UNITED STATES OF AMERI CA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

WASHI NGTON, DC

Regulatory

Docket No. _______________

**IN THE MATTER OF THE PETITION FOR EXEMPTION OF: GARY BREVIG**  **FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF** 

**TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1),**  **91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF DJI**  **Inspire 1 UNMANNED AIRCRAFT SYSTEMS** 

**PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012**  **(PUBLIC LAW 112** 
**- 95)** **Submitted on May 5, 2015** GARY BREVIG 11090 183rd Cir NW Elk River MN 55330
952

- 278

- 2402 Gary b@DennisonTech.com

**TABLE OF CONTENTS** Page GLOSSARY OF ABBREVIATIONS ..................................................................................3

SUMMARY ..................................................................................................................... .....4

IN TRODUCTION AND INTERESTS OF PETITIONER ................................................... 4

BACKGROUND ....

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

BASI S FOR PETITION........................................................................................................ 5NAME AND ADDRESS OF PETITIONER.......................................................7

THE SPECI FI C SECTI ONS OF 14 C.F.R. FROM WHI CH GARY BREVIG SEEKS EXEMPTI ON........................................................................8

THE EXTENT OF RELIEF GARY BREVIG SEEKS AND THE REASON

GARY BREVIG SEEKS THE RELIEF........................... ............12

THE REA SONS WHY GRANTING GARY BREVIG’S REQUEST WOUL D BE IN THE PUBLIC INTEREST .........................................................15 THE REASONS WHY GRANTING THE EXEMPTI ON WOULD NOT ADVERSELY AFFECT SAFETY ......................................................................... 18 SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGI STER.............33 ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS

AVAILABLE TO SUPPORT GARY BREVIG’S REQUEST............34 CONCLUSION .................................................................................................................. . 35
APPENDI CES........................................................................................36

**GLOSSARY OF ABBREVI ATIONS**  AGL Above Ground Level NAS National Airspace Sy stem AOI Area of Interest
ATC Air Traffic Control
ATO Air Traffic Organization AV Aerial Vehicle CFR Code of Federal Regulations COA Certificate of AuthorizationFAA Federal Aviation

Administration
FAR Federal Aviation Regulation GCS Ground Control Station GPS Global Positioning Sy stem
LOL Loss of Link MSLMean Sea Level

NOTAM Notice to Airman
PI C Pilot in Command Section 333 Faa Modernization and Reform act of 2012 (FMRA) SO Safety

Observer SOP Standard Operating Procedures UA Unmanned Aircraft UAS Unmanned Aircraft Sy stem VFR Visual Flight Rules VLOS Visual L ine of Sight VMC Visual Meterological Conditions VTOL Vertical Takeoff and Landing

**SUMMARY** G ar y B revig seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft Sy stem pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Gary

Brevig to operate an Unmanned Aircraft Sy stem (UAS) for the commercial purpose of conducting aerial video and photography of construction sites, real estate, farmland, and landscape over certain areas of the United States.

**INTRODUCTION AND INTERESTS OF THE PETITIONER** Gary Brevig provides his clients with expertise and knowledge in advanced tec hnologies and solutions to increase efficiency , productivit y and effectiveness. Gary Brevig is an instrument rated pilot with nearl y 100 hours of fl yi ng experience. He has over 10 years recreational/hobb y experience in all aspects of aerial video and photo graphy . The objectiveof Gary Brevig and his aerial operations is to safely provide high qualit y i maging for a variet y of commercial, public, and residential uses, specificall y targeting:

• Agriculture

• General aerial still photos

• Wildlife population surveys

• Real Estate marketing

• Motion Picture Filming

• Aerial inspections of public and private Structures.

