~**

### ...Qate Mode 

### S Code (base 

### 8/ oct) Mode S Code (base 16 I hex) CancelDate ExportTo 

### OllHV1990 50722017
A3A40F 03/09/1996 None

### sUA and UA Notarized Statements

N-number: N3335V

. UAS Class: o Airship, o Glider, o Airplane, • Rotorcraft, o Hybrid Lift, o Ornithopter Manufacturer/Builder: 

### OJJ, (Show fuH legal name ofaircraft mal}ufaotureror bUilder).·'·

. ' L l"" \.

## Seri~l Number.

## P.5A~CH1.~0~0~'r!' 

# .X':.'**···t·~ax Ta~eotei~ht:**  2.68

. tbs. Engme Type: • Electnc; o**2,{;~~9i~flt!>iii}!o4~Witeotptocatmg;** 0 Tutbojet- Fan/Prop/Shaft/Jet Numberof**Engines:~.** The Unde[!igned Owner Certifies (ref. 14 CFR § 47.33 (a) and (b), ownership requirements) Select and complete one ofthese statements or compose a statement for your situation addressing these 1ssues

. _L1)

..I**purdBSedtbe....,utlf.~~Gl~ Zf~..,.···~·~·~·.**  from a retail store, catalog orinternet vendor named CopterShoS:r/Amazon.CQm located in (city, state, country) 19510 144th Ave NE, Suite B-7 Woodinville Washington US Q8Q72 , on (date) 11/02/2015

. A manufacturer's bill ofsale was not available at the time of purchase, and the (receipt I invoice I other evidence) (is**enclos~** I notavailable) to confirm the purchase. _2) I built the small unmanned aircraft described above from a prefabricated kit. The kit bill ofsale from the manufacturerto the undersigned or other evidence to prove the transaction is enclosed. _3) I buift the small unmanned aircraft described above using salvaged, fabricated, miscellaneous, spare
or individually purchased parts. _4) The small unmanned aircraft described above was manufactured new by the undersigned from standardized parts according to a proprietary design. _5) I purchased the used aircraft described above, the Bill of Sale signed by the seller is enclosed. _6} I purchased the used.aircraft described above from (seller's full name)-------- located in (city, state, country)----------------- I am unable to produce the required bill of sa!e

The following item(s) are attached as proofthat the transaction did take place, (list item(s)) Amazon.com Order Number: 107-2677466-0636217 Receipt ofCopterShop purchase.

The undersigned affirms the information and statements provided herein are correct, and the undersigned is the aircraft's rightful owner.
..

Rrl'>ntt'n A,.ri<:>l P<:>trnl lnt' I r.:r.,,nrv I 1\Aill,.r(Notary Public or individual autholized under local lawto administeroaths) (5eal required if applicable in your State.)No certificate may be issued unless a completed application form has been received (14 C.F.R. 91. 101. and 105).

# ~ From Approved: O.M.B. No.2120-0027 08/31/2008 US Department ofTransportation APPLICANTS -DO NOT USE THESE SPACES Federal Aviation Administration Region 

# I Date APPLICATION FOR Action**;;·~::::·::** OApproved 

### 0 Disapproved

- "Explain under "Remi;lrks" CERTIFICATE OF WAIVER Signature ofauthorized FAA representative 

### :

... : OR AUTHORIZATION :·.,) '··:' '., .,f,,)' INSTRUCTIONS fighting equipment The applicant may also wish·lb submit'... Submit this application in triplicate (3) to any FAA Flight Standards district office. photographs and scale diagrams as supplementaJ:roaterial to assist in the FAA's evaluation of a particular site.· Applicants requesting a Certificate ofWaiver orAuthoriza- Application for a Certificate ofWaiver orAuthorization must tion for an aviation event must complete all the applicable be submitted 45 days prior to the requested datl!'i:'of the items on this form and attach a properly marked 7.5 series event. Topographic Quadrangle Map(s), published by the U.S. Geological Survey (scale 1:24,000), ofthe proposed opera!- Applicants requesting a Certificate ofWaiver orAuthorizaing area. The map(s) must include scale depictions ofthe tion for activities other than an aviation eventwill complete flightlines, showlines, race courses, and the location ofthe items 1 through 10 only and the certification, item 17, on the air event control point, Police dispatch, ambulance, and fire reverse. 1. Name of organization 2. Name of responsible person 

# 13 V2&

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3. Permanent House number and street or route number City State and ZIP code Telephone No.

mailing



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4. State whetherthe applicant orany of its principal officers/owners has an application for waiver pending at any other office ofthe FAA }lo
5. State whether the applicant orany of its principal officers owners has ever had its application forwaiver denied, orwhether the FAA has everwithdrawn a waiverfrom the applicant orany of its

principal officers/owners. 

# No

6. FAR section and numberto be waived ;.yc.&;e. ,j"'f4•7w<

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### /7 "'tl/? ' 7. Detailed description of proposed operation (Attach supplementifneeded) A -1-hte·h 

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8. Area at**operat~.fLOcatlon,** a111tuaes, etc.) ··:;uv 

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9a. Beginning (Date andhour) b. Endmg (Date andhow) O{J.DAJ tijJj}f'DOtrt( 10. Aircraft Pilot's Name Certificate number Home address make**a~~** model and rating (Street,**~~~ty,** State) (b) (C) {) ::S1 fiJ,,..tvf,:.tm} Grfc litl/(i£l?_ '3& :J. 7 

### ::r.:rs- :;.i'7 

## s.c:R- l.:ZSc.u**_")..ft~t~d/1.1''** L i.l**'~'** 111 , / .::T J.JCf ,<.uil <'I.J4i..) :T,A/ OSI**f'll~m** 3' v**$(,~ 71~1**  ;). ()if

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FAA Form 7711 -2 (8-08) Supersedes Previous Edition

## .... ITEMS 11 THROUGH 16 TO BE FILLED OUTFOR AIR SHOW/AIR RACE WAIVER REQUESTS ONLY. 11. The air event will be sponsored by:

12. Permanent House number and street or route number City State and ZIP code Telephone No. mailing address
13. Policing (Describe provisions to be made forpolicing the event.)

14. Emergency facilities (Markall that willbe available at time andplace ofairevent.) 0 Physician 0 Fire truck D Other

- Specify 0 Ambulance 0 Crash wagon
15. AirTraffic control (Describe methodofcontrolling traffic, including provision forarrivalanddeparlure ofscheduledaircraft.)

16. Schedule of Events (include arrivaland deparlure ofscheduledaircraftandotherperiods the airporlmaybe open.)
Hour Date Event (a) (b) (c)

Ifsufficientspace is notavailable, the entire schedule ofevents maybe submittedon separate sheets, in the orderandmannerindicatedabove.

## PleaseRe~ The undersigned applicant accepts full responsibility for the strict observance ofthe terms ofthe Certificate of Waiver or Authorization, and understands that the authorization contained in such certificate will be strictly limited to the above described operation. 17. Certification -I CERTIFY that the foregoing statements are true. Date



# \**,,.~}**

# \b

# WVW~tbMRemarks

FAA Form 7711-2 (8-08) Supersedes Previous Edition