June 25, 2015

Exemption No. 11909 Regulatory Docket No. FAA

– 20 15

– 1253

Mr. Andrew Bernstein GraVoc Associates, Inc. 81 Main Street Peabody
, MA 01960

Dear Mr. Bernstein :

This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends.

By letter dated March 27 , 2015 , you petitio ned the Federal Aviation Administration (FAA) on behalf of GraVoc Associates, Inc. ( hereinafter petitioner or operator ) for an exemption . The petitioner requested to operate an unmanned ai rcraft system (UAS) to conduct aerial photography and videography

. See Appendix A for the petition submitted to the FAA des cribing the proposed operations and the regulations that the petitioner seeks an exemption

. The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner

.
Airworthiness Certification

The UAS proposed by the petitioner are the DJI Phantom 2 and DJI Inspire 1

. In accordance with the statutory criteria provided in Section 333 of P ublic Law 112

− 95 in reference to 49 U

. S

. C

. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the Secretary of Transportation has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA2

finds that relief from 14 CFR part 21
, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates , and any ass ociated noise certification and testing requirements of part 36, is not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection 1

. The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 20 14

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the peti tioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public i nterest.
Having reviewed your reasons for requesting an exemption, I find that

—

 They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213 ;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to the situation you present; and

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, GraVoc Associates, Inc. is granted an exemption from 14 CFR §§ 61.23(a) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a) , 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection

. This exempti on is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, GraVoc Associates, Inc. is hereafter referred to as the operator.

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (part iculate measurement, etc.), or any other gathering of data by instruments aboard the UA.3

Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2 and DJI Inspire 1 when weighing less than 55 pounds including payload. Prop osed operations of any other aircraft will require a new petition or a petition to amend this exemption

.
2. Operations for the purpose of closed

- set motion picture and television filming are not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

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

- issued airman medical certificate or U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times ;
e lectronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the du ties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. Th e operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, t he conditions and limitations herein 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 respons ibility to track such revisions and present updated and revised4

documents to the Administrator or any law enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this gr ant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FA A’s UAS Integration Office (AFS− 8 0) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g.
, replacement of a flight critical compone nt, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must b e conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g.
, inoperable components, items, or equipment. 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.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul,

r eplacement, inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Col u mbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstr ates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC q ualification flight hours and currency must be logged in a manner consistent with5

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (traini ng, proficiency, and experience

- building) and determining the PIC’s ability to saf ely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During traini ng, pro ficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations ma y not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical mil es of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbo l as denoted on the current FAA

- published aeronautical chart, unless a letter of a greement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request

.
17. 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.

18. If the UAS loses communications or loses its GPS sign al, the UA must return to a pre

- det ermined location within the pr ivate or controlled

- access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be cond ucted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA

.
22. All a ircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.6

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

24. The UA must remain clear a nd give way to all manned aviation operations and activities at all times.

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

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, v ehicles, 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 protectio n. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons ; and b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects 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 undue hazard.

The PIC, VO, operator t rainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or control led

- access property with permission from the property owner/controller or authorized representative. P ermission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. 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 FA A'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

. If this exemption permits operations for the purpose of closed

- set motion picture and television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.7

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) wi th jurisdiction over the a rea of proposed filming. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights; b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of th e person responsible for the on

- scene operation of the UAS; d. Make, model, and serial or N− Number of UAS to be used;

e. Name and certificate number of UAS PICs involv ed in the aerial filming; f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request; g. Signature of exemption holder or representative; and h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operatio n.

31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.8

This exemption terminates on June 30, 2017 , unless sooner superseded or rescinded.

Sincerely,

/ s/ John S. Duncan Director, Flight Standards Service

EnclosuresUNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: GraVoc Associates, Inc. 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 PHANTOM 2 VISION+ AND DJI INS PIRE 1 UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)

Submitted on March 27 , 2015

Andrew Bernstein

GraVoc Associates, Inc. 81 Main Street Peabody, MA 01960 978.538.90552 TABLE OF CONTENTS

Page

GLOSSARY OF ABBREVIATIONS...................................................................................3

SUMMARY......................................................................................................................