• Search and Rescue operations

**BACKGROUND** Unmanned Aircraft Sy stems: DJ I Inspire 1 UASs Gary B revig seeks an exemption to operate DJIs ys tems for compensation or hire within the NAS. The DJI Inspire 1 is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone s ys tems. The DJ I Inspire 1 has a maximum gross weight of approximately 2936 g with battery , while total measurements are 438x461x301mm , and a maximum speed of approximately 22m/s

. The DJ I Inspire 1 UA is equipped with four main rotors, driven by Lithium Poly

mer battery

powered electric motors. The DJ I Inspire 1 UA that will be operated by G ary Brevig will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft , as well as 14 C.F.R Part 47, Aircraft Registration , and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking

.

**BASIS FOR PETITION**Petitioner, Gary Brevig, pursuant to the provisions of the Federal Aviation Regu lations (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 DJI Inspire 1 UA in the National Airspace Sy stem (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). In consideration of the speed, weight, size, and limited operatin g area associated with the unmanned aircraft and its operation, Gary Brevig’s operation of the DJ I Inspire 1 UA meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingl y, Gary Brevig 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. G ar y Brevig submits that the requested relief is proper since an equivalent level of safet y will be ensured. Gary

Brevig will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the metho ds, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Lo g, and DJI Inspire 1 Instruction Manual). Furthermore, G ary B revig will document and maintain all maintenance records for the DJ I Inspire 1 UA. Relief from certain requirements of Section 61.113(a) and (b), entitled Private Pilot Privileges and Limitations: Pilot in Command, is requested b y G ary B revig to the extent necessary to allow a Pilot in Command (PI C) holding a private pilot or higher leve l certificate, as well as an airman medical certificate, and who has demonstrated, b y meeting minimum flight

- hour and currency requirements, that the PI C is able to safely operate the DJI Inspire 1 UA in a manner consistent with this exemption, including ev asive and emergency

maneuvers and maintaining appropriate distances from people, vessels, vehicles, and structures. G ar y B revig seeks relief from Section 91.7(a), entitled Civil Aircraft Airworthiness , because the DJ I Inspire 1 UA does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Gary Brevig submits that he will ensure that the DJ I Inspire 1 UA is in an airworth y condition, prior to every flight, by determining that the UA is in compliance with the o perating documents (i.e., Monthly Maintenance Log, and DJ I Inspire 1 Instruction Manual), and that the aircraft is in a condition for safe flight. G ar y B revig also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , a s the DJI Inspire 1 UA will not have a t ypical barometric altimeter onboard. However, altitude information of the DJ I In spire 1 UA will be provided to the PI Cvia Global Positioning Sy stem (GPS) equipment and radio communications telemetry data link, which d ownlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with Gary Brevig’s operation of the DJI Inspire 1 UA within visual line of sight, at or below 500 feet AGL, will ensure a level of safet y equivale nt to Section 91.121. Additionally , G ary B revig seeks an exemption from the requirements of Section 91.151(b), entitled Fuel Requirements for Flight in VFR Conditions

. Gary Brevig submits that safety

will not be affected by

operation of the DJ I Inspire 1 UA during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery

power to fl y for a total duration of approximately 12.5 minutes to the first point of intended landing and, assuming normal cruising s peed, to fl y after that for at least 4.5 minutes. In accordance with 14 C.F.R. § 11.81, G ary Brevig provides the followi ng information in support of his petition for exemption:

**Name And Address Of The Petitioner.**
The name and address of the Petitioner and point of contact is: GARY BREVIG 11090 183rd Cir NW Elk River MN 55330
952

- 278

- 2402 Gary b@DennisonTech.com**The Specific Sections Of 14 C.F.R. From Which G**  **ary B**  **revig Seeks Exemption.** 

**1. G ary**  **B revig**  **Seeks Exemption from**  **the Requirements**  **of Section**  **61.113(a) and**  **(b).** Section 61.113, entitled Private Pilot Privileges and L imitations: Pilot in Command, subsections (a) and (b) prescribe the following, in relevant part: (a) No person who holds a private pilot certificate may act as a pilot in command (PI C) of an aircraft that is carrying passengers or propert y for compensation or hire; nor may that person , for compensation or hire, act as PI C of an aircraft. (b) A private pilot may , for compensation or hire, act as PI C of an aircraft in connection with an y business or emplo ym ent if

