UNITED STATES OF AMERI CA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHI NGTON, DC

INTHE MATTER OF THE PETITION FOR EXEMPTI ON OF: Ringo Rocky Long

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 14 C.F.R §§ 61.23(a), 61.101(34) 61.113(a) & (b), 61.315 (a), 91.7(a), 91.119 (c), 91.119 (c), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), CONCERNI NG COMMERCIAL OPERATI ON OF DIATONE 500MM QUADCOPTER(NAZA V2) AND TAROT 680MM

HEXACOPTER(ZYX

- M) UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112

- 95)

Sub mitted on May

31 , 2015
Ringo R. Lo ng 519 River Landing Drive Soddy Dais y, TN 37379 423 834

- 0433

## 1 Table of Contents GLOSSARY OF ABBREVIATIONS

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

................................ ................................ ................................ ................................ ............................ 3 IN TRODUCTION AND INTER ESTS OF THE PETITIONER

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

................................ ................................ ................................ ................................ .................... 3 BASI S FOR PETITION

................................ ................................ ................................ ................................ ......... 3 Name And A ddress Of The Petitioner.

................................ ................................ ................................ ................... 5 The Specific Sections Of 14 C.F.R. From Which Applicant Seeks Exemption.

................................ .................... 5 The Extent Of Relief Applicant Seeks And The Reason Applicant Seeks The Relief.

................................ .......... 7 The Reasons Why

Granting Applicant Request Would Be In The Public Interest; That Is, How It Would Benefit The Public As A Whole.

................................ ................................ ................................ ................................ ......... 9 The Reasons Why

Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provid ed By The Rule From Which Applicant Seeks Exemption.

................................ ................................ ................................ ................................ ............................ 10 CONCLUSION

................................ ................................ ................................ ................................ ..................... 17

## 2 GLOSSARY OF ABBREVIATIONS AGL Above Ground Level AOI Area of Interest ATC Air Traffic Control ATO Air Traffic Organization AV Aerial Vehicle CFR Code of Federal Regulations COA Certificate of Authorization FAA Federal Aviation Administration FAR Federal Aviation Regulation GCS Ground Control Station GPS Global Positioning System LOL Loss of Link NAS National Airspace System NOTAM Notice to Airman PI C Pilot In Command Section 333 FAA Modernization and Reform Act of 2012 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

## 3 SUMMARY Ringo Rocky Long (Applicant) seeks exemption from the requirements of 14 C.F.R §§ 61.23(a), 61.101(34 ) 61.113(a) & (b), 61.315 (a) , 91.7(a), 91.119 (c), 91.119 (c), 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 Applicant to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photograph y of to be used in television commercials, weather traffic and news reports, and sporting events over certain areas of the United States.



### INTRODUCTION AN D INTERESTS OF THE PETITIONER My name is Ringo Rocky

L ong; I am 39 ye ars old, with an Associates Degree in Computer Science, Bachelor s Degree in Business Management , and a Mas ters Degree in Business Administration. I am a current member of the Academy

of Model Aeronautics, and my member number is 1065938. I have been fl ying for over 8 months, and have built four different quadcopters and one hexacopter. These various models range in size from 250mm to 680mm. I reall y enjo y taking aerial photography, and sharing it for others to enjoy

also. I have logged over 31 hours of flight time over the past several months, and would like to start performing aerial photography for others.



### BACKGROUND Unmanned Aircraft Systems: Di atone 500mm quadcopter(NAZA V2) , Tarot 680 hexacopter Applicant seeks an exemption to operate DJI and Tarot sy stems for compensation or hire within the NAS. The various models are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing a radio control

. My current collection has a maximum weight of 8lbs, and can travel at a maximum speed of 50knots . The Diatone 500mm quadcopter(NAZA V2) is equipped with four main rotors; driven by Lithium Poly

mer battery

po wered electric motors , and the Tarot 680 mm hexacopter(ZYX

- M) is also driven by Li thium Poly

mer batteries, and has six main rotors

. The Diatone 500mm quadcopter(NAZA V2) and 680mm hexacopter UAs that will be operated b y Applicant 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, Applicant , pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereb y petitions the Administrator to c ommerciall y operate the Di atone 500mm quadcopter(NAZA V2) and 680mm hexacopter UASs in the National Airspace S ys tem (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.23(a), 61.101(e 4 ) 61.113(a) & (b), 61.315 (a) , 91.7(a), 91.119 (c), 91.119 (c), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1 ) & (a)(2), and 91.417(a) & (b). In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, Applicant operation of Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UASs meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingl y, Applicant 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 appl y to aircraft with an airworthiness certificate. Applicant submits that the requeste d relief is proper since an equivalent level of safet y will be ensured. Applicant will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescrib ed in the operating documents

