# Wold Development LLC

.

REQUESTS 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 P HANTOM 4 UNMANNED AIRCRAFT

SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)

Submitted on March 15, 2016 Wold Development Benjamin Wold 6434 E Military Rd

. Cave Cree k , AZ 85331

254

- 913

- 7557 nwold53@gmail.com

### T ABLE OF CONTENTS

GLOSSARY OF ABBREVIATIONS

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

SUMMARY

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

INTRODUCTION AND INTERESTS OF THE PETITIONER

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

BACKGROUND

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

BASIS FOR PETITION

................................ ................................ ................................ ............................... 7

A. NAME AND ADDRESS OF THE PETITIONER.

................................ ................................ ................. 8

B. THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH WOLD DEVELOPMENT SEEKS

EXEMPTION.

................................ ................................ ................................ ................................ .............. 9

C. THE EXTENT OF RELIEF WOLD DEVELOPMENT SEEKS AND THE REASON WOLD

DEVELOPMENT SEEKS THE RELIEF.

................................ ................................ ................................ .. 12

D. THE REASONS WHY GRANTING WOLD DEVELOPMENT REQUEST WOULD BE IN THE

PUBLIC INTEREST

................................ ................................ ................................ ................................ .. 14

E. THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT

SAFET Y

................................ ................................ ................................ ................................ ..................... 16

F. A SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER

................................ . 25

G. ANY ADDITIONAL INFORMATION

................................ ................................ ................................ 25

CONCLUSION

................................ ................................ ................................ ................................ ........... 27

EXHIBITS:

................................ ................................ ................................ ................................ ................. 28

### GLOSSARY OF A BBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviati on Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

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

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing

### SUMMARY

Wold Development LLC seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Wold Development LLC to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography of construction sites, real

estate, Non

- Profit and other comm uni ty special events in and around the State of Arizona

.

### INTRODUCTION AND INTERESTS OF THE PETITIONER

Wold Development LLC . (Hereinafter referred to as “ Wold Development”) provides its commercial clients with affordable highest quality digital content fo r use in their commercial, personal, and other photography related projects. Wold Development also provides the community and Non

- Profit organization our services for no charge as a way of giving back to the community

. Wold Development is a seasoned leader in unmanned aerial videography with over 2 years recreational/hobby experience in all aspects of RC Aircraft, Quadcopters and other small UAS’s. The objective of Wold Development aerial video and photography operations is to provide high quality imaging f or a variety of commercial, public, and residential uses, specifically targeting:

Aerial r eal e state photography and videography

Aerial Agricultural survey and inspection

Aerial Land survey and mapping

Aerial Construction and b uilding inspection

Aerial P ublic and private e vent p hotography and v ideography Free aerial photograph and videography s ervices to n on

- p rofit and c ommunity o rganizations

### BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 4 Wold Development see ks an exemption to operate a DJI Phantom 4 for compensation or hire within

the NAS. The DJI Phantom 4 is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. Th e DJI Phantom

4 has a maximum gross weight of approximately 3 pounds, while having a le ngth of 16 inches

, width of 16 inches, height of 8 inches, and a maximum speed of approximately 40 knots. The DJI Phantom

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

motors. The DJI Phantom 4 UAS that will be operated by Wold Development 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 ma rked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking

.

### BASIS FOR PETITION

Petitioner, Wold Development , pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereby petitions the Administrator to commercial ly operate the DJI Phantom 4 UAS in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). In considera tion of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, Wold Development operation

of DJI Phantom 4 UAS meets the conditions of FMRA Section 333 and therefore, will not require an

airworthiness c ertificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingly, Wold Development requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft

with an airworthiness certificate. Wold Development submits that the requested relief is proper since an equivalent level of safety will always be ensured (see Exhibit D). Wold Development will use

licensed technicians or the manufacturer s’ service centers to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 4 Instruction Manual).