—(1) The flight is onl y incidental to that business or employment; and

(2) The aircraft does not carry passengers or property

for compensation or hire.
**2. G ary**  **B revig**  **Seeks Exemption From The Requirements**  **of Section 91.7(a).**  Section 91.7, entitled Civil Aircraft Airworthiness , subsection (a), states the following: (a) No person may

operate a civil aircraft unless it is in an airworthy condition.
**3. G ary**  **B revig Seeks Exemption From The**  **Requirements Of Section 91.121.** 
Section 91.121, entitled Altimeter Settings, subsection (a), states the following, in part:
(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, 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 miles of the aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure.
**4. G ary**  **B revig**  **Seeks Exemption From The Requirements Of Section 91.151(b).** Section 91.151, e ntitled Fuel Requirements for Flight in VFR Conditions , subsection

(b), states the following:

(b ) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.
**5. G ary**  **B revig**  **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 inspectio ns, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.]

**6. G ary**  **B revig**  **Seeks Exemption From The Requirements Of Section 91.407(a)(1)**  Section 91.407, entitled Operation After M aintenance, Preventive Maintenance, Rebuilding, or Alteration , subsection (a)(1), states the following: (a) No person may

operate any

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

-- (1) It has been approved for return to service b y a person authorized under § 43.7 Of this chapter.
**7. G ary**  **B revig**  **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. Gary**  **Brevig Seeks Exem**  **ption From The Requirements Of Sections**  **91.417(a) And 91.417(b).** Section 91.417, entitled Maintenance Records , subsections (a) and (b), state the following: (a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preventive maintenance, and alteration and records of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include

-- (i) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of completion of the work performed; and (iii) The signature, and certificate number of the person approving the aircraft for return to service. (2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor.(ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the time since the last inspection required b y the inspection pr ogram 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 safety directive number and revision date. I f the AD or safet y 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 currently installed engines, rotors, pr opellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 ye ar after the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retained an d transferred with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to se rvice.**The Extent Of Relief And The Reason G ary**  **B revig**  **Seeks The Relief.**

**1. Extent**  **of Relief G**  **ary B**  **revig Seeks And The Reason**  **G ary**  **B revig**  **Seeks Relief From Section 61.113(a) And (b).** Relief from Section 61.113(a) and (b) entitled Private Pilot Privileges and Limitations: Pilot in command, is requested to the extent necessary to allow a PIC holding a private pilot or higher level certificate, as well as a current and valid airman medica l certificate, and who has met certain flight

- hour and currency requirements, to conduct the proposed UAS flight operations for compensation or hire. This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a priv ate pilot may , for compensation or hire, act as PI C of an aircraft in connection with any business or employ

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

for compensati on or hire. As set forth more full y below, G ary B revig submits that an equivalent level of safet y will be maintained because no PI C will be allowed to operate the DJ I Inspire 1 UA unless that PI C has met certain flight

- hour and currency requirements, dem onstrating that the PI C is able to safel y operate either the DJ I Inspire 1 UA in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances f rom people, vessels, vehicles, and structures. Further, G ary B revig submits that all flights of the DJI Inspire 1 UA, conducted by the PI C pursuant to the grant of this Petition: (1) will be incidental to Gary Brevig’s business; and (2) will not carry p assengers or propert y for compensation or hire. **2. Extent Of Relief G**  **ary B**  **revig Seeks And The Reason G**  **ary B**  **revig**

**Seeks Relief From Section 91.7(a).**
Relief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to the extent required to all ow G ary B revig to determine that the DJ I Inspire 1 UA is in airworthy condition prior to every

flight by ensuring that the UAS is in compliance with the operating documents (i.e., Monthly Maintenance Log and DJ I Inspire 1 Instruction Manual).G ar y B revig seeks the requested relief because the DJ I Inspire 1 UA does not require an

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, G ar y B revig will ensure that the DJ I Inspire 1 UA is in airworthy condition based upon its compl iance with the operating documents (i.e., Monthly Maintenance Log, and DJ I Inspire 1 In struction Manual) prior to every flight, and further, determine that the aircraft is in condition for safe flight, as stated in the conditions and limitations below.