## 4 (i.e., Monthly

Maintenance Log, and Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) Manual s ). Furthermore, Applicant will document and maintain all maintenance records for the Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UASs. Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested by Applicant 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, b y meeting minimum flight

- hour and currency requirements, that the PIC is able to safel y operate the Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UASs in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Applicant seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness , because the Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Applicant submits that he will ensure that the Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UASs are in an airworthy condition, prior to every

flight, by determining that the UASs are in compliance with the operating documents (i.e., Naza v2 manual and the Tarot ZYX

- M manual ), and that the aircraft are in a condition for safe flight. Applicant also seeks an exemption from the requirements of Section 91.119 (c), entitled Minimum Safe Altitudes: General , as the Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UAs operate at low altitudes of 400 feet or less. Applicant also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , as the Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UAs will not have a ty pical barometric altimeter onboard. However, altitude information of Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UAs 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 Applicant ’s operation of the Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopt er(ZYX

- M) UASs within visual line of sight, at or below 500 feet AGL, will ensure a level of safet y equivalent to Section 91.121. Additionally, Applicant seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions

. Applicant submits that safety will not be affected b y operation of the Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UAs during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a tota l duration of approximately 15 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. In accordance with 14 C.F.R. § 11.81, Applicant provides the following information in support of its petition for exemption:

## 5 Name And Address Of The Petitioner. The name and address of the Petitioner and point of contact is: Ringo Long 519 River Landing Drive Soddy Dais y, TN 37379 (423) 834

- 0433 Email: ringolong@gmail.com



### The Specific Sections Of 14 C.F.R. From Which Applicant Seeks Exemption. **Applicant Seeks Exemption From The Requirements Of Section 61.23(a).**  **Medical certifi cates:**  **Requirement and duration.** (a) Operations requiring a medical certificate. Except as provided in paragraphs (b) a nd (c) of this section. **Applicant Seeks Exemption From The Requirements Of Section 61.101(e4)**  **Recreational pilot privileges and**  **limitations. (e)**  Except as provided in paragraphs (d) and (i) of this section, a recreational pilot may not act as pilot in command of an aircraft

— **(iv)** With retractable landing gear; **Applicant 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 PI C of an aircraft. (b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with an y 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

fo r compensation or hire. **Applicant Seeks Exemption From The Requirements Of Section 315 (a).**  61.315 What are the privileges and limits of my sport pilot certificate? **(a)** If you hold a sport pilot certificate you may act as pilot in command of a light

- sport aircraft, except as specified in paragraph (c) of this section. **Applicant 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

opera te a civil aircraft unless it is in an airworthy condition. **Applicant Seeks Exemption From The Requirements Of Section 91.119 (c).**  Except when necessary

for takeoff or landing, no person may operate an aircraft below the following altitudes: **Applicant 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

## 6 case may be, by reference to an altimeter that is set, when operating

-- (1) Below 18,000 feet MSL , to

-- (i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure. **Applicant Seeks Exemption From The Requirements Of Section 91.151(b).**  Section 91.151, entitled Fuel requirements for flight in VFR conditions , subsection (b), states the following: (b ) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes. **Applicant Seeks Exemption From The Requirement Of Section 91.405(a).**  Section 91.405, entitled Maintenance required , subsection (a), states the following: Each owner or operator of an aircraft

— (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.] **Applicant S**  **eeks Exemption From The Requirements Of Section 91.407(a)(1)**  Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration , subsection (a)(1), states the following: (a) No person may

operate any

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

-- (1) It has been approved for return to service by a person authorized under § 43.7 of this chapter[.] **Applicant Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2).**  Section 91.409, entitled Inspections , subsection (a), states the following: (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless , within the preceding 12 calendar months, it has had

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

§ 43.7 of this chapter; or (2) An inspection for the issuan ce of an airworthiness certificate in accordance with part 21 of this chapter. **Applicant Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b).**  Section 91.417, entitled Maintenance records , subsections (a) and (b), state the following : (a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preventive maintenance , and alteration and records of the 100

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

-- (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.