Furtherm ore, Wold Development will document and maintain all maintenance records for the DJI

Phantom 4 UAS. Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command , is requested by Wold Dev elopment to the extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an airman medical certificate, and who has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 4 UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Wold Development seeks relief

fro m Section 91.7(a), entitled Civil aircraft airworthiness , because the DJI Phantom 4 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Wold Development submits that it will ensure that the DJI Phantom 4 UAS are in an airworthy condition, prior to every flight, by determining that the UASs are in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 4 Instruction Manual), and that the aircraft are in a

condition for safe flight. Wold Development also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , as the DJI Phantom 4 UA will not have a typical barometric altimeter onboard. However, altitude information of the DJI Phantom 4 UA will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with Wold Development’s operation of the DJI Phantom 4 UAS within visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121 and our additional safety requirements as outlined in Exhibit D. Additionally, Wold Development seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions

. Wold Development submits that safety will not be affected by operation of the DJI Phantom 4 UA during daylight hours in visual meteorolo gical conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration of approximately 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minut es. In accordance with 14 C.F.R. § 11.81, Wold Development provides the following information in support of its petition for exemption:

### A. NAME AND ADDRESS OF THE PETITIONER

.

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

Wold Development Benjamin Wold

, 6434 E Military Rd

Cave Cree k , AZ 85331

Email: nwold53@gmail.com

### B. T HE SPECIFIC SECTIONS OF 14 C.F.R. F ROM WHICH WOLD DEVELOPMENT

SEEKS EXEMPTION

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1. Wold Development Seeks Exemption From The Requirements Of Section 61.113(a) And (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command , subsections (a) and (b) prescribe the following, in relevant part: (a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PIC of an aircraft.

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if

—

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire.

2. Wold Developm ent 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. Wold Development Exemption From The Requirements Of Section 91.121. Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: 9 (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of tha t aircraft, as the case may be, by reference to an altimeter that is set, when operating

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(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) the re 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) the case of an aircraft not equipped with a radio, the elevation of the departure air port or an appropriate altimeter setting available before departure.

4. Wold Development Exemption From The Requirements Of Section 91.151(b). Section 91.151, entitled Fuel requirements for flight in VFR conditions , subsection (b), states the following: (b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that fo r at
least 20 minutes.

5. Wold Development Exemption From The Requirement Of Section 91.405(a).Section 91.405, entitled Maintenance required , subsection (a), states the following: Each owner or

operator of an aircraft

— (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.]

6. Wold Dev elopment From The Requirements Of Section 91.407(a)(1) Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration , subsection (a)(1), states the following:

(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

--

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

43.7 of this chapter[.]

7. Wold Development 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 unles s, within the preceding 12 calendar months, it has had

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(1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by § 43.7 of this chapter; or

(2) An inspection for the iss uance of an airworthiness certificate in accordance with part 21 of this chapter.

8. Wold Development 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 f ollowing: (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 ma intenance, 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

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(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.

11 (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 c urrent inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and s afety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required.

(vi) Copies of the forms pre scribed by § 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and transfe rred with the

aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.

### C. T HE EXTENT OF RELIEF WOLD DEVELOPMENT SEEKS AND THE REASON

WOLD DEVELOPMENT SEEKS THE RELIEF

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1. Extent Of Relief Wold Development Seeks And The Reason Wold Development Seeks Relief From Section 61.113(a) And (b). Relief from Section 61.113(a) and ( b) entitled Private pilot privileges and limitations: Pilot in

command , is requested to the extent necessary to allow a PIC holding a private pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met cert ain flight

hour and currency requirements, to conduct the proposed UAS flight operations for compensation or

hire. This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. As set forth more fully below, Wold Development submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the DJI Phantom 4 other than the person listed as James R. Fitzpatrick, who has 10+ years’ experience in RC/VAV operation. In addition all flights

must full under the safety guidelines of Exhibit D, which will be updated as new FAA guidelines take place. Further, Wold Development submits that all flights of the DJI Phantom 4 UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be in cidental to Wold Development business; and (2) will not carry passengers, packages or property for compensation or hire.