. ....4

INTRODUCTION AND INTERESTS OF PETITIONER....................................................4

BACKGROUND................................................................................................................... .4

BASIS FOR PETITION.... .....................................................................................................5

NAME AND ADDRESS OF PETITIONER.............................................................7

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH GRAVOC ASSO CIATES, INC. SEEKS EXEMPTION............

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

THE EXTENT OF RELIEF GRAVOC ASSOCIATES, INC. SEEKS AND THE REASON GRAVOC ASSOCIATES, INC. SEEKS THE RELIEF...

... ...............11

THE REASONS WHY GRANTING GRAVOC ASSOCIAT ES, INC.’S REQUEST WOULD BE IN THE PUBLIC INTEREST

......... . . . . . . . . . . . . . . . . . . ..........15

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY..........................................................................19

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER......34

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT GRAVOC ASSOCIATES, INC.’S REQUEST .......3 4

CONCLUSION.......................................................................................... ..........................35

APPENDICES........................................................................................373 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
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 Landing4 SUMMARY

GraVoc Associates, Inc. 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

GraVoc Associates, Inc. to operate an Unmanned Aircraft System (UAS) for the
commercial purpose of conducting aerial videography and photography over certain areas

of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

GraVoc Associates, Inc. is a technology consulting firm with over 2 0 years of
professi onal experience in the Information Technology industry and is recognized as an
expert in Business Solutions, Information Security and Media Production. The objective of

GraVoc Associates, Inc. ’s aerial video graphy and photography operation s is to provide

h igh quality imaging for a variety of comme rcial and public uses, specifically targeting the
following :

• Marketing Materials & Promotional Materials

• Township Grant Creation

• Short

- Form and Long

- Form Video Production

• High Resolution Real Estate and Appraisal I magery

• Outdoor Event Video and Photo Coverage5 BACKGROUND
Unmanned Aircraft Systems: DJI Phantom 2

GraVoc Associates, Inc. seeks an exemption to operate a DJI system for
compensation or hire within the NAS. The DJI Phantom is a vertical takeoff and land ing
(VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing
electronic tablet or smart phone systems. The DJI Phantom 2 has a maximum gross weight
of approximately 2 pounds 3 ounces, while having a diagonal length of 13.8 inches, height
of 8 inches, and a maximum speed of approximately 29 knots. The DJI Phantom 2 is
equipped with four main rotors; driven by Lithium Polymer battery powered electric

motors.
The DJI Phantom 2 that will be operated by GraVoc Associates, Inc. will be
registe red 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, GraVoc Associate s, Inc. , 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 com mercially operate the DJI Phantom 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).6 In conside ration of the speed, weight, size, and limited operating area associated
with the unmanned aircraft and its operation, GraVoc Associates, Inc. ’s operation of DJI
Phantom 2 Vision+ and DJI Inspire 1 UASs meets the conditions of FMRA Section 333

and therefor e, will not require an airworthiness certificate in accordance with 14 C.F.R.
Part 21, Subpart H.
Accordingly, GraVoc Associates, Inc. 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.

GraVoc Associates, Inc. submits that the requested relief is proper since an
equivalent level of safety will be ensured. GraVoc Associates, Inc. will use ex perienced
personnel or technicians to perform maintenance, alterations, or preventive maintenance on
the UASs using the methods, techniques, and practices prescribed in the operating
documents (i.e., Monthly Maintenance Log , and DJI Phantom 2 Instruction M anual).

Furthermore, GraVoc Associates, Inc. will document and maintain all maintenance records

for the DJI Phantom 2.
Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot
privileges and limitations: Pilot in command , is r equested by GraVoc Associates, Inc. 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 curre ncy requirements, that the PIC is able to safely
operate the DJI Phantom 2 in a manner consistent with this exemption, including evasive
and emergency maneuvers and maintaining appropriate distances from people, vessels,

vehicles and structures.7 GraVoc As sociates, Inc. seeks relief from Section 91.7(a), entitled Civil aircraft

airworthiness
, because the DJI Phantom 2 do es not require an airworthiness certificate in
accordance with 14 C.F.R. Part 21, Subpart H. As such, GraVoc Associates, Inc. submits

that it will ensure that the DJI Phantom 2 is in an airworthy condition, prior to every flight,
by determining that the UAS is in compliance with the operating documents (i.e., Monthly
Maintenance Log, and DJI Phantom 2 Instruction Manual), and that the aircraf t are in a
condition for safe flight.