## 7 (ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safe ty directives including, for each, the method of compliance, the AD or safet y 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 prescri bed b y § 43.9(d) of this chapter for each major alteration to the airframe and currentl y installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed: (1) The records speci fied in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded b y other work or for 1 ye ar after the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retained and transferred wi th 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.



### The Ext ent Of Relief Applicant Seeks And The Reason Applicant Seeks The Relief. **Extent Of Relief Applicant**  **Seeks And The Reason Applicant**  **Seeks Relief From Section 61.23(a).** Medical certificates: Requirement and duration. (a) Operations requiring a medical certificate. Except as provided in paragraphs (b) and (c) of this section. The PI C will not be operating a aircraft which is capable of carrying passengers or the pilot. **Extent Of Relief Applicant**  **Seeks And The Reason Applicant**  **Seeks Relief From Section 61.101(e4).**  61.101 Recreational pilot privileges and limitations. **(e)** Except as provided in paragraphs (d) and (i) of this section, a recreational pilot may not act as pilot in command of an aircraft

— **(iv)** With retractable landing gear; as the Tarot 680mm hexacopter(ZYX

- M) has retractable landing gear which is integral to the operation of the camera. The landing gear lifts to allow 360 degree rotation of the camera without interference b y the landing gear. This operation is ultimately safer th an rotating the entire Tarot 680mm hexacopter(ZYX

- M) do the simplification of the rotation process. **Extent Of Relief Applicant**  **Seeks And The Reason Applicant**  **Seeks Relief From Section 61.113(a) And (b).** Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command , is requested to the extent necessary to allow a PIC holding a private pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met certain flight

- h our 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 an y b usiness or employ

ment 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 full y b elow, Applicant submits that an equivalent level of safet y will be maintained because no PI C will be allowed to ope rate the Diatone 500mm quadcopter(NAZA V2) or Tarot 680mm hexacopter(ZYX

- M) UAS unless that PIC has met certain flight

- hour and currency requirements, demonstrating that the PIC is able to safely operate either the Diatone 500mm quadcopter(NAZA V2) or Tarot 680mm hexacopter(ZYX

- M) UAS in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures. Further, Applicant submits that all flights of the Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UASs, conducted b y the PIC pursuant to the grant of this Petition: (1) will be incidental to Applicant 's business; and (2) will not carr y p assengers or property for compensation or hire.

## 8 **Extent Of Relief Applicant**  **Seeks And The Reason Applicant**  **Seeks Relief From Section 91.7(a).** Relief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to the extent required to allow Applicant to determine that the Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UASs are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., the Applicant Aerial Operations Manual, Monthly Maintenance Log, and Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) Instruction Manual s ). Applicant seeks the requested relief because the Di atone 500mm quadcopter (NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Applicant will ensure that the Di atone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UASs are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly

Maintenance Log, and Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) Instruction Manual s ) prior to every flight, and further, determine th at the aircraft are in condition for safe flight, as stated in the conditions and limitations below. **Extent Of Relief Applicant**  **Seeks And The Reason Applicant**  **Seeks Relief From Section 91.119 (c).** Relief from Section 91.119 (c), entitled Minimum Safe Altitudes: General , as the Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UAs operate at low altitudes of 400 feet or less. **Extent Of Relief Applicant**  **Seeks And The Reason Applicant**  **Seeks Relief From Section 91.121**
**.** Relief from Section 91.121 , entitled Altimeter settings , may be required to allow flight operations of the Di atone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UASs, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any altitude informati on concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), Applicant seeks the requested relief because the Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UA’s altimeter may be set on the g round to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight. Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply

with the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level of safety will be maintained since the Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UAs are equipped with a barometric pressure sensor and GPS equipment, which automatically

ensures that a ground level pressure setting will be established prior to each flight, and provides the PI C with altitude information of the UA on the heads