**3. Extent**  **of Relief G**  **ary B**  **revig Seeks And The Reason G**  **ary B**  **revig Seeks Relief From Section 91.121.** 

Relief from Section 91.121, entitled Altimeter Settings, may be required to allow flight operations of the DJ I Inspire 1 UA, which utilizes 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 re ported to air traffic control (ATC) in feet above ground level (AGL), G ary B revig seeks the requested relief because the DJ I Inspire 1 UA’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, bef ore each flight. Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply

with the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level of safet y will be maintained since the DJ I Inspire 1 UA is equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the PIC with altitude information of the UA on the heads

- up display

of the GCS.
**4. Extent Of Relief G**  **ary B**  **revig Seeks And The Reason G**  **ary B**  **revig Seeks Relief From Section 91.151(b).** 
Relief from Section 91.151(b) entitled Fuel Requirements for Flight in VFR Conditi ons, is requested to the extent required to allow flights of the battery powered DJ I Inspire 1 UA during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fl y after that for at least 4.5 minutes. G ary B revig seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered DJ I Inspire 1 UA wil l severel y Constrain the practicality of an y aerial video or still photo flight operations that G ary B revig proposes to conduct pursuant to this Petition.Significantl y, as set forth below, the technical specifications of the DJ I Inspire 1 UA, the

DJI I nspire 1 and Gary

Brevig’s proposed operating limitations, ensure that G ary B revig will safely

operate the battery

powered DJ I Inspire 1 UA during day light hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fl y for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fl y after that for at least 4.5 minutes.

**5. Extent of**  **Relief G ary**  **B revig**  **Seeks And The Reason G**  **ary B**  **revig Seeks Relief**  **From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b).** 

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) onl y apply to aircraft with an airworthiness certificate, G ary B revig requests relief from these Sections because the DJ I Inspire 1 UA does not require airworthiness certificates. As set forth more full y below, the DJ I Inspire 1 UAS meets the conditions of FMRA Section 333 for operation without an airworthiness certificate. A ccordingl y, G ary B revig will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the Monthly Maintenance Log, and DJ I Inspire 1 Instruction Manual). Furthermore, G ary B revig will document and maintain all maintenance records for the DJ I Inspire 1 UAS. **The Reasons Why Granting Gary Brevig’s Request Would Be In The Public Interest; That Is, How It Would Benefit The Public**  **As A Whole.**
Granting the present Petition will further the public interest b y allowing G ar y B revig 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 and assist area first responders

. Additionally , use of the DJI Inspire 1 UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy . Notably , the benefits of Gary Brevig’s proposed operation of the DJ I Inspire 1 UAS will be realized without implicating any privacy issues.
**1. The Public Will Benefit From Decreased Congestion Of The NAS.** The DJ I Inspire 1 UA is battery powered and serves as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery . By reducing the number of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJ I Inspire 1 UAS would reduce the number of manned aircraft in the NAS and red uce noise and air pollution, as well as increase the safet y of life and propert y in the air and on the ground. Furthermore, b y reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircr aft will be reduced. The DJ I Inspire 1 UA does not require an airport to takeoff or land. L ikewise, a reduction of manned aircraft conducting aerial video and photograph y missions would result in fewer aircraft that must be handled by

air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations.