2. Extent Of Relief Wold Development Seeks And The Wold Development Seeks R elief From Section 91.7(a). Relief from Section 91.7(a) ent itled Civil aircraft airworthiness , is requested to the extent required to

allow Wold Development to determine that the DJI Phantom 4 UAS are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating document s (i.e., the Wold Development Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 4 Instruction Manual). Wold Development seeks the requested relief because the DJI Phantom 4 UAS do not require an

airworthiness certificate in accordance wit h 14 C.F.R. Part 21, Subpart H. Therefore, Wold Development will ensure that the DJI Phantom 4 UAS are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 4 Instruction Manual) prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated in the conditions and limitations below.

3. Extent Of Relief Wold Development Seeks And The Reason Wold Development Seeks Relief

From Section 91.121. Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of

the DJI Phantom 4 UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude inf ormation from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), Wold Development seeks the reques ted relief because the DJI Phantom 4 UA’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight. 20Considering the limited altitude of the proposed operations, relief from 14 CFR

91.121 is sought to the extent necessary to comply with the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level of safety will be maintained since the

DJI Phantom 4 UAS are equipped with a barometri c 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 Relie f Wold Development Seeks And The Wold Development Relief From Section 91.151(b). Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to allow flights of the battery powered DJI Phantom 4 UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after

that for at least 4.5 min utes. Wold Development seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered DJI Phantom 4 UA will severely constrain the practicality of any aerial video or still photo flight opera tions that Wold Development proposes to conduct pursuant to this Petition. Significantly, as set forth below, the technical specifications of the DJI Phantom 4 UAS, the DJI

Phantom 4 operating documents, and Wold Development’s proposed operating limitatio ns, ensure that Wold Development will safely operate the battery powered DJI Phantom 4 UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

5. Extent Of Relief Wold Development Seeks And The Reason Wold Development Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b). Since Sections 91.405(a), 91.407(a)(1), 91.409( a)(1) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, Wold Development requests relief from

these Sections because the DJI Phantom 4 UAS does not require airworthiness certificates. As set forth more fully below, th e DJI Phantom 4 UAS meets the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, Wold Development will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 4 Instruction Manual). Furthermore, Wold Development will document and maintain all maintenance reco rds for the DJI

Phantom 4 UAS.

### D. T HE REASONS WHY GRANTING WOLD DEVELOPMENT REQUEST WOULD

BE IN THE PUBLIC INTEREST ; That Is, How It Would Benefit The Public As A Whole. Granting the present Petition will further the public interest by allowing Wold Deve lopment to safely, efficiently, and economically perform aerial video and photography for Non

- Profit and Community Organizations , as well as, pursue revenue for a Small Business in the USA as we provide commercial services for Homes and Land for sale, Plac es of Lodging, Golf Courses, and other commercial properties seeking the described services for marketing purposes over certain areas

of Arizona and the surrounding areas.

Additionally, use of the DJI Phantom 4 UAS will decrease congestion of the NAS and reduce pollution , since past aerial photography required large manned 20 aircraft for extended periods of time. Notably, the benefits of Wold Development ’s proposed operation of the DJI Phantom 4 UAS will be realized without implicating any privacy issues.

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

The DJI Phantom 4 UA are battery powered and serve as a safe, efficient, and economical alternative to

the manned aircraft tra ditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJI Phantom 4 UAS
would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground (as outlined in Exhibit D).