- up display of the GCS. **Extent Of Relief Applicant**  **Seeks And The Reason**  **Applicant Seeks Relief From Section 91.151(b).**  Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions , is requested to the extent required to allow flights of the battery powered Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UAs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fl y after that for at least 4.5 minutes. Applicant seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UAs will seve rel y constrain the practicality of any aerial video or still photo flight operations that Applicant proposes to conduct pursuant to this Petition. Significantl y, as set forth below, the technical specifications of the Di atone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UASs, the Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) operating documents, and Applicant ’s proposed operating limitations, ensure that Applicant will safel y operate the battery powered Di atone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) 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. **Extent Of Relief Applicant**  **Seeks And The Reason Applicant**  **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 appl y to aircraft with an airworthiness certificate, Applicant requests relief from these Sections because the Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacop ter(ZYX

- M) UASs do not require airworthiness certificates. As set forth more full y b elow, the Di atone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

-

## 9 M) UASs meet the conditions of FMRA Section 333 for operation without an airworthiness certificat e. Accordingl y, Applicant 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 Applicant Aerial Operations s al, Monthly Maintenance Log, and Di atone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) Instruction Manual s ). Furthermore, Applicant will document and maintain all maintenance records for the Di atone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UASs.


### The Reasons Why Granting Applicant 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 Applicant to safel y, efficiently, and economicall y perform aerial video and photography of construction sites, real estate, and landscape over certain areas of the United States. Additionally, use of the Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter (ZYX

- M) UASs will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy . Notably, the benefits of Applicant ’s proposed operation of the Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UASs wil l be realized without implicating any privacy issues. **The Public Will Benefit From Decreased Congestion Of The NAS.** The Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UAs are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionall y utilized to obtain aerial imagery . By

reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowi ng the use of a Di atone 500mm quadcopter(NAZA V2) or Tarot 680mm hexacopter(ZYX

- M) UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground. Furthermore, b y reducing the number of manned aircraft operating in the NAS, congestion around airports caused b y arriving and departing aircraft will be reduced. The Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UAs do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photograph y missions would result in fewer aircraft that must be handled b y air traffic control during the ground, takeoff, departure, arrival, and landing p hases of flight operations. **The Public Will Benefit From The Safety And Efficiency Of The Diatone 500mm quadcopter(NAZA V2)**  **and Tarot 680mm hexacopter(ZYX** 

**- M)**  **UASs.** Conducting aerial acquisitions with the Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UASs, instead of manned aircraft, will greatly benefit the public by

drasticall y reducing the levels of air and noise pollution generated during traditional aerial video and still photograph y flight operations. By

using battery

power and electric motors, the Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UASs produce no air pollution, and is the most viable environmentall y conscious alternative to the cabin class, six cy linder internal combustion engine aircraft that a re typicall y utilized for aerial video and photography, while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The Di atone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UAs, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAs are propelled b y b attery powered electric motors, rather than an internal combustion engine. By using the Diatone 500mm quadcopter(NAZA V2) and T arot 680mm hexacopter(ZYX

- M) UASs 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 substantially reduced or compl etely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UAs (weighing under 2 pounds and 5 pounds respectivel y, at their maximum gross weights with l engths of 16 inche s and 28 inches respectively , and with no fuel on board), has less physical potential for collateral damage to life and propert y on the ground, and in the air, compared to the manned aircraft that ty picall y conduct similar operations (wei ghing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacit y of 180 gallons). **Performing Aerial Video and Photography Operations With The Di**  **atone 500mm quadcopter(NAZA V2) and**  **Tarot 680mm hexacopter (ZYX** 

**- M)**  **UASs Will Benefit The Economy.**

## 10 In addition to being safe and efficient, the Di atone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UASs are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UASs will allow United States based companies, like Applicant , to remain competitive and contribute to growth of the U.S. economy. 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 companie s must adopt new and alternative technology in order to remain competitive. Operating the battery

powered Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UASs is one such technology

that not only

allows companies greater operational fle xibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft. By operating the Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UASs, companies such as the Applic ant , 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 Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UASs, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in or der to remain competitive both in the United States and abroad. **There Are No Privacy Issues.** Similar to the manned aerial acquisition flight operations that have been conducted for decades, Applicant ’s proposed operation of the Di atone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UASs will not implicate any privacy issues. Specifically, the Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UASs will be operated only in compliance with operating documents (i.e., the Applic ant Aerial Operations Manual, Monthly Maintenance Log, and Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) Instruction Manual s ) which requires property owner involvement as well as local law enforcement notification, and in accordance w ith the Federal Aviation Regulations, including 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 Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which Applicant Seeks Exemption. **Reasons Why The Diatone 500mm quadcopter(NAZA V2)**  **and Tarot 680mm hexacopter(ZYX** 

**- M)**  **UAs Meet The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333.**  In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, Applicant ’s operation of the Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UASs meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requir ements 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 requirem ent of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act. (b ) Assessment of Unmanned Aircraft Systems.