GraVoc Associates, Inc. also seeks an exemption from the requirements of Section

91.121, entitled Altimeter Settings , as the DJI Phantom 2 will not have a typical barometric

altimeter onboard. However, altitude inform ation of the DJI Phantom 2 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, c ombined with GraVoc Associates, Inc. ’s operation
of the DJI Phantom 2 within visual line of sight, at or below 500 feet AGL, will ensure a
level of safety equivalent to Section 91.121.
Additionally, GraVoc Associates, Inc. seeks an exemption from the requ irements of
Section 91.151(b), entitled Fuel requirements for flight in VFR conditions

. GraVoc

Associates, Inc. submits that safety will not be affected by operation of the DJI Phantom 2
during daylight hours in visual meteorological conditions (VMC) under visual flight rules
(VFR), with enough battery power to fly for a total duration of approximately 13.5 minutes
to the first point of intended landing and, assuming normal cruising speed, to fly after that

for at least 4.5 minutes.8 In accordance with 14 C .F.R. § 11.81, GraVoc Associates, Inc. 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:

GraVoc Associates, Inc. 81 Main Str eet Peabody MA 01960 978

- 538

- 9055 Email: abernstein@gravoc.com

B. The Spec ific Sections Of 14 C.F.R. From Which GraVoc Associates, Inc. Seeks Exemption.

1. GraVoc Associates, Inc. Seeks Exemption From The Requirements Of Section 61.113(a) And (b).

Secti on 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 employme nt 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. GraVoc Associates, Inc. Seeks Exemption From The Requirements Of Section 91.7(a).

Section 9 1.7, entitled Civil aircraft airworthiness , subsection (a), states the
following:9 (a) No person may operate a civil aircraft unless it is in an airworthy condition.

3. GraVoc Associates, Inc. Seeks Exemption From The Requirements Of Section 91.121.

Sec tion 91.121, entitled Altimeter settings , subsection (a), states the following, in

part:
(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, 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

.
4. GraVoc Associates, Inc. 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 u nder VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.

5. GraVoc Associates, Inc. See ks 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

—10 (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. GraVoc Associates, Inc. Seeks Exemption From The Requirements Of Section 91.407(a) (1)

Section 91.407, entitled Operation after maintenance, preventive maintenance,
rebuilding, or alteration
, subsection (a)(1), states the following:
(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuildin g, or alteration unless

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

7. GraVoc Associates, Inc. Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2).

Section 91.409, e ntitled 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 wi th 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 issuance of an airworthiness certificate in accordance with part 21 of this chapter.

8. GraVoc Associate s, Inc. 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 reg istered 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 requi red or approved inspections, as appropriate, for each aircraft (including the airframe) and11 each engine, propeller, rotor, and appliance of an aircraft. The records must include

-- (i) A description (or reference to data acceptable to the Administrator) of the work performed; and

(ii) The date of completion of the work performed; and
(iii) The signature, and certificate number of the person approving the aircraft for return to service.

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

(ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance.
(iii) The time since last overhaul of all items installed on the aircraft w hich 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 safety 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 a nd date when the next action is required.
(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall reta in 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 specifi ed in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold.12 (3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defect s are repaired and the aircraft is approved for return to service.