**2. The Public Will Benefit From The Safety And Efficiency Of The DJI**  **Inspire 1 UAS.** 

Conducting aerial acquisitions with the DJI Inspire 1 UAS, instead of manned aircraft, will greatl y benefit the public by drasticall y 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, th e DJ I Inspire 1 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 t ypically utilized for aerial video and photograph y, while burning appro ximately 20

- 30 gallons per hour of leaded aviation fuel. The DJ I Inspire 1 UA, while Reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAs are propelled b y battery

- powered electric motors, rather than an interna l combustion engine. By using the DJ I Inspire 1 UAS to perform aerial acquisitions, the substantial risk to life and propert y in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantia lly reduced or completely

eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJ I Inspire 1 UA (weighing approximately 2 pounds 11 ounces at its maximum gross weight with a length of 16 inches and widths of 16 inches and with no fuel on board), has less phy sical potential for collateral damage to life and propert y on the ground, and in the air, compared to the manned aircraft that ty pically conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).**3. Performing Aerial Video and Photography Operations With The DJI**  **Inspire 1 UAS Will Benefit The Economy.** 

In addition to being safe and efficient, the DJ I Inspire 1 UA is also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJ I Inspire 1 UAS will allow United States based companies, like G ary B revig , to remain competitive and contribute to growth of the U. S. econom y. Specificall y, 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 rem ain competitive. Operating the battery

powered DJ I Inspire 1 UAS is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility

without the high operational cost of a traditio nal manned aircraft. By operating the DJ I Inspire 1 UAS, companies such as G ary B revig “Dennison Technology

Group” , can remain competitive and profitable, and therefore, provide greater job stability

to employ ees and contractors, which will ultimately co ntribute to growth of the U.S. economy . Improved financial performance of U.S. companies, through commercial use of the DJ I Inspire 1 UAS, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and all ows 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, Gary

Brevig’s proposed operation of the DJI Inspire 1 UAS will not implicate any privacy issues. Specifically , the DJ I Inspire 1 UAS will be operated onl y in compliance with operating documents (i.e., The Monthly Maintenance Log, and DJ I In spire 1 In struction Manual) which requires propert y owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, incl uding the minimum altitude requirements of 14 C.F.R. § 91.119.**The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The**  **Ex emption Would Provide A Level Of Safety At Least Equal To That**  **Provided By The Rule From Which G ary**  **B revig**  **Seeks Exemption.**

**1. Reasons Why The DJI Inspire 1**  **UA Meets The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 33**  **3.**

In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, Gary Brevig’s operation of the DJ I Inspire 1 UASmeets the conditions of FMRA Section 333, and will not require an airworthiness

certificate in accordance with 14 C.F.R. Part 21, Subpart H. Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requireme nts for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security . Specifically , FMRA Section 333 states the following, in part:

(a ) In General.

--Notwithstanding any other requirement o f this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act. (b ) Assessment of Unmanned Aircraft Systems.

--In making the determination under subsection (a), the Secretary shall determine, at a minimum

-- (1 ) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace sys tem or the public or pose a threat to national security; and

(2 ) Wh ether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1).
(c) Requirements for Safe Operation.

--If the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system.In seeking this exemption, G ary B revig submits that the DJ I Inspire 1 UAS can operate

safel y in the NAS pursuant to FMRA Section 333, as demonstrated b y: ( a) the characteristics of the DJ I Inspire 1 UA; (b) the pilot certification requirement; and (c) the specific operating limitations.

**a. The Specifications Of The DJI Inspire 1**  **UAS Demonstrates Its Safe Characteristics.** 

The DJ I Inspire 1 UAS does not create a hazard to users of the NAS or the public, or otherwise pose a threat to national securit y considering its size, weight, speed, and operational capability

.

**i. Technical Specifications of**  **The DJI Inspire 1**  **UAS**

The technical spe cifications of the DJ I Inspire 1 UAS are set forth by the DJI Inspire 1 User Manual, attached here to as Appendix A.