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

-- (1 ) whi ch 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 s ystem or the public or pose a threat to national security; and (2 ) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1). (c) Requirements for Safe Operation.

--If the Secretary determines under this section that certain unmanned

## 11 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, Applicant submits that the Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UASs can operate safely in the NAS purs uant to FMRA Section 333, as demonstrated b y: (a) the characteristics of the Di atone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UASs; (b) the pilot certification requirement; and (c) the specific operating limitations. **a. The Specifications Of The Di**  **atone 500mm quadcopter(NAZA V2) and**  **Tarot 680mm hexacopter(ZYX**

  ** M)** **UASs Demonstrate Its Safe Characteristics.** The Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UASs do 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 Di**  **atone 500mm quadcopter(NAZA V2) and**  **Tarot 680mm hexacopter(ZYX** 

**- M)**  **UASs.** The technical specifications of the Di atone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UASs are set forth b y the Di atone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) Specifications and Data Sheet, attached hereto as Exhibit A and B. **ii. The Diatone 500mm quadcopter(NAZA V2)**  **and Tarot 680mm hexacopter(ZYX** 

**- M)**  **UASs Autonomous Flight And Navigation Modes Enable The UASs To Remain Within A Defined**  **Operational Area.** The Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UASs may be operated in both manual and fully autonomous flight modes. A complete description of the flight and navigational modes of the Diatone 500mm quadcopter( NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UASs is provided at pages 10

- 11 of the DJ I Naza v2 and page 8 of the Tarot ZYX

- M User Manuals, attached hereto as Exhibit C and D. **iii. The Di**  **atone 500mm quadcopter(NAZA V2) and**  **Tarot 680mm hexacopter(ZYX**

**- M)**  **UASs Are Designed For Automatic Return To Home Point Or Hover In The Event Of Loss Of The**  **Control Link Or Navigation.** When the Control Link is lost, the Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UAs will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UAs do not reacquire control link data from the GCS, the UAs will assume that the Control L ink is lost and the UAs will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown. A complete descripti on of the Failsafe Functions of the Diatone 500mm quadcopter(NAZA V2) UAS are set forth at page 16 and for the Tarot 680mm hexacopter(ZYX

- M) at pages 12 through 13 of the Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) User Manuals, att ached hereto as Exhibit C and D. **iv. The Di**  **atone 500mm quadcopter(NAZA V2) and**  **Tarot 680mm hexacopter(ZYX**

**- M)**  **GCS And Its Operation.**  A complete description of the operation and specifications of the Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) GCS and flight control software is provided in the User Manual s

. The Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) User Manuals are attached hereto as Exhibits C and D. **b. Flight Operations Of Di**  **atone 500mm quadcopter(NAZA V2)**  **and Tarot 680mm hexacopter(ZYX** 

**- M)**  **UASs Are Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer.** Applicant will only

utilize certificated pilots who possess a current and valid airman medical certificate to act as a pilot in command (PIC) of the Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UASs. Additionally, a safety observer will assis t all pilots during flight time. **c. Flights Of Diatone 500mm quadcopter(NAZA V2)**  **and Tarot 680mm hexacopter(ZYX** 

**- M)**  **UASs Will Be Conducted Pursuant To Specific Operating Limitations.**  In seeking this exemption, Applicant proposes to commercially operate Di atone 500mm quadcopter(NAZA V2)

## 12 and Tarot 680mm hexacopter(ZYX

- M) UASs for the special purpose of conducting aerial video and photography over certain areas of United States, pursuant to the following specific operating limitations: 1. Operations authorize d 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: Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) Unmanned Aircraft Sy stems. 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 photog raphy