C. The Extent Of Relief GraVoc Associates, Inc. Seeks And The Reason GraVoc Associates, Inc. Seeks The Relief.

1. Extent Of Relief GraVoc Associates, Inc. Seeks And The Reason GraVoc Ass ociates, Inc. 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 who has
met certain flight

- hour and c urrency 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 ai rcraft 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, GraVoc Associate s, Inc. submits that an equivalent
level of safety will be maintained because no PIC will be allowed to operate the DJI
Phantom 2 unless that PIC has met certain flight

- hour and currency requirements,
demonstrating that the PIC is able to safely operate ei ther the DJI Phantom 2 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.13 Further, GraVoc Associates, Inc. submits that all flights of the DJI Phantom 2,
conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to

GraVoc Associates, Inc. ’s business; and (2) will not carry passengers or property for
compensatio n or hire.

2. Extent Of Relief GraVoc Associates, Inc. Seeks And The Reason GraVoc Associates, Inc. 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 GraVoc Associates, Inc. to determine that the DJI Phantom 2 is in
airworthy condition prior to every flight by ensuring that the UAS is in compliance with
the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 Instruction
Manual).

GraVoc Asso ciates, Inc. seeks the requested relief because the DJI Phantom 2 does
not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Therefore, GraVoc Associates, Inc. will ensure that the DJI Phantom 2 is in airworthy

condition based upon its compliance with the operating documents (i.e ., Monthly
Maintenance Log, and DJI Phantom 2 Instruction Manual) prior to every flight, and

further, determine that the aircraft is in condition for safe flight, as stated in the conditions

and l imitations below.

3. Extent Of Relief GraVoc Associates, Inc. Seeks And The Reason GraVoc Associates, Inc. Seeks Relief From Section 91.121.
Relief from Section 91.121, entitled Altimeter settings , may be required to allow
flight operations of the DJI Ph antom 2, which utilize s 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 inform ation concerning UAS operations be reported to air traffic14 control (ATC) in feet above ground level (AGL), GraVoc Associates, Inc. seeks the
requested r elief because the DJI Phantom 2’s altimeter may be set on the ground to zero

feet AGL, rather than the l ocal 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 DJI Phantom 2 is equipped with a barometric pressure sensor and
GPS equipment, which automatically ensures that a ground level pressure setting will be

established prior to each flight, and provides the PIC with altitude information of the UA

on the heads

- up display of the GCS.

4. Extent Of Relief GraVoc Associates, Inc. Seeks And The Reason GraVoc Associates, Inc. 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 DJI
Phantom 2 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 minutes. GraVoc

Associates, Inc. seeks the requested relief because without an exemption from Section
91.151(b), the flight time duration of the battery powered DJI Phantom 2 will severely
constrain the practicality of any aerial video or still photo flight operations that GraVoc

Associates, Inc. proposes to conduct pursuant to this Petition.
Significant ly, as set forth below, the technical specifications of the DJI Phantom 2,
the DJI Phantom 2 operating documents, and GraVoc Associates, Inc. ’s proposed
operating limitations, ensure that GraVoc Associates, Inc. will safely operate the battery15 powered DJI Phantom 2 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 GraVoc Associates, Inc. Seeks And The Reason GraVoc Associates, Inc. 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), 9 1.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b)
only apply to aircraft with an airworthiness certificate, GraVoc Associates, Inc. requests

relief from these Sections because the DJI Phantom 2 do es not require airworthiness

certificates. As set fort h more fully below, the DJI Phantom 2 meets the conditions of
FMRA Section 333 for operation without an airworthiness certificate. Accordingly,

GraVoc Associates, Inc. will use trained technicians to perform maintenance, alterations,
or preventive maintena nce on the UAS using the methods, techniques, and practices
prescribed in the UAS operating documents (i.e., Monthly Maintenance Log, and DJI
Phantom 2 Instruction Manual). Furthermore, GraVoc Associates, Inc. will document and

maintain all maintenance rec ords for the DJI Phantom 2.

D. The Reasons Why Granting GraVoc Associates, Inc. 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 Gra Voc

Associates, Inc. to safely, efficiently, and economically perform aerial video graphy and
photography for a variety of purposes over certain areas of the United States.
Additionally, use of the DJI Phantom 2 will decrease congestion of the NAS,

reduce pollution, and provide significant benefits to the economy. Notably, the benefits of16 GraVoc Associates, Inc. ’s proposed operation of the DJI Phantom 2 will be realized
without implicating any privacy issues.