**ii. The DJI**  **Inspire 1 UAS Autonomous Flight And Navigation**  **Modes Enable The UAS To Remain Within A Defined Operational Area.** 
The DJ I Inspire 1 UAS may be operated in both manual and full y autonomous flight modes. A complete description of the flight and navigational modes of the DJI Inspire 1 UAS is provided at pages 25

- 35 of the DJ I Inspire 1 User Manual, attached hereto as Appendix A.
**iii. The DJI**  **Inspire 1 UAS 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 DJI Inspire 1 UA will remain stationary , in flight, for 3 seconds or more. If, a fter 3 seconds, the DJ I Inspire 1 UA does not reacquire control link data from the GCS, the UA will assume that the Control L ink is lost and the UA 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 Function of the DJ I Inspire 1 UAS is set forth at

pages 27 through 29 of the DJ I Inspire 1 User Manual, attached hereto as Appendix A. **iv. The DJI Inspire 1**  **GCS And Its Operation.**

A complete description of the operation and specifications of the DJ I Inspire 1 GCS and flight control software is provided at pages 32 through 43 of the DJ I Inspire 1 User Manual. DJ I Inspire 1 User Manuals are attached hereto as Appendix A.

**b. Flight Operat**  **ions Of DJI Inspire 1**  **UAS Are Limited To The Line Of Sight**  **of a**  **Certificated Pilot in Command with**  **a Safety Observer.** 

G ar y B revig will be the only person to act as a pilot in command (PI C) of the DJ I Inspire 1 UAS. Additionally , a safety observer will assist him during flight time.

**c. Flights Of DJI**  **Inspire 1 UAS Will Be Conducted Pursuant To**  **Specific Operating Limitations.** In seeking this exemption, G ary B revig proposes to commerciall y operate DJI Inspire 1 UAS for the special purpose of conducting aerial video and photograph y over certain areas of the United States, pursuant to the following specific operating limitations:

1. Operations authorized b y this grant of exemption will be limited to the following a ircraft described in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: DJ I Inspire 1 Unmanned Aircraft Sy stem. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant.

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

3. The UA may

not be flown at an indicated airspeed exceeding 20 knots.4. The UA must be operated at an altitud e of no more than 500 feet above ground level (AGL), as indicated 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 UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PI C to be able to use human vision unaided by any device other than corrective lenses, as specified on the PI C’s FAA

issued airman medical certificate.

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

7. All operations must utilize a safet y observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PI C alway s maintains VLOS capability . The SO and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PI C 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 operating documents.

8. The SO must not perform any other duties bey ond 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 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 oper ating documents, the conditions and limitations contained in the grantof exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may

update or revise its operating documents. It is the operator’s responsibility

to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. I f 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 (A FS

- 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenan ce has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properl y documented in the aircraft records.

11. Any UAS th at 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, items, or equipment, not already covered in the relevant sections of the operating documents.

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

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

15. Each UAS operated under this exemption must comply with all manufacturer Safet y Bulletins.

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

17. The PI C must possess at least a private pilot certificate and at least a current third

- class medical certificate.

18. The operator may

not permit any

PI C to operate unless the PI C meets the operator’s qualification criteria and demonstrates the ability to safel y operate the UAS in a manner consistent with how the UAS will be operated under the exempti on, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles, and structures. PI C qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes o f 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 f or flight operations are considered nonparticipants, and the PI C must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119.

19. UAS operations may

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

20. The UA may

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

- published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required b y the operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request.

21. The UA may

not be operated less than 500 feet below or less than 2,000 feet horizontally

from a cloud or when visibility is less than 3 statute miles from the PI C.

22. If the UA loses communications or loses its GPS signal, it must return to a pre - determined 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 co nditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 25% battery power remaining.

25. The operator must obtain an Air Traffic Organization (ATO)

- issued Certificate of Waiver or Authorization (COA) prior to conducting an y operations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) no t 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 requi rements.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. Marki ngs must be as large as practicable.

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

r equirements.

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 an y time the UAS is operating. These documents must be made available to the Administrator or an y law e nforcement 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 suff iciently 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 nonparticipatingpersons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PI C has made a safet y 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, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a).

32. All operations shall be conducted over private or controlled

- access propert y with permission from the land own er/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted.

