UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: LASHBRO, LLC FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMEN TS 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) CONCERNI NG COMMERCIAL OPERATION OF DJI INSPIRE 1 UNMANNED AIRCRAFT SYSTEM S

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

(PUBLIC LAW 112-95)

Submitted on August 25, 2015 Rodney B. Kolash Lashbro, LLC 1258 Robin Street De Pere, WI 54115 Tel: (920) 360-60022 TABLE OF CONTENTS Page

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

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

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

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

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

BACKGROUND.........................................

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

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

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

NAME AND ADDRESS OF PETITIONER..................... .......................................8

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH LASHB RO, LLC SEEKS EXEMPTION....................................

................................................... .......8 THE EXTENT OF RELIEF LASHBRO, LLC SEEKS AND THE REA SON LASHBRO, LLC SEEKS THE RELIEF...................... .........................................12 THE REASONS WHY GRANTING LASHBRO, LLC REQUEST WOULD BE IN THE PUBLIC INTEREST ................................ ............................................15

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY............................ ..............................................18

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGIST ER......32 ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT LASHBRO, LLC REQUEST.......... ........................33

CONCLUSION.........................................

................................................... ........................33

APPENDICES.........................................

................................................... .........................353 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 2 012 (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 Lashbro, LLC seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407( a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft Sy stem pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). Th is exemption will permit Lashbro, LLC to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography of const ruction sites, real estate, special events, film sets, and landscape over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER Lashbro, LLC provides its clients with expertise an d knowledge in advanced technologies and solutions to increase efficiency, productivity and effectiveness. Lashbro, LLC also provides its clients with the highest qual ity digital content for use in their commercial, personal, and non-profit multimedia pro jects. Lashbro, LLC has over 26 years of professional experience in photography and video taping. Lashbro, LLC produces

television commercials and a television series call ed “Mad Dog & Merrill’s Midwest Grill’n” (www.MadDogandMerrill.com ), has provided professional Video and Photography services to corporations like Kimberly- Clark (Neenah, WI) and advertising agencies like Brand Directions (Appleton, WI) and A rketype (Green Bay, WI) as well as residential photography and videography. In additio n, Lashbro, LLC provides FREE video services for community firefighter training. The ob jective of Lashbro, LLC aerial video and photography operations is to provide high quali ty imaging for a variety of commercial, public, and residential uses, targeting: Aerial inspections of public and private structures

. Search and Rescue operations5 Aerial photography/videography of houses / resident ial and commercial buildings Aerial event photography/videography Aerial event filming Aerial Appraisals Real Estate Marketing Insurance Inspections of Home and Property Commercial Advertising Video and Photography Real Estate Photography and Videography FREE services offered to our community, firefighter and state officials Nature Monitoring

BACKGROUND

Unmanned Aircraft Systems: DJI Inspire 1 UAS Lashbro, LLC seeks an exemption to operate DJI syst ems for compensation or hire within the NAS. The DJI Inspire 1 is a vertical takeoff an d landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The DJI Inspire 1 has a maximum gross weig ht of 6.47 pounds, a length of 17.25 inches, width of 17.76 inches, height of 11.85 inch es, and a maximum speed of approximately 42.75 knots. The DJI Inspire 1 UA is equipped with four main rotors ; Driven by Lithium Polymer battery powered electric motors. The DJI Inspire 1 UA that will be operated by Lashbro, LLC and will be regist ered 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, Lashbro, LLC, pursuant to the provision s of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Moderni zation and Reform Act of 20126

(FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereby petitions the Administrator to commercially operate the DJI Inspire 1 UAS in the National Airspace System (NAS), and for an exemption from th e requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405 (a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). In consideration of the speed, weight, size, and li mited operating area associated with the unmanned aircraft and its operation, Lashb ro, LLC operation of DJI Inspire 1 UAS

meets the conditions of FMRA Section 333 and theref ore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, S ubpart H. Accordingly, Lashbro, LLC requests relief from Sect ions 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as thes e sections set forth requirements for maintenance that only apply to aircraft with an air worthiness certificate. Lashbro, LLC submits that the requested relief is p roper since an equivalent level of safety will be ensured. Lashbro, LLC will use ex perienced personnel or technicians to perform maintenance, alterations, or preventive mai ntenance on the UAS using the methods, techniques, and practices prescribed in th e operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 Instruction Manu al) ). Furthermore, Lashbro, LLC will

document and maintain all maintenance records for t he DJI Inspire 1 UAS

. Relief from certain requirements of Section 61.113( a) and (b), entitled Private pilot privileges and limitations: Pilot in command , is requested by Lashbro, LLC 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 certifica te, and who has demonstrated, by meeting minimum flight- hour and currency requirements, tha t the PIC is able to safely operate the7

DJI Inspire 1 UAS in a manner consistent with this exemption, inc luding evasive and emergency maneuvers and maintaining appropriate dis tances from people, vessels,

vehicles and structures. Lashbro, LLC seeks relief from Section 91.7(a), ent itled Civil aircraft

airworthiness , because the DJI Inspire 1 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As su ch, Lashbro, LLC submits that they

will ensure that the DJI Inspire 1 UAS are in an airworthy condition, prior to every flig ht, by determining that the UASs are in compliance with th e operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual), and that the aircraft are in a condition for safe flight. Lashbro, LLC also seeks an exemption from the requi rements of Section 91.121,

entitled Altimeter Settings , as the DJI Inspire 1 UAS will not have a typical barometric altimeter onboard. However, altitude information of the DJI Inspire 1 UAS will be provided to the PIC via Global Positioning System (GPS) equi pment 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 wi th Lashbro, LLC operation of DJI Inspire

1 UAS within visual line of sight, at or below 400 fe et AGL, will ensure a level of safety equivalent to Section 91.121. Additionally, Lashbro, LLC seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions . Lashbro, LLC submits that safety will not be affected by operation of th e DJI Inspire 1 UAS during daylight hours in visual meteorological conditions (VMC) under vis ual flight rules (VFR), with enough battery power to fly for a total duration of approx imately 13.5 minutes to the first point of8

intended landing and, assuming normal cruising spee d, to fly after that for at least 4.5

minutes. In accordance with 14 C.F.R. § 11.81, Lashbro, LLC provides the following information in support of its petition for exemptio n:

A. Name And Address Of The Petitioner. The name and address of the Petitioner and point of contact is: Rodney B. Kolash Lashbro, LLC 1258 Robin Street De Pere, WI 54115 Tel: (920) 360-6002 Email: rod@lashbro.com B. The Specific Sections Of 14 C.F.R. From Which La shbro, LLC Seeks Exemption. 1. Lashbro, LLC Seeks Exemption From The Requirements Of Section 61.113(a) And (b). Section 61.113, entitled Private pilot privileges a nd limitations: Pilot in command , subsections (a) and (b) prescribe the following, in relevant part: (a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire , act as PIC of an aircraft. (b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if— (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or prope rty for compensation or hire.

2. Lashbro, LLC Seeks Exemption From The Requiremen ts Of Section 91.7(a). Section 91.7, entitled Civil aircraft airworthiness , subsection (a), states the following:9 (a) No person may operate a civil aircraft unless i t is in an airworthy condition.

3. Lashbro, LLC Seeks Exemption From The Requirements Of Section 91.121. Section 91.121, entitled Altimeter settings, subsec tion (a), states the following, in

part: (a) Each person operating an aircraft shall maintai n the cruising altitude or flight level of that aircraft, as the case may be, by refe rence to an altimeter that is set, when operating-- (1) Below 18,000 feet MSL, to-- (i) The current reported altimeter setting of a sta tion along the route and within 100 nautical miles of the aircraft; (ii) If there is no station within the area prescri bed in paragraph (a) (1) (i) of this section, the current reported altimeter settin g 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 setti ng available before departure.

4. Lashbro, LLC 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 un der VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assumin g normal cruising speed, to fly after that for at least 20 minutes.