1. The Public Will Benefit From Decreased Conge stion Of The NAS.

The DJI Phantom 2 is battery powered and serve s as a safe, efficient, and
economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery.
By reducing the amount of manned aircraft needed to perform aerial a cquisitions, an
exemption allowing the use of a DJI Phantom 2 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, by reducing the number of manned aircraft operating in the NAS,
congestion around airports caused by arriving and departing aircraft will be reduced. The

DJI Phantom 2 does 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 control during the ground, takeoff, departure,
arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Effici ency Of The DJI Phantom 2

. Conducting aerial acquisitions with the DJI Phantom 2, instead of manned aircraft,
will greatly benefit the public by drastically reducing the levels of air and noise pollution
generated during traditional aerial video and stil l photography flight operations. By using
battery power and electric motors, the DJI Phantom 2 produce s 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 DJI17 Phantom 2, while reducing the carbon footprint of aerial acquisitions, also eliminates noise
pollution, as the UA is propelled by battery powered electric motors, rather than an internal
combustion engine.
By using the DJI Phantom 2 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
2 (weighing approximately 2 pounds 3 ounces and with no fuel on board), has less physical
potential for collateral damage to life and property on the ground, and in the air, compared
to the manned aircraft that typically conduct similar operations (weighing approximately
6,000 pounds and a fuel capacity of 180 gallons ).

3. Performing Aerial Video and Photography Operations With The DJI Phantom 2 Vision+ and DJI Inspire 1 UASs Will Benefit The Economy.
In addition to being safe and efficient, the DJI Phantom 2 is also an economical
alternative to using manned aircraf t to conduct similar aerial operations. As such, operation

of the DJI Phantom 2 will allow United States based companies, like GraVoc Associates,

Inc. , to remain competitive and contribute to growth of the U.S. economy. Specifically,

with the general trend of rising aviation fuel costs 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 b attery powered DJI Phantom 2 is one such technology that not
only allows companies greater operational flexibility compared to manned aircraft, but
provides such flexibility without the high operational cost of a traditional manned aircraft.18 By operating the DJI Phantom 2 , companies such as GraVoc Associates, Inc. , 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

financi al performance of U.S. companies, through commercial use of the DJI Phantom 2
, 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 orde r
to remain competitive both in the United States and abroad.

4. There Are No Privacy Issues.
Similar to the manned aerial acquisition flight operations that have been conducted for

decades, GraVoc Associates, Inc. ’ s proposed operation of the DJI Phantom 2 Vision+ and
DJI Inspire 1 UASs will not implicate any privacy issues. Specifically, the DJI Phantom 2
will be operated only in compliance with operating documents (i.e., Monthly Maintenance
Log, and DJI Phantom 2 Instruction Manual) which requires prope rty owner involvement

as well as local law enforcement notification, and in accordance with the Federal Aviation
Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which GraVoc Associates, Inc. Seeks Exemption.
1. Reasons Why The DJI Phantom 2 Meet s 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, GraVoc Associates, Inc. ’s operation of the

DJI Phantom 2 meet s the conditions of FMRA Sectio n 333, and will not require an
airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.19 Section 333 provides authority for a UAS to operate without airworthiness
certification and sets forth requirements for considering whether a UAS wil l 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 of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act.

(b) Assessment of Unmanned Aircraft Systems.

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

-- (1) which types of unmanned aircraft systems, i f 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 system or the public or pose a threat to national security; and
(2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified under para graph (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 o f such aircraft systems in the national airspace system.
In seeking this exemption, GraVoc Associates, Inc. submits that the DJI Phantom 2
can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the

characteristics of the DJI Phantom 2; (b) the pilot certification requirement; and (c) the
specific operating limitations.

a. The Specifications Of The DJI Phantom 2 Demonstrate Its Safe Characteristics.20 The DJI Phantom 2 do es 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 2

. The technical specifications of the DJI Phantom 2 are set forth by the DJI Phantom

2 Spec ifications and Data Shee t, attached hereto as Exhibit A

.
ii. The DJI Phantom 2 Autonomous Flight And Navigation Modes Enable The UAS To Remain Within A Defined Operational Area.