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departin g aircraft will be reduced. The DJI Phantom 4 UA do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handled by air traffic cont rol during the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. The Public Will Benefit from The Safety and Efficiency Of The DJI Phantom 4 UAS. Conducting aerial acquisitions with the DJI Phantom 4 UAS, instead of manned a ircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, the DJI

Phantom 4 UAS prod uce no air pollution, and is the most viable environmentally conscious alternative to
the cabin class, six

- cylinder internal combustion engine aircraft that are typically utilized for aerial video and photography, while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The DJI

Phantom 4 UA, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAS are propelled by battery powered electric motors, rather than an internal combustion engine.
By using the DJI Phantom 4 UAS to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members
located onboard the aircraft, the DJI Phantom 4 UA (weighing approximately 3 p ounds at their maximum

gross we ights with length of 16 inches , width of 16 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 p ounds 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 Phantom 4 UAS Will

Benefit Non

- Profit and Community Organizations.As stated earl ier in this petition, Wold Development provides free services to Non

- Profit and Community

Organization that normally could not afford to have their event or site professionally photographed. There the Oneida community and surrounding area benefits.

4. Per forming Aerial Video and Photography Operations with The DJI Phantom 4 UAS Will

Benefit the Economy. In addition to being safe and efficient, the DJI Phantom 4 is also an economical alternative to using manned aircraft to conduct similar aerial operations . As such, 20 operation of the DJI Phantom 4 UAS will allow United States based companies, like Wold Development , to remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery powered DJI Phantom 4 UAS is one such technolo gy that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft. By operating the DJI Phantom 4 UAS, companies such

as Wold Deve lopment , can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through commercial use of the DJI Phantom 4 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 in the United

States and abroad.

5. There Are No Privacy Issues. Similar to the manned aerial acquisition flight operations that have been conducted for decades, Wold Development proposed operation of the DJI Phantom 4 UAS will not implicate any privacy issues. Specifically , the DJI Phantom 4 UAS will be operated only in compliance with operating documents (i.e.,

the Wold Development Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 4 Instruction Manual) which requires property owner involvement as well as l ocal law enforcement
notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.

### E. T HE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY

AFFECT SAFETY , Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which Wold Development Seeks Exemption. 1. Reasons Why The DJI Phantom 4 UA Meet the Conditions of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333.

In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, Wold Development operation of the DJI Phantom 4 UAS meet the conditions of FMRA Section 333, and will not requir e an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a

hazard to users of the NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part:

(a) In General.

-- Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date o

f 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 guidanc e 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

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(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 air space system or the public or pose a threat to national security; and (2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of u nmanned aircraft

20 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 aircra ft systems in the national airspace system.

In seeking this exemption, Wold Development submits that the DJI Phantom 4 UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the

DJI Phantom 4 UAS; ( b) the pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications of The DJI Phantom 4 UAS Demonstrate Its Safe Characteristics.

The DJI Phantom 4 UAS does not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability.

i. Technical Specifications of The DJI Phantom 4 UAS. The technical specifications of the DJI Phantom 4 UAS is set forth by the DJI Phantom 4 Specifications and Data Sheet, attached hereto as Exhibit A.ii. The DJI Phantom 4 UAS Autonomous Flight and Navigation Modes Enable The UAS To

Remain Within A Defined Operational Area.

The DJI Phantom 4 UAS may be operated in both manual and fully auto nomous flight modes. A complete description of the flight and navigational modes of the DJI Phantom 4 UAS is provided at pages 25

- 32 of the DJI Phantom 4 User Manual, attached hereto as Exhibit B.

iii. The DJI Phantom 4 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 Link is lost, the DJI Phantom 4 UA will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 4 UA does n ot reacquire control link data from the GCS, the UA will assume that the Control Link 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 F ailsafe Functions of the DJI Phantom 4 UAS are set forth at pages 27 through 28 of the DJI Phantom 4 User Manual, attached hereto as Exhibit B.

iv. The DJI Phantom 4 GCS and Its Operation. A complete description of the operation and specifications of th e DJI Phantom 4 GCS and flight control software is provided at pages 32 through 43 of the DJI Phantom 4 User Manual. DJI Phantom