. 3. The UAs may

not be flown at an indicated airspeed exceeding 20 knots. 4. The UA must be operated at an altitude of no more than 500 feet above ground level (AGL), as indicated b y the procedures specified in the operating documents unless a speci al request is made and approved b y ATC. All altitudes reported to ATC must be in feet AGL. 5. The UAs must be operated within visual line of sight (VLOS) of the PI C at all times. This requires the PI C to be able to use human vision unaided by any device o ther than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate. 6. The use of first person view (FPV) b y the PIC or safety 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 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 designate d before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the SO can perform the functions prescribed in the operating documents. 8. The SO must not perform any other duties beyond assisting th e 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 operating documents, the conditions and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may

update or revise its operating documents. I t is the operator’s responsibility to track suc h revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its grant of exemption. The FAA’s UAS I ntegration 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 f rom operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records. 11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PI C who conducts the fu nctional 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 doc uments. 13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. 14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of

## 13

replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature o f the authorized person returning the UAS to service. 15. Each UASs operated under this exemption must comply with all manufacturer Safety Bulletins. 16. The authorized person must make an entry in the aircraft record of the corrective action taken again st discrepancies discovered between inspections. 17. The PIC must possess at least a private pilot certificate and at least a current third

- class medical certificate. 18. The operator may

not permit any

PI C to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including eva sive 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 of training the oper ator’s PICs are permitted under the terms of the exemption. However, training operations may

onl y be conducted during dedicated training sessions. During training, proficiency, and experience

- building flights, all persons not essential for flight operation s are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119. 19. UAS operations may

not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). I f flight at night is required, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized. 20. The UA may

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

- published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a 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 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 unpredicted obstacles or emergencies in accordance with the operating documents. 24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 25% battery power remaining. 25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting an y operations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more th an 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 must comply

with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made available to the Administrator or any l aw enforcement official upon request. 29. The UA must remain clear and y ield the right of way

to all manned aviation operations and

## 14

activities at all times. 30. The UAS may

not be operated b y the PIC from any moving device or vehicle. 31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PI C has made a safety assessment of the risk of o perating closer to those objects and determined that it does not present an undue hazard, and; c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a). 32. All operations shall be conducted over private or controlled

- access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted. 33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

. **Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Advers ely**  **Affect Safety.** Applicant submits that the equivalent level of safety established b y Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UASs unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the Diatone 500mm quadcopter(NAZA V2) or Tarot 680mm hexacopter(ZYX

- M) UAS in a manner consistent with the exemption, i ncluding evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering Applicant ’s proposed area of operations, and the operating limitations set forth

- above; the parallel nature of privat e pilot aeronautical knowledge requirements to those of commercial pilot requirements ( See Exemption No. 11062); and the airmanship skills necessary to safel y operate the Diatone 500mm quadcopter(NAZA V2) or Tarot 680mm hexacopter(ZYX

- M) UAS, Applicant sub mits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for Applicant ’s specific proposed flight operations. The FAA has previously

granted relief from Section 61.11 3(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 1 1161). Applicant will not allow any PI C to operate the Diatone 500mm quadcopter(NAZA V2) or Tarot 680mm hexacopter(ZYX

- M) UAS unless that PIC has demonstrated, by meeting minimum flight

- hour requirements or the Diatone 500mm quadcopter(NAZA V2) or Tarot 680mm hexacopter(ZYX

- M) UAS training and currency requirements, that the PIC is able to safely operate the Diatone 500mm quadcopter(NAZA V2) or Tarot 680mm hexacopter(ZYX

- M) UAS in a manner consistent with this exemption, including evasive and emerge ncy maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Specificall y, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot ( with a minimum of 5 hours of those hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). I n addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safet y during Applicant ’s proposed operations. The Adm inistrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows:

## 15 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 requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi

- rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. I n addition to the hour requirements, the PIC 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 safel y 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 PIC is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15. Accordingl y, Applicant will ensure safe operations by not allowing any P IC to operate the Diatone 500mm quadcopter(NAZA V2) or Tarot 680mm hexacopter(ZYX

- M) UAS unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safel y operate the Diatone 500mm quadcopter(NAZA V2) or Tarot 680mm hexacopter(ZYX

- M) UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. **Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Ad versely Affect**  **Safety.** The equivalent level of safety established b y Section 91.7(a) will be maintained because prior to every flight, Applicant will ensure that the Diatone 500mm quadcopter(NAZA V2) or Tarot 680mm hexacopter(ZYX