The DJI Phantom 2 may be operated in both manual and fully autonomous flight
modes. A complete description of the flight and navigational modes of the DJI Phantom 2
is provided starting at page 5 of the DJI Phantom User Manual , attached hereto as Exhibit

B

.
iii. The DJI Phantom 2 Vision+ and DJI Inspire 1 UASs Are Designed For Au tomatic 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 2 will remain stationary, in flight,

for 3 seconds or more. If, after 3 seconds, the DJI Phantom 2 do es not reacq uire 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 Failsafe Functions of the DJI Phantom 2 is set forth

at pages 2 5 through 2 6 attached hereto as Exhibit B.

iv. The DJI Phantom 2 GCS And Its Operation.21 A complete description of the operation and specifications of the DJI Phantom 2
GCS and flight control software is provided at pages 14 through 19 of the DJI Phantom 2

User Manual. The DJI Phantom 2 User Manual is attached hereto as Exhibit B

.

b . Flights Of DJI Phantom 2 Will Be Conducted Pursuant To Specific Operating Limitations.
In seeking this exemption, Gra Voc Associates, Inc. proposes to commercially
operate DJI Phantom 2 for the special purpose of conducting aerial video graphy and
photography over certain areas of United States, pursuant to the following specific
operating limitations:
1. Operations author ized 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 2 Unmanned Aircraft System. Proposed operations of any other airc raft 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 UA may not be flown at an indicated airspeed exc eeding 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 UA 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 corrective lenses

. 6. The use of first person view (FPV) by the PIC 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 t imes. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the SO can perform the functio ns prescribed in the operating documents.22 8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is not permitted to operate the camera or other in struments.
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 exemp tion 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. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised document s 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

ex emption. 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. I f 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 Stat ion 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 PIC who conducts the functional test flight must make an entry in the aircraft records.
12. The pre

- flight inspection must account for all potential discrepancies, e. g. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents.
13. The operator must 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 replacement/overhaul component parts must be not ed in the aircraft records, including time in service, description of work accomplished, and the signature of the authorized person returning the UAS to service.23 15. Each UASs operated under this exemption must comply with all manufacturer Safety Bulleti ns. 16. The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections.

1 7 . The operator may not permit any PIC to operate unless the PIC meets the operator’s qualific ation 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, vehic les and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator’s PICs are permitted under the terms of the exemption. However, training operations may

on ly be conducted during dedicated training sessions. During training, proficiency, and experience

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

1 8 . UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized.

19 . 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 by the operator’s COA. The letter of agreement with the airport manageme nt must be made available to the Administrator upon request.

2 0 . 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.

2 1 . If the UA loses com munications 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.

2 2 . The PIC must abort the flight in the event of unpredicted obstacl es or emergencies in accordance with the operating documents.

2 3 . 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.24 2 4 . The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will also requi re the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requirements.

2 5 . 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.

2 6 . Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FC C) or other appropriate government oversight agency requirements.

2 7 . The documents required pursuant to 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 b e made available to the Administrator or any law enforcement official upon request.

2 8 . The UA must remain clear and yield the right of way to all manned aviation operations and activities at all times.

29 . The UAS may not be operated by the PIC from a ny moving device or vehicle.

3 0 . 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 s tructures 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 nonparticipatin g 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 gr anted 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 undue hazard, and;
c. Operations nearer to the PIC, SO, operator trainees or essential persons do not pr esent an undue hazard to those persons per § 91.119(a).25 3 1 . 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.