4 User Manual is attached hereto as Exhibit B.

b. Flight Operations of DJI Phantom 4 UAS Are Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer. Wold Development will only utilize certificated pilots who possess a current and valid airman medical certificate to act as a pilot in command (PIC) of the DJI Phantom 4 UAS. Ad ditionally, a safety observer will assist all pilots during flight time. And the guidelines exhibited in D, will be

followed at all

- times ensuring the safety of all involved.

c. Flights of DJI Phantom 4 UAS Will Be Conducted Pursuant To Specific Operatin g Limitations. In seeking this exemption, proposes to commercially operate DJI Phantom 4 UAS for the special purpose of conducting aerial video and photography over certain areas of Oneida County and surrounding areas, pursuant to the following specific o perating limitations: 1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight:

DJI Phantom 4 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 photography.

3. The UAS m ay not be flown at an indicated airspeed exceeding 20 knots.

4. The UA must be operated at an altitude of no more than 500 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved by ATC. All altitudes reported to ATC must be in feet AGL.

5. The UAS must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than correct ive lenses, as specified on the PIC’s FAA

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

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the fl ight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the SO can perform the functions prescribed in the operating documents.

8. The SO must not perform any other duties beyond assisting the PIC with see ing 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 avai lable to the Administrator upon request. If a discrepancy exists between the conditions and limitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exe mption 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 a nd present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. If the operator determines that any update or

rev ision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operating documents. 10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircr aft 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 te st flight must make an entry in the aircraft records.

12. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections of the operating

documents.

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

14. The operator must carry out its maintenance, inspections, and record keeping requirements, in

accorda nce with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature of the au thorized person returning the

UAS to service.15. Each UASs operated under this exemption must comply with all manufacturer Safety Bulletins.

16. The authorized person must make an entry in the aircraft record of the corrective action taken against dis crepancies discovered between inspections.

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

- class medical

certificate.

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qua lification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the

purpose 2 s 3 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 distan ce 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. §

19.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is re quired, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized.

20. The UA may not operate within 5 nautical miles of an airport reference point as deno ted 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 by the operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request.

21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

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

- determined location within the planned operating area and land or be recovered in accordance with the operating

documents.

23. The PIC must abort the flight in the event of unpredicte d obstacles or emergencies in accordance with the operating documents.

24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 25% battery power remaining.

25. The oper ator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption. This COAwill also require the operator to request a Notice to Airman (NOTAM) not more t han 72 hours in

advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requirements.

26. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (N

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

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

UA m 24 ust comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requiremen ts.

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made

available to the a dministrator or any law enforcement of ficial upon request.

29. Wold Development abides and enforces the safety checklist to as exhibited in section D to ensure that we provide safety for everyone in and near to the site.

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

activities at all times.

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

32. Flight operations must be conducted at least 400 feet from all nonparticipating persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures

unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure t hat nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or;

b. The aircraft is operated near ves sels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undu e hazard, and;

c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a).

33. 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.

34. 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 UASIntegration Office (AFS

- 80) within 24 hours. Accidents must be r eported to the National

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would

Not Adversely Affect Safety. Wold Development submits that the equivalent level of safety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI Phantom 4 UAS unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requireme nts, that the PIC is able to safely operate the DJI Phantom 4 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering Wold Dev elopment 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 nec essary to safely operate the DJI Phantom 4 UAS, Wold Development submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for Wold Development specific proposed fli ght 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, 1110 9, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). Wold Development will not allow any PIC to operate the DJI Phantom 4 UAS unless that PIC has demonstrated, by meeting minimum flight

- hour requirements or the DJI Phantom 4 UAS training and currency requirements, that the PIC is able to safely operate the DJI Phantom 4 UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot operating the same make and mod el of UAS to be used for operations under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). As in Exemption Nos. 11062, 11138, and 11153, prior document ed flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during Wold Development proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi

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

- rotor time and

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

- 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 complia nce with applicable regulations would satisfy this requirement. Training, proficiency, and experience