33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents must be repor ted to the National Transportation Safet y Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. **2. Reasons Why an**  **Exemption from**  **the Requirements Of**  **Section 61.113(a) And (b) Would Not Adversely Affect Safety.**

G ar y B revig s ubmits that the equivalent level of safet y established b y Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI Inspire 1 UAS unless that PI C has demonstrated, by meeting minimum flight hour and currency requirements , that the PIC is able to safel y operate the DJ I Inspire 1 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles, and structures.Considering Gary Bre vig’s proposed area of operations and the operating limitations set forth

- above, the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062), and the airmanship skills necessary

to safely operate the DJ I Inspire 1 UAS, G ary B revig submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for Gary Brevig’s specific proposed flight operation s. 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, 11 112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). G ar y B revig will not allow any PI C to operate the DJI Inspire 1 UAS unless that PI C has demonstrated, b y meeting minimum flight

- hour requirements or the DJ I In spire 1 UAS training and c urrency

requirements, that the PI C is able to safel y operate the DJ I Inspire 1 UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles, and structures. Specificall y, the PI C must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In addition to the hour requirements, the PI C must accomplish 3 takeoffs and landings in the preceding 90 day s (for currency purposes).
As in Exemption Nos. 11062, 11138, and 11153, prior documented flight ex perience that was obtained in compliance with applicable regulations will ensure an equivalent level of safet y during Gary

B revig’s proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows: In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi

- rotor UAS. Prior to operations under Exemption No. 11062, the PI C must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and m odel of UAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirementsto be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi

- rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PI C must accomplish 3 takeoffs and landings in the preceding 90 day s (for currency purposes). The FAA finds that at a minimum, the flight

- ho ur requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary

to safely conduct the petitioner’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency , and experience

- building flights can also be conducted under the grant of exemption to accomplish the required flight time. During training, proficiency , and experience

- b uilding flights the PI C is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119.

**3. Reasons Why an**  **Exemption from**  **the Requirements**  **of Section**  **91.7(a) Would Not Adversely Affect Safety.**

The equivalent lev el of safet y established b y Section 91.7(a) will be maintained because prior to every

flight, G ary B revig will ensure that the DJ I Inspire 1 UAS is in an airworth y condition based upon the UAS’ compliance with its operating documents and as stated in the co nditions and limitations herein. Additionally , the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 110 66, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

**4. Reasons Why an**  **Exemption from**  **the Requirements**  **of Section 91.121**  **Would Not Adversely Affect Safety.**

The equivalent level of safet y established b y Section 91.121 will be maintained because the altitude information of the DJ I Inspire 1 UA will be provided to the PI C via GPS equipment and a radio communications telemetry data link, which downlinks from the U A to the GCS for active monitoring of the flight path and altitude. This altitude information, combined with Gary

Brevig’s operation of the DJI Inspire 1 UA within visual line of sight,at or below 500 feet AGL, will ensure a level of safet y equivalent to S ection 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 automatically established by

the UASs at ground level. The FAA has previously

granted re lief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11 159, 11160, 11161).

**5. Reasons Why an**  **Exemption from**  **the Requirements**  **of Section**  **91.151(b) Would Not Adversely Affect Safety.**

A grant of this exemption would ensure an equivalent level of safety established by

14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJ I Inspire 1 UAS; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingl y, G ary B revig will ensure that it wi ll safel y operate the battery

- powered DJ I Inspire 1 UA during daylight hours in VFR conditions, with enough battery

power to fly

for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fl y after th at for at least 4.5 minutes. Here, as in Exemption No. 11109, the technical specifications of the DJ I In spire 1 UAS, the limitations on the proposed flight operations, and the location of the proposed operations, will ensure an equivalent level of safety established b y 14 C.F.R. Section 91.151(b). Furthermore, safet y will be ensured as the DJ I Inspire 1 UAS provides audible and visual warnings to the PI C at the GCS when the UA experiences low battery voltage, the first warning occurring at approximately 33% remaining battery

power, and again at approximately

10% remaining battery

power. At the criticall y low battery l evel, the DJ I Inspire 1 UAS will descend and land automatically

. Significantl y, previous exemptions granted b y the FAA concerning Section 91.151 establish that safet y is not adversel y affected when the technical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 sp ecific 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, 11 159, 11160, 11161).**6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would**  **Not Adversely Affect Safety.**