5. Lashbro, LLC Seeks Exemption From The Requirement O f 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 prescribe d 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[.]10 6. Lashbro, LLC Seeks Exemption From The Requiremen ts 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 und ergone maintenance, preventive maintenance, rebuilding, or alteration unless-- (1) It has been approved for return to service by a person authorized under § 43.7 of this chapter [.] 7. Lashbro, LLC Seeks Exemption From The Requiremen ts 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 sec tion, no person may operate an aircraft unless, within the preceding 12 calendar m onths, 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 aut horized by § 43.7 of this chapter; or (2) An inspection for the issuance of an airworthin ess certificate in accordance with part 21 of this chapter. 8. Lashbro, LLC Seeks Exemption From The Requiremen ts 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 followi ng records for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preventive maintena nce, and alteration and records of the 100-hour, annual, progressive, and o ther required or approved inspections, as appropriate, for each aircraft (inc luding the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include--11 (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 ea ch airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul of all items ins talled on the aircraft which are required to be overhauled on a specified time b asis. (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 compl iance, the AD or safety directive number and revision date. If the AD or sa fety directive involves recurring action, the time and date when t he 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 inst alled engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the followin g records for the periods prescribed: (1) The records specified in paragraph (a)(1) of th is section shall be retained until the work is repeated or superseded by other w ork or for 1 year after the work is performed. (2) The records specified in paragraph (a) (2) of t his section shall be retained and transferred with the aircraft at the time the a ircraft is sold. (3) A list of defects furnished to a registered own er or operator under § 43.11 of this chapter shall be retained until the defects ar e repaired and the aircraft is approved for return to service.12

C. The Extent Of Relief Lashbro, LLC Seeks And The Reason Lashbro, LLC Seeks The Relief. 1. Extent Of Relief Lashbro, LLC Seeks And The Reas on Lashbro, LLC 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 P IC holding a private pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met certain flight-hour an d currency requirements, to conduct the proposed UAS flight operations for compensation or hire. This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does n ot carry passengers or property for compensation or hire. As set forth more fully below, Lashbro, LLC submits that an equivalent level of safety will be maintained because no PIC will be al lowed to operate the DJI Inspire 1 UAS unless that PIC has met certain flight-hour and cur rency requirements, demonstrating that the PIC is able to safely operate either the DJI Inspire 1 UAS in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropr iate distances from people, vessels,

vehicles and structures. Further, Lashbro, LLC submits that all flights of t he DJI Inspire 1 UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to Lashbro, LLC business; and (2) will not carry passengers or prop erty for compensation or hire.13 2. Extent Of Relief Lashbro, LLC Seeks And The Reas on Lashbro, LLC 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 Lashbro, LLC to determine that the DJI Inspire 1 UAS are in airworthy condition prior to every flight by ensuri ng that the UAS is in compliance with the operating documents (i.e., the Lashbro, LLC Aer ial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Instruction Manu al). Lashbro, LLC seeks the requested relief because the DJI Inspire 1 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Lashbro, LLC will ensure that the DJI In spire 1 UAS are in airworthy condition based upon its compliance with the operating docume nts (i.e., Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual) prior to ever y flight, and further, determine that the aircraft are in condition for safe flight, as state d in the conditions and limitations below. 3. Extent Of Relief Lashbro, LLC Seeks And The Reas on Lashbro, LLC Seeks Relief From Section 91.121. Relief from Section 91.121, entitled Altimeter sett ings, may be required to allow flight operations of the DJI Inspire 1 UAS, which u tilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry dat a link to downlink altitude information from the UA to the PIC at the ground co ntrol station (GCS). Since the FAA requires that any altitude information concerning U AS operations be reported to air traffic control (ATC) in feet above ground level (AGL), Las hbro, LLC seeks the requested relief because the DJI Inspire 1 UA’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitud e, before each flight. Considering the limited altitude of the proposed op erations, relief from 14 CFR 91.121 is sought to the extent necessary to comply with the applicable conditions and14