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

- b uilding flights the

PIC is required to operate the UA with appropriate

27 D istances in accordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15. Accordingly, Wold Development will ensure safe operations by not allowing any PIC to operate the

DJI Phantom 4 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 4 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety. Wold Development requires a tight set of rules that follow best prac tices and FAA requirements and guidelines (Exhibit D). The equivalent level of safety established by Section 91.7(a) will be maintained because prior to every flight, plus Wold Development also requires the safety checklist in Exhibit D that ensures that

the DJI Phantom 4 UAS is in an airworthy condition based upon the UAS’s compliance with its operating documents and as stated in the conditions and limitations herein. Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UA S, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

4. Reasons Why a n Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety. As outlined in Exhibit D, Wold Development fly’s only under a very set rules. We believe these rules include and go beyond current FAA guidelines. Therefore, the e quivalent level of safety established by Section 91.121 will be maintained because the altitude information of the DJI Phantom 4 UA will be provided to the PIC via GPS equipment and a radio communications telemetry data link, which

downlinks from the UA to the GCS for active monitoring of the flight path and altitude. This altitude information, combined with Wold Development operation of the DJI Phantom 4 UA within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to S ection 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically established by the UASs at ground level. The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150 , 11153, 11156, 11157, 11158, 11159, 11160, 11161).

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely Affect Safety. A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R.

S ection 91.151(b) as a result of (1) the technical specifications of the DJI Phantom 4 UAS; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, Wold Development will ensure that it will safely operate the battery powered DJI

Phantom 4 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 fly after tha t for at least 4.5 minutes.Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 4 UAS; the

limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safety e stablished by 14 C.F.R. Section 91.151(b). Furthermore, safety will be

ensured as the DJI Phantom 4 UAS provide audible and visual warnings to the PIC at the GCS when the UAS experiences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery power. At the critically low battery level, the DJI Phantom 4 UAS will descend and land automatically. Significantly, previous exemptions granted by the FAA concerning Section 91.15 1 establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, includi ng 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, 1106 2, 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 91.405(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, Wold Development submits that the equivalent level of safety with regard to the regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91.40 9(a)(1) & (a)(2), and 91.417(a) & (b) will be met because Wold Development will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating docum ents (i.e., the Wold Development Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 4 Instruction Manual). Furthermore, Wold Development will document and maintain all maintenance records for

the DJI Phantom 4 UAS. Since the DJI Phantom 4 U AS will be inspected as prescribed by the operating documents, Wold Development will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI Phantom 4 User Manuals are attached hereto as Exhibit B; a copy of the DJI Phantom 4 UAS Maintenance LOG is attached hereto as Exhibit C. Likewise, the exemption sought will not adversely affect safety because Wold Development will use trained technicians to perfor m maintenance, alterations or preventive Maintenance on the UAS using the methods, techniques, and practices prescribed by the operating documents. Furthermore, the exemption sought would maintain an equivalent level of safety established by Sections 91.4 07, 91.417(a) and 91.417(b), because all maintenance of the DJI

Phantom 4 UAS will be performed by trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log. Significantly, previous exemptions granted by the

F AA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the technical characteristics and operating

limitations of the UAS are considered. In consideration of Wold Deve lopment proposed operating limitations, the operating documents, and the technical aspects of the DJI Phantom 4 UAS, Wold Development submits that safety will not be adversely affected by granting exemption from 14 nd (a)(2), 91.409(a)(2), and 91.417(a) a nd (b). C.F.R. Sections 91.405(a), 91.407(a)(1) a 31 32 T he 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). In additional 350 Sky Vision fly only under a tight set of rules which can be found in Exhibit D, which ensure the safest operation under any foreseen circumstan ce.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, Wold Development requests that the FAA prescri be special conditions for the intended operation of the DJI Phantom 4 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, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAS for the limited purpose of conducting aerial video and photography over ce rtain areas of the United States for compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, prov ides the authority for such UAS to operate without airworthiness certification in accordance with any requirements that must be established for the safe operation of the UAS in the NAS. Likewise, the Administrator may prescribe special conditions pursuant to 14 33 C.F.R. § 21.16, for operation of the DJI Phantom 4 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, e ntitled Special Conditions, states the following: If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or unusual

d esign feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety standards for the air craft, 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 pres cribe special conditions for Leading Edge’s intended operation of the DJI Phantom 4 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 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).



### F. A S UMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER , stating:

The Rules From Which Wold Development Seeks Exemption: Wold Development 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 Wold Development Seeks: This exemption will permit Wold Development to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the

United States.



### G. A NY ADDITIONAL INFORMATION

, Views, Or Arguments Available To Support Wold Development 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 safe ly in the NAS. As such, Wold Development request for exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification. As discussed in detail above,Wold Development will operate the DJI Phantom 4 UASs safely in the NAS, without creating a

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

### CONCLUSION

As set forth herein, Wold Development seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of2012 (FMRA), which will permit safe operation of the DJI Phantom 4 UAS commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography over Arizona and surrounding area. 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 Wold Development to safely, efficiently, and economically operate the DJI Phantom 4 UAS commercially within the NAS. WHEREFORE , in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of2012, Section 333, Wold Development respectfully requests th at 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)(l) & (a)(2), and 91.417(a) & (b), and permit Leading Edge to operate the DJ I

Phantom 4 UAS commercially for the purpose of conducting aerial video and photography over

certain areas of the United States.

Dated: December 8

, 2015 Respectfully submitted, Wold Development

Wold Development, LLC Benjamin Wold 6434 E Military Rd

Cave Cree k , AZ 85331

Email: nwold53@gmail.com

### E XHIBITS :

A

– DJI Phantom 4 Specifications Data Sheet

B

– DJI Phantom 4 Manufacturer’s User Manual (see attached file)

C

– Monthly Maintenance Log

D

– Wold Development On

- Site Safety ChecklistEXHIBIT

– A

DJI PHANTOM 4 TECHNICAL SPECIFICATIONS Wold Development only utilizes safe and reliable UASs. DJI is an industry leader in small UAS production. DJI UASs are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJI software provides real

- time altitude and

location information to the PIC via the linked monitor (smart phone/tablet

devices) 

### Aircraft Supported Battery:

DJI 5350 mAh LiPo Battery Weight (Battery & Propellers included):

1380 g Hover Accuracy (Ready to Fly): Vertical:
0.8m; Horizontal: 2.5m Max Yaw Angular Velocity; 200°/s
Max Tiltable Angle: 3 0 ° Max Ascent / Descent Speed: Ascent: 6m/s; Descent: 4 m/s
Max Flight Speed: 20 m/s (Not
Recommended)
Diagonal motor

- motor distance: 350mm



### Remote Control Operating Frequency: 2.400 GHz

- 2.483

G Hz

Comm unication Distance (open area):
CE Compliance 3,50 0m FCC Compliance: 50 800m Receiver Sensitivity (1%PER):

- 93dBm

Transmitter Power: CE Compliance: 17bBm; FCC Compliance: 23dBm Working Voltage: 1200 mA@ 7.4 V

Built

- in LiPo Battery Working Current/Capacity: 7.4v

, 6000 mAhEXHIBIT

– B

DJI Phantom 4 Professional User Manual



### https://dl.djicdn.com/downloads/phantom_4/en/Phantom_4_User_Manual_en_v1.2_160328.pdfEXHIBIT

– C



# Wold Development LLC

On

- Site Safety Checklist

Pre

- flight Reviewed targeted area through Google Earth for any obstructions

Reviewed area for any FAA re stricted fly zones or other areas of concern

Reviewed safety requirements with sponsor / owner (sign

- off required back of form)
Posted “Aerial Photography” in process sign at opening / curb