3 2 . 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

. 2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety.
GraVoc Associates, Inc. submits that the equivalent level of safety established by
Section 61.113(a) and (b) will be maintained because no PIC will be allowe d to operate the

DJI Phantom 2 unless that PIC has demonstrated, by meeting minimum flight

- hour and
currency requirements, that the PIC is able to safely operate the DJI Phantom 2 in a
manner consistent with the exemption, including evasive and emergency m aneuvers and
maintaining appropriate distances from people, vessels, vehicles and structures.
Considering GraVoc Associates, Inc. ’s proposed area of operations, and the
operating limitations set forth

- above; the parallel nature of private pilot aeronautic al
knowledge requirements to those of commercial pilot requirements ( See Exemption No.
11062); and the airmanship skills necessary to safely operate the DJI Phantom 2, GraVoc

Associates, Inc. submits that the additional manned airmanship experience of a

co mmercially certificated pilot would not correlate to the airmanship skills necessary for

GraVoc Associates, Inc. ’s specific proposed flight operations.
The FAA has previously granted relief from Section 61.113(a) and (b) specific to

UAS, in circumstances similar, in all material respects, to those presented herein (e.g.26 Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112,
11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

GraVoc Associates, Inc. will not allow any PIC to operate the DJI Phantom 2 UAS
unless that PIC has demonstrated, by meeting minimum flight

- hour requirements or the

DJI Phantom 2 training and currency requirements, that the PIC is able to safely operate

the DJI Phantom 2 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), 2 5 hours of total time as a UAS rotorcraft pilot (with a
minimum of 5 hours of those hours as a UAS pilot operating the same make and model of
UAS to be used for operations under the exemption). In addition to the hour requirements,
the 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 GraVoc Associates, Inc. ’s proposed operations. The
Administrator has held that prior documented flight experience that was obtained in
compliance with applicable regulations would ensure safe operations, stating as follows:
In Exemption No. 11062 , the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilo t 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 model of UAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements27 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 inc luded 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

- hour requirements in Exe mption No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the petitioner’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable re gulations 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

- building flights the PI C is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119.
Exemption No. 11138 at page 15.
Accordingly, GraVoc Associates, Inc. will ensure safe operations by not allowing
any PIC to operate the DJI Phantom 2 unless t hat PIC has demonstrated, by meeting
minimum flight

- hour and currency requirements, that the PIC is able to safely operate the
DJI Phantom 2 in a manner consistent with the exemption, including evasive and
emergency maneuvers and maintaining appropriate di stances from people, vessels,

vehicles and structures.

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety.
The equivalent level of safety established by Section 91.7(a) will be maintained
because prior to every flight, GraVoc Associates, Inc. will ensure that the DJI Phantom 2

Vision+ or DJI Inspire 1 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.

Add itionally, the FAA has previously granted relief from Section 91.7(a) specific
to UAS, in circumstances similar, in all material respects, to those presented herein (e.g.28 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 An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety.
The equivalent level of safety established by Section 91.121 will be maintained

because the altitude information of the DJI Phantom 2 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 informati on,

combined with GraVoc Associates, Inc. ’s operation of the DJI Phantom 2 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 by GPS equipm ent 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 al l 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. Section 91.151(b) as a result of (1) the technical specifications of the DJI

Phantom 2 ; (2) the limitations on the proposed flight operations; and (3) the location of the
proposed flight operations. Accordingly, GraVoc Associates, Inc. will ensure that it will
safely operate the battery powered DJI Phantom 2 during daylight hours in VFR
conditions, with enough battery power to fly for a total duration of 13.5 minutes to the first29 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 DJI Phan tom

2 ; the limitations on the proposed flight operations; and the location of the proposed
operations, will ensure an equivalent level of safety established by 14 C.F.R. Section
91.151(b). Furthermore, safety will be ensured as the DJI Phantom 2 provide au dible 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 le vel, the DJI
Phantom will descend and land automatically.
Significantly, previous exemptions granted by the FAA concerning Section 91.151
establish that safety is not adversely affected when the technical characteristics and
operating limitations of the U AS are considered. Relief has been granted for manned
aircraft to operate at less than the minimums prescribed in Section 91.151, including
Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief
from Section 91.151 specific t o 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, 1116 0, 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, GraVoc Associates, Inc. submits that the equivalen t
level of safety with regard to the regulatory maintenance and alteration requirements
established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b)30 will be met because GraVoc Associates, Inc. will use trained technicians to perform
maintenance, alterations, or preventive maintenance on the UASs using the methods,
techniques, and practices prescribed in the operating documents (i.e., Monthly
Maintenance Log, and DJI Phantom 2 Instruction Manual). Furthermore, GraVoc