limitations stated below. As more fully set forth h erein, an equivalent level of safety will be maintained since the DJI Inspire 1 UA are equipp ed 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 t he PIC with altitude information of the UA on the heads-up display of the GCS. 4. Extent Of Relief Lasbro, LLC Seeks And The Reaso n Lashbro, LLC Seeks Relief From Section 91.151(b). Relief from Section 91.151(b) entitled Fuel require ments for flight in VFR conditions, is requested to the extent required to allow flights of the battery powered DJI Inspire 1 UA during daylight hours in visual meteor ological 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. Lashbro, LLC seeks the requested relief because wit hout an exemption from Section 91.151(b), the flight time duration of the battery powered DJI Inspire 1 UAs will severely constrain the practicality of any aerial video or s till photo flight operations that Lashbro, LLC proposes to conduct pursuant to this Petition. Significantly, as set forth below, the technical sp ecifications of the DJI Inspire 1 UAS, the DJI Inspire 1 operating documents, and Las hbro, LLC proposed operating limitations, ensure that Lashbro, LLC will safely o perate the battery powered DJI Inspire 1 UA during daylight hours in visual meteorological c onditions (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 norma l cruising speed, to fly after that for at

least 4.5 minutes.15 5. Extent Of Relief Lashbro, LLC Seeks And The Reas on Lashbro, LLC Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.40 9(a)(1) & (a)(2), And 91.417(a) & (b). Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1 ) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certif icate, Lashbro, LLC requests relief from these Sections because the DJI Inspire 1 UAS do not require airworthiness certificates. As set forth more fully below, the DJI Inspire 1 UAS meet the conditions of FMRA Section 333 for operation without an airworthiness certific ate. Accordingly, Lashbro, LLC will use trained technicians to perform maintenance, alterat ions, or preventive maintenance on the UAS using the methods, techniques, and practices pr escribed in the UAS operating documents (i.e., the Lashbro, LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, Lashbro, LLC will document and maintain all maintenance records for the DJI Inspir e 1 UAS. D. The Reasons Why Granting Lashbro, LLC Request Wo uld Be In The Public Interest; That Is, How It Would Benefit The Public As A Whole. Granting the present Petition will further the publ ic interest by allowing Lashbro, LLC to safely, efficiently, and economically perfor m aerial video and photography of construction sites, real estate, special events, fi lm sets, and landscape over certain areas of

the United States. Additionally, use of the DJI Inspire 1 UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of Lashbro, LLC proposed operation of the DJI Inspire 1 UAS will be realized without implicating any privacy issues. 1. The Public Will Benefit From Decreased Congestio n Of The NAS.16 The DJI Inspire 1 UAs are battery powered and serve as a safe, effici ent, and

economical alternative to the manned aircraft tradi tionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJI Inspire 1 UAS w ould 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 aircr aft operating in the NAS, congestion around airports caused by arriving and d eparting aircraft will be reduced. The DJI Inspire 1 UA do not require an airport to takeoff or land. Li kewise, a reduction of manned aircraft conducting aerial video and photogr aphy missions would result in fewer aircraft that must be handled by air traffic contro l during the ground, takeoff, departure, arrival, and landing phases of flight operations. 2. The Public Will Benefit From The Safety And Effi ciency Of The DJI Inspire 1 UAS. Conducting aerial acquisitions with the DJI Inspire 1 UASs, instead of manned aircraft, will greatly benefit the public by drasti cally reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, the DJI Inspire 1 UAS produce no air pollution, and is the most viable environmentally c onscious alternative to the cabin class, six cylinder internal combustion engine aircraft th at are typically utilized for aerial video and photography, while burning approximately 20-30 gallons per hour of leaded aviation fuel. The DJI Inspire 1 UA, while reducing the carbon footprint of aerial a cquisitions, also eliminates noise pollution, as the UA are propelled by battery powered electric motors, rather than an internal combustion engine.17 By using the DJI Inspire 1 UAS to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew memb ers located onboard the aircraft, the DJI Inspire 1 UA (weighing approximately 6.47 pounds respectively , at its maximum gross weight with a length of 17.25 inches and width of 1 7.76 inches, and with no fuel on board), has less physical potential for collateral damage t o life and property on the ground, and in the air, compared to the manned aircraft that typic ally conduct similar operations (weighing approximately 6,000 pounds with a wingspa n of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons). 3. Performing Aerial Video and Photography Operatio ns with DJI Inspire 1 UAS Will Benefit The Economy. In addition to being safe and efficient, the DJI In spire 1 UAS are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Inspire 1 UAS will allow United States based companies, like Lashbro, LLC, to remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviat ion fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery powered Inspire 1 UAS is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft. By operating the DJI Inspire 1 UAS, companies such as Lashbro, LLC, can remain competitive and profitable, and therefore, provide greater job stability to employees and18