In seeking this exemption, G ary B revig submits that the equiv alent level of safet y 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 G ary B revig will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e. The Monthly Maintenance Log and DJ I Inspire 1 Instruction Manual). Furthermore, G ary B revig will documen t and maintain all maintenance records for the DJ I Inspire 1 UAS. Since the DJ I Inspire 1 UAS will be inspected as prescribed b y the operating documents, G ary B revig will maintain the equivalent level of safet y established b y Sections 91.405(a), 91.409(a) (1), and 91.409(a)(2). A cop y of the DJ I Inspire 1 User Manual is attached hereto as Appendix A; a cop y of the DJ I Inspire 1 UAS Maintenance LOG is attached hereto as Appendix B. Likewise, the exemption sought will not adversel y affect safety because G ary B revig 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 equival ent level of safet y established by

Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI Inspire 1 UAS will be performed b y t rained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log. 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 th e UAS are considered. In consideration of Gary

Brevig’s proposed operating limitations, the operating documents, and the technical aspects of the DJ I Inspire 1 UAS, G ary B revig submits that safet y 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 thosepresented herein (e.g. Exemption Nos. 11062, 110 63, 11064, 11065, 11066, 11067, 11080,

11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). **7. The FAA May Prescribe Any Other Conditions For Safe Operation.** In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, G ary B revig requests that the FAA prescribe special conditions for the intended operation of the DJ I Inspire 1 UAS, whi ch contain such safety standards that the Administrator finds necessary to establish a level of safety

equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91 .409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UA 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 set s forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national securit y; and further, provides the authority for such UAS to operate without airworthiness certification in accordance with an y 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 Inspire 1 UAS, since the airwo rthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safet y 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 a irworthiness regulations of this subchapter do not contain adequate or appropriate safet y 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 spe cial conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety

standards for the aircraft, aircraft engine or propeller as the FAA finds necessary

to establish a level of safety equivalent to that established in the regulations.

See 14 C.F.R. § 21.16. Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for Leading Edge’s intended operation of the DJI Inspire 1 UAS, which contain such safet y standards that the Administrator finds necessary toestablish a level of safet y 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), 9 1.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

**A Summary That Can Be Published in the**  **Federal Register, stating: The Rules**  **from Which G**  **ary B**  **revig Seeks**  **Exemption:**G ary B revig seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

**A Brief Description of**  **The Nature Of The Exemption G ary**  **B revig**  **Seeks:**

This exemption will permit G ary B revig to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States.**Any Additional Information, Views, or**  **Arguments Available To Support Gary Brevig’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, Gary Brevig’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 otherwise pose a threat to national securit y; and further, provides the authority for such UAS to ope rate without airworthiness certification.
As discussed in detail above, G ary B revig will operate the DJ I Inspire 1 UAS 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

. Li sted in Appendix C is a link to a brief article outlining the environmental benefits of commercial use of a UAS.**CONCLUSION**

As set forth herein, G ary B revig seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI Inspire 1 UAS commerciall y, without an airworthiness certificate, for the limited purpose of conducting aerial video and photo graph y 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 G ary B revig to safely , efficientl y, and economically operate the DJ I Inspire 1 UAS commerciall y within the NAS. **WHEREFORE** , in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, Gary Brevigrespectfully 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 G ary B revig to operate the DJ I Inspire 1 UAS commercially for the purpose of conducting aerial video and photography over certain areas of the United States. Dated: May 27th, 2015 Respectfully

submitted,

_________________________ GARY BREVIG 11090 183rd Cir NW Elk River MN 55330

952

- 278

- 2402 Gary b@DennisonTech.com**Apendix**

**A. DJI**  **Inspire 1 User Manual**  **Attached**

**B. Proposed Maintenance Log** 

**C. Link to a Supportive Article**  **http://rotordronemag.com/can**
**- drones** 
**- save**  **** **planet/** Service Date Aircraft

Hours Items performed Items Needing Attention