Associates , Inc. will document and maintain all maintenance records for the DJI Phantom

2.
Since the DJI Phantom 2 will be inspected as prescribed by the operating

documents, GraVoc Associates, Inc. will maintain the equivalent level of safety
established by Sectio ns 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI

Phantom 2 User Manual is attached hereto as Exhibit B ; a copy of the DJI Phantom 2

Maintenance LOG is attached hereto as Exhibit C

. Likewise, the exemption sought will not adversely affect sa fety because GraVoc

Associates, Inc. will use trained technicians to perform maintenance, alterations or
preventive maintenance on the UAS using the methods, techniques, and practices
prescribed by the operating documents.
Furthermore, the exemption sough t would maintain an equivalent level of safety
established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the
DJI Phantom 2 will be performed by trained technicians. Maintenance will be documented
and maintained utilizing the month ly maintenance log.
Significantly, previous exemptions granted by 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 operat ing limitations of the

UAS are considered.31 In consideration of GraVoc Associates, Inc. ’s proposed operating limitations, the
operating documents, and the technical aspects of the DJI Phantom 2, GraVoc Associates,

Inc. submits that safety will not be adver sely 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 presente d herein (e.g. Exemption Nos. 11062, 11063, 11064,

11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156,
11157, 11158, 11159, 11160, 11161).

7. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance wit h Section 333 of the FAA Modernization and Reform Act of 2012
(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions
, GraVoc Associates, Inc.
requests that the FAA prescribe special conditions for the intended operation of the DJI

Phantom 2, which contai n 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 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 accor dance with
any requirements that must be established for the safe operation of the UAS in the NAS.32 Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R.
§ 21.16, for operation of the DJI Phantom 2, since the airworthiness regu lations of 14
C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or
unusual design features of the aircraft. Section 21.16, entitled Special Conditions , states
the following:

If the FAA finds that the airworthiness re gulations of this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent to that established in the regulations.

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA
may prescribe special conditions for GraVoc Associates, Inc.’s intended operation of the

DJI Phantom 2, which contain s 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),

91.4 07(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

F. A Summary That Can Be Published In The Federal Register, stating: The Rules From Which GraVoc Associates, Inc. Seeks Exemption:

GraVoc Associates, Inc. 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 GraVoc Associates, Inc. Seeks:33 This exemption will permit GraVoc Associates, Inc. to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States.

G. Any Additional Information, Views, Or Arguments Available To Support GraVoc Associates, I nc. ’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 safely in the NAS. As such, GraVoc Associates, Inc. ’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 publi c, 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, GraVoc Associates, Inc. will operate the DJI Phantom
2 safely in the NAS, wi thout creating a hazard to users of the NAS, or the public, or
otherwise pose a threat to national security.

CONCLUSION

As set forth herein, GraVoc Associates, Inc. seeks an exemption pursuant to 14

C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012
(FMRA), which will permit safe operation of the DJI Phantom 2 commercially, 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 Modernization and34 Reform Act of 2012, while also advancing the interests of the public, by allowing GraVoc

Associates, Inc. to safely, efficiently, and economical ly operate the DJI Phantom 2
commercially within the NAS.

WHEREFORE , in accordance with the Federal Aviation Regulations and the FAA

Modernization and Reform Act of 2012, Section 333, GraVoc Associates, Inc. respectfully
requests that the Administrator gr ant 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 GraVoc Associates, Inc. to operate

the DJI Phantom 2 commercially for the purpose of conducting aerial video and
photography over certain areas of the United States.

Date d: April 3 , 2015

Respectfully submitted,

GraVoc Associates, Inc.

_________________________ GraVoc Associates, Inc. 81 Main Street Peabody, MA 01960 978

- 538

- 9055

Appendic es :

A

– DJI Phantom 2 Specifications Data Sheet B

– DJI Phantom 2 Manufacturer’s User Manual C

– Monthly Maintenance Log