Visit each neighbor to announce that aerial photography w ill be taking place
Posted “Launch/Landing” zone sign calling for 50’ parameter

Walked the hover area or path of flight to check for any areas on concern

Flight Set

- up Advise anyone within “Launch/Landing” area of safety and 50’ requirement

Unpack and check DJI Phantom 4 for any visible signs of damage

Turn on Remote Controller and observe that both power and Wi

- Fi are green

Ensure launch zone is clear and turn on DJI Phantom 4 battery

Toggle S1 & S2 switches five times to set GPS recalc & failsafe landing zone

Wait for solid GPS lights (Solid Green slow flashing)

Spin DJI Phantom 4 360 ° both Horizontal and Vertically to ensure lock

Review Launch Site one last time before liftoff

Engage motors and start straight horizont al lift to desired altitude

Flight Monitor both GPS Lock (# satellites) / Battery Level every minute

Watch for any changes to the “Launch/Landing” area of safety and advise as necessary

Watch for any irregular craft behavior and land immediatel y if necessary

Return the craft to the landing area within 20% of battery life

Post

- Flight Announce that the craft is returning for landing

Visual check that the 50’ rule is observed / Otherwise hover until 50’ is observed

Slowly bring th e DJI Phantom 4 in for a landing

Turn off Battery on Craft first, then the Remote Controller

Store all equipment in their cases before allowing observes to approach

## On

- Site Safety Checklist

Sponsor / Owner Sign

- off
As the sponsor or owner of this engagement you understand that Wold Development LLC operates under the following rules and obligation to ensure the public safety and privacy, and that we follow all FAA rules and guidelines. As the sponsor / owner of this engagement you agree to the following through your initial of each item and signature at the bottom of this page.

Eagle Eyes Services LLC has advised you as to the following: Initial: _____ We will not fly within 1 mile of FAA Restricted Zones ______

We will not fly over 400’ of the current launch elevation ______
We will not fly if a 50’ Launch/Landing parameter cannot be established ______

We will land the craft immediately of any technical issues occur ______

We will land the craft if on

- site activity occurs that presents a security concern ______

Privacy Concerns:
If Neighbors have a privacy concern, we will not fly until it is resolved ______

If pictures taken has a privacy concern, it will not be made available ______

Safety: You agree to assist in the limiting of people within the launch/landing area ______

You agree to assist in the support of all other identified safety areas

Safety Checklist Signatures

Sponsor / Owner

Name: ______________________________

Address:

____________________________ Phone: ______________________________ Email: ______________________________

Signature: ___________________________

Wold Development LLC

Nick Wold 6434 E Military Rd Unit 101
Cave Creek, AZ 85331

Signed: ___________________

______________EXHIBIT

– D



# Wold Development LLC

Maintenance Log

EVERY WEEK or EVER 10 FLIGHTS, WHICHEVER SOONER

1. Visual inspection of shell and other plastic components for cracking/damage (landing
skids, camera mounting plates, etc.)

2. Check tightness of motor retaining screws and shell retaining screws (both 2.0mm hex)

3. Clean data spring pins and battery contact pads with alcohol and swab or proprietary electrical contact cleaner and cycle spring pins several times to check for spring

weakness and full uni mpeded travel;

4. Plug in to Vision Assistant and check tx & IMU calibration state and all battery cells have good balance (repeat for all batteries);

5. Check batteries for number of cycles and discharge per DJI recommendations if
required.

EVERY MONTH or EVERY 40 FLIGHTS, WHICHEVER SOONER

1. Remove upper shell and check state of all wiring

- plugs fully seated, condition of all solder joints, condition of visible circuit boards and wiring runs, internals generally clean and no debris/loose items.

2. Remove motor s and check security of E clips, condition of bearings and general visual
inspection.

3. Remove rubber cover from Vision camera servo mounting point and check tightness of

the small cross

- head screw.

Date Inspection Notes Inspected By