- M) UAS is in an airworthy condition based upon the UAS’s compliance with its operating documents and as stated in the conditions and limitations herein. Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstanc es 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). **Reasons Why An Exemption From The Requirements Of Section**  **91.119 (c) and 91.121 Would Not**  **Adversely Affect Safety.** The equivalent level of safety established b y Section s 91.119 (c) and 91.121 will be maintained because the altitude information of the Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UAs 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 Applicant ’s operation of the Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UAs within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information will be generated 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 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). **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. Sectio n 91.151(b) as a result of (1) the technical specifications of the Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UASs; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Acco rdingl y, Applicant will ensure that it will safely operate the battery powered Di atone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UAs during day light hours in

## 16 VFR conditions, with enough battery power to fly for a tota l duration of 15 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. Here, as in Exemption No. 11109, the technical specifications of the Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacop ter(ZYX

- M) UASs; 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, safety will be ensured as the Di atone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UASs provide audible and visual warnings to the PIC at the GCS when the UAs experiences low battery

voltage, the first warning occurring at approximately 33% remaining battery

power, and again at approx imately

10% remaining battery

power. At the critically low battery level, the Di atone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UASs will descend and land automatically

. Significantl y, previous exemptions granted b y the FAA concerning Se ction 91.151 establish that safety 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 91.1 51, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). **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, Applicant submits that the equivalent level of safet y with regard to the regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.40 7(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because Applicant will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operati ng documents (i.e., the Applicant Aerial Operations Manual, Monthly Maintenance Log, and Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) Instruction Manual s ). Furthermore, Applicant will document and maintain all maintenance records for the Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UASs. Since the Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UASs will be inspected as prescribed by the operating documents, Applicant will maintain the equivalent level of safet y established by

Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the Di atone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) User Manuals are attached hereto a s Exhibit C and D

. Likewis e, the exemption sought will not adversely affect safety because Applicant will use trained technicians to perform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed b y the operating docume nts. Furthermore, the exemption sought would maintain an equivalent level of safet y established b y Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UASs will be pe rformed by trained 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 adversely affected when the technical characteristics and operating limitations of the UAS are considered. In consideration of Applicant ’s proposed operating limitations, the operating documents, and the technical aspects of the Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UASs, Applicant submits that safety

will not be adversely

affected by

granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted relief specific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). **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 , Applicant requests that the FAA prescribe special conditions for the intended operation of the Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UASs, which contain such safety

standards that the Administrator finds necessary to establish a level of safety equivalent to

## 17 that established by

14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAs for the limited purpose of conducting aerial video and photograph y over certain areas of the United States for compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification in accordance with any requirements that must be established for the safe operation of the U AS in the NAS. Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of the Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UASs, since the airworthiness 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 airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or unusual design feature of the aircraft, aircraft engine or p ropeller, 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 safet y s tandards for the aircraft, aircraft engine or propeller as the FAA find s 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 the Applicant intended operation of the Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UASs, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpar t 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).

 **A Summary That Can Be Published In The Federal Register,**  **stating: The Rules From Which Applicant**  **Seeks Exemption:** Applicant 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 Applicant**  **Seeks:** This exemption will permit Applicant 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 Supp ort**  **Applicant ’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, Applicant ’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 pub lic, or otherwise pose a threat to national securit y; and further, provides the authority for such UAS to operate without airworthiness certification. As discussed in detail above, Applicant will operate the Diatone 500mm quadcopter(NAZA V2) and Tarot 68 0mm hexacopter(ZYX

- M) 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, Applicant 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 Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UASs commerciall y, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernizatio n and Reform Act of 2012, while also advancing the interests of the public, by allowing

## 18 Applicant to safel y, efficiently, and economically operate the Di atone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UASs commercially within the NAS. WH EREFORE , in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, Applicant respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a ) & (b), and permit the Applicant to operate the Diatone 500mm quadcopter(NAZA V2) and Tarot 680mm hexacopter(ZYX

- M) UASs commercially for the purpose of conducting aerial video and photography over certain areas of the United States.

R espectfully

submitted,

Ringo R. Long 519 River Landing Drive , Soddy Dais y, TN 37379 ringolong@gmail.com (423) 834

- 0433