contractors, which will ultimately contribute to gr owth of the U.S. economy. Improved financial performance of U.S. companies, through co mmercial use of the DJI Inspire 1 UAS, provides a stable workforce that increases con sumer spending; improves local, state, and federal tax revenues; and allows companies to i nvest in research and development in order to remain competitive both in the United Stat es and abroad. 4. There Are No Privacy Issues. Similar to the manned aerial acquisition flight ope rations that have been conducted for decades, Lashbro, LLC proposed operation of the DJI Inspire 1 UAS will not implicate any privacy issues. Specifically, the DJI Inspire 1 UAS will be operated only in compliance with operating documents (i.e., the Lashbro, LLC Ae rial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual) which requires property owner

involvement as well as local law enforcement notifi cation, 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 Safet y At Least Equal To That Provided By The Rule From Which Lashbro, LLC Seeks Exemption. 1. Reasons Why The DJI Inspire 1 UA Meet The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333. In consideration of the size, weight, speed, and li mited operating area associated with the unmanned aircraft and its operation, Lashb ro, LLC operation of the DJI Inspire 1 UAS meet the conditions of FMRA Section 333, and wi ll not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, S ubpart H. Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for consi dering whether a UAS will create a19

hazard to users of the NAS or the public, or otherw ise 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 befo re 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 ma king the determination under subsection (a), the Secretary shall determine, at a minimum-- (1) which types of unmanned aircraft systems, if an y, as a result of their size, weight, speed, operational capability, proxim ity to airports and populated areas, and operation within visual line o f sight do not create a hazard to users of the national airspace system o r 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 air craft systems identified under paragraph (1). (c) Requirements for Safe Operation.--If the Secret ary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall estab lish requirements for the safe operation of such aircraft systems in the national airspace system. In seeking this exemption, Lashbro, LLC submits tha t the DJI Inspire 1 UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI Inspire 1 UAS; (b) the p ilot certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The DJI Inspire 1 UAS Demonstrate Its Safe Characteristics. The DJI Inspire 1 UAS do not create a hazard to use rs of the NAS or the public, or otherwise pose a threat to national security consid ering its size, weight, speed, and operational capability.20 i. Technical Specifications Of The DJI Inspire 1 UAS. The technical specifications of the DJI Inspire 1 U AS are set forth by the DJI Inspire 1 Specifications and Data Sheet, attached h ereto as Exhibit A.

ii. The DJI Inspire 1 UAS Autonomous Flight And Nav igation Modes Enable The UAS To Remain Within A Defined Operation al Area. The DJI Inspire 1 UAS may be operated in both manua l and fully autonomous flight modes. A complete description of the flight and nav igational modes of the DJI Inspire 1 UAS is provided in the Manufacturer’s User Manual *See attached PDF File iii. The DJI Inspire 1 UAS Are Designed For Automatic Return To Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation. When the Control Link is lost, the DJI Inspire 1 UA will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Inspire 1 UA do not reacquire control link data from the GCS, the UAs will assume that the Control Link is lost and the UAs will return to the home position (i.e., failsaf e mode) via GPS, and will descend to the takeoff position and shutdown. A complete description of the Failsafe Functions of the DJI Inspire 1 UAS is provided in the Manufacturer’s User Manual *See attached PDF

iv. The DJI Inspire 1 GCS And Its Operation. A complete description of the operation and specifi cations of the DJI Inspire 1 GCS and flight control software is provided in the Manufacturer’s User Manual *See attached

PDF b. Flight Operations Of DJI Inspire 1 UAS Are Limited To The Line Of

Sight Of A Certificated Pilot in Command With A Saf ety Observer. Lashbro, LLC will only utilize certificated pilots who possess a current and valid airman medical certificate to act as a pilot in com mand (PIC) of the DJI Inspire 1 UAS. Additionally, a safety observer will assist all pil ots during flight time.21 c. Flights Of DJI Inspire 1 UAS Will Be Conducted Pursuant To Specific Operating Limitations. In seeking this exemption, Lashbro, LLC proposes to commercially operate DJI Inspire 1 UAS for the special purpose of conducting aerial vi deo and photography over certain areas of United States, pursuant to the fol lowing specific operating limitations: 1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, roto rcraft UASs weighing less than 55 pounds maximum gross weight: DJI Inspire 1 Unmanned Aircraft Systems. 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 limi ted to conducting operations for the purpose of aerial video and photography. 3. The UAs may not be flown at an indicated airspee d exceeding 20 knots. 4. The UA must be operated at an altitude of no mor e than 500 feet above ground level (AGL), as indicated by the procedures specifi ed in the operating documents unless a special request is made and appr oved by ATC. All altitudes reported to ATC must be in feet AGL. 5. The UAs must be operated within visual line of s ight (VLOS) of the PIC at all times. This requires the PIC to be able to use huma n vision unaided by any device other than corrective lenses, as specified o n the PIC’s FAA-issued airman medical certificate. 6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted. 7. All operations must utilize a safety observer (S O). The SO may be used to satisfy the VLOS requirement as long as the PIC always main tains VLOS capability. The SO and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer hi s or her designation for the duration of the flight. The PIC must ensure that th e SO can perform the functions prescribed in the operating documents. 8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground bas ed obstacles/obstructions and is not permitted to operate the camera or other ins truments. 9. The operating documents and the grant of exempti on must be accessible during UAS operations and made available to the Administra tor upon request. If a discrepancy exists between the conditions and limit ations contained in the grant22 of exemption and the procedures outlined in the ope rating documents, the conditions and limitations contained in the grant o f exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator m ay update or revise its operating documents. It is the operator’s responsib ility to track such revisions and present updated and revised documents to the Ad ministrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. I f the operator determines that 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 Integration Office (AFS-80 ) may be contacted if questions arise regarding updates or revisions to t he operating documents. 10. Prior to each flight the PIC must inspect the U AS to ensure that it is in a condition for safe flight. If the inspection reveal s a condition that affects the safe operation of the UAS, the aircraft is prohibit ed from operating until the necessary maintenance has been performed and the UA S is found to be in a condition for safe flight. The Ground Control Stati on must be included in the preflight inspection. All maintenance and alteratio ns must be properly documented in the aircraft records. 11. Any UAS that has undergone maintenance or alter ations that affect the UAS operation or flight characteristics, e.g. replaceme nt of a flight critical component, must undergo a functional test flight. T he PIC who conducts the functional test flight must make an entry in the ai rcraft records. 12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not alr eady 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, in spections, and record keeping requirements, in accordance with the operating docu ments. Maintenance, inspection, alterations, and status of replacement/ overhaul component parts must be noted in the aircraft records, including to tal time in service, description of work accomplished, and the signature of the auth orized person returning the UAS to service. 15. Each UASs operated under this exemption must co mply with all manufacturer Safety Bulletins. 16. The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies disco vered between inspections. 17. The PIC must possess at least a private pilot c ertificate and at least a current third- class medical certificate.23 18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS wil l be operated under the exemption, including evasive and emergency maneuver s and maintaining appropriate distances from persons, vessels, vehicl es and structures. PIC qualification flight hours must be logged in a mann er consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training th e operator’s PICs are permitted under the terms of the exemption. However , training operations may only be conducted during dedicated training session s. During training, proficiency, and experience-building flights, all p ersons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in a ccordance with 14 C.F.R. § 91.119. 19. UAS operations may not be conducted during nigh t, 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 re quest will be made at the FAA office closest to proposed area of operations. Flig hts 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 cha rt unless a letter of agreement with that airport’s management is obtaine d, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request. 21. The UA may not be operated less than 500 feet b elow or less than 2,000 feet horizontally from a cloud or when visibility is les s than 3 statute miles from the PIC.

22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating ar ea and land or be recovered in accordance with the operating documents. 23. The PIC must abort the flight in the event of u npredicted obstacles or emergencies in accordance with the operating docume nts. 24. The PIC is prohibited from beginning a flight u nless (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 Organiz ation (ATO) issued Certificate of Waiver or Authorization (COA) prior to conductin g any operations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance , but not less than 4824 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA in cluding class of airspace, altitude level and potential transponder requiremen ts. 26. All aircraft operated in accordance with the ex emption must be identified by serial number, registered in accordance with 14 C.F .R. part 47, and have identification (N- Number) markings in accordance w ith 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable

. 27. Before conducting operations, the radio frequen cy spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government ov ersight 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 avai lable to the Administrator or any law enforcement official upon request. 29. The UA must remain clear and yield the right of way to all manned aviation operations and activities at all times. 30. The UAS may not be operated by the PIC from any moving device or vehicle. 31. Flight operations must be conducted at least 50 0 feet from all nonparticipating persons (persons other than the PIC, SO, operator t rainees or essential persons), vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficie ntly protect nonparticipating persons from the UA and/or debris in the event of a n accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticip ating persons leave such protection and are within 500 feet of the UA, fligh t 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 struc tures has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined th at it does not present an undue hazard, and; c. Operations nearer to the PIC, SO, operator train ees 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 a uthorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted.25 33. Any incident, accident, or flight operation tha t transgresses the lateral or vertical boundaries of the operational area as defi ned by the applicable COA must be reported to the FAA's UAS Integration Offic e (AFS-80) within 24 hours. Accidents must be reported to the National T ransportation Safety Board (NTSB) per instructions contained on the NTSB Web s ite: www.ntsb.gov

. 2. Reasons Why An Exemption From The Requirements O f Section 61.113(a) And (b) Would Not Adversely Affect Safety. Lashbro, LLC submits that the equivalent level of s afety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safe ly operate the DJI Inspire 1 UAS in a manner consistent with the exemption, including eva sive and emergency maneuvers and maintaining appropriate distances from people, vess els, vehicles and structures. Considering Lashbro, LLC proposed area of operation s, and the operating limitations set forth-above; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requireme nts (See Exemption No. 11062); and the airmanship skills necessary to safely operate t he DJI Inspire 1 UAS, Lashbro, LLC submits that the additional manned airmanship exper ience of a commercially certificated pilot would not correlate to the airmanship skills necessary for Lashbro, LLC 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 resp ects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 1 1067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11 160, 11161). Lashbro, LLC will not allow any PIC to operate the DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight-hou r requirements or the DJI Inspire 126

UAS training and currency requirements, that the PI C is able to safely operate the DJI Inspire 1 UAS in a manner consistent with this exem ption, including evasive and emergency maneuvers and maintaining appropriate dis tances from people, vessels,

vehicles and structures. Specifically, the PIC must have accumulated and log ged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time a s a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot op erating 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 app licable regulations will ensure an equivalent level of safety during Lashbro, LLC prop osed operations. The Administrator has held that prior documented flight experience th at 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 o perations), 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 l east 10 hours logged as a UAS pilot with a multi-rotor UAS. Prior to operations u nder 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 the se 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 th e 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addit ion 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 Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the petitioner’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance27 with applicable regulations would satisfy this requ irement. Training, proficiency, and experience-building flights can also be conduct ed under the grant of exemption to accomplish the required flight time. During trai ning, proficiency, and experience-building 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. Accordingly, Lashbro, LLC will ensure safe operatio ns by not allowing any PIC to operate the DJI Inspire 1 UAS unless that PIC has d emonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the DJI Inspire 1 UAS in a manner consistent with the exemption, in cluding evasive and emergency maneuvers and maintaining appropriate distances fro m people, vessels, vehicles and

structures. 3. Reasons Why An Exemption From The Requirements O f Section 91.7(a) Would Not Adversely Affect Safety. The equivalent level of safety established by Secti on 91.7(a) will be maintained because prior to every flight, Lashbro, LLC will en sure that the 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. Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all material r espects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 1 1067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11 159, 11160, 11161). 4. Reasons Why An Exemption From The Requirements O f Section 91.121 Would Not Adversely Affect Safety. The equivalent level of safety established by Secti on 91.121 will be maintained because the altitude information of the DJI Inspire 1 UA will be provided to the PIC via GPS equipment and a radio communications telemetry data link, which downlinks from28

the UA to the GCS for active monitoring of the flig ht path and altitude. This altitude information, combined with Lashbro, LLC operation o f the DJI Inspire 1 UA within visual line of sight, at or below 500 feet AGL, will ensur e a level of safety equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude 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, 1108 0, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11 161). 5. Reasons Why An Exemption From The Requirements O f Section 91.151(b) Would Not Adversely Affect Safety. A grant of this exemption would ensure an equivalen t level of safety established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJI Inspire 1 UAS; (2) the limitations on the proposed flight o perations; and (3) the location of the proposed flight operations. Accordingly, Lashbro, L LC will ensure that it will safely operate the battery powered DJI Inspire 1 UA during daylight hours in VFR conditions, with enough battery power to fly for a total durati on of 13.5 minutes to the first point of intended landing and, assuming normal cruising spee d, to fly after that for at least 4.5

minutes. Here, as in Exemption No. 11109, the technical spec ifications of the DJI Phantom 3 UAS; the limitations on the proposed flight operati ons; and the location of the proposed operations, will ensure an equivalent level of safe ty established by 14 C.F.R. Section 91.151(b). Furthermore and similarily, safety will be ensured as the DJI Inspire 1 UAS29

provide audible and visual warnings to the PIC at t he GCS when the UAs experiences low battery voltage, the first warning occurring at app roximately 33% remaining battery power, and again at approximately 10% remaining battery po wer. At the critically low battery level, the DJI Inspire 1 UAS will descend and land automatically. Significantly, previous exemptions granted by the F AA concerning Section 91.151 establish that safety is not adversely affected whe n the technical characteristics and operating limitations of the UAS are considered. Re lief has been granted for manned aircraft to operate at less than the minimums presc ribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in circumstanc es similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 1 0808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11 136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 6. Reasons Why An Exemption From The Requirements O f 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, Lashbro, LLC submits tha t the equivalent level of safety with regard to the regulatory maintenance and alter ation requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a )(2), and 91.417(a) & (b) will be met because Lashbro, LLC will use trained technicians t o perform maintenance, alterations, or preventive maintenance on the UAS using the methods , techniques, and practices prescribed in the operating documents (i.e., the La shbro, LLC, Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruct ion Manual). Furthermore, Lashbro,

LLC will document and maintain all maintenance reco rds for the DJI Inspire 1 UAS.30 Since the DJI Inspire 1 UAS will be inspected as pr escribed by the operating documents, Lashbro, LLC will maintain the equivalen t level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI Inspire 1 User Manuals are attached hereto as Exhibit B; a copy of the DJI Inspire 1 UAS Maintenance

LOG is attached hereto as Exhibit C. Likewise, the exemption sought will not adversely a ffect safety because Lashbro, LLC will use trained technicians to perform mainten ance, alterations or preventive maintenance on the UAS using the methods, technique s, and practices prescribed by the operating documents. Furthermore, the exemption sought would maintain an equivalent level of safety established by Sections 91.407, 91.417(a) and 91.41 7(b), because all maintenance of the DJI Inspire 1 UAS will be performed by trained tech nicians. Maintenance will be documented and maintained utilizing the monthly mai ntenance log. Significantly, previous exemptions granted by the F AA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the technical character istics and operating limitations of the

UAS are considered. In consideration of Lashbro, LLC proposed operating limitations, the operating documents, and the technical aspects of the DJI Ins pire 1 UAS, Lashbro, LLC submits that safety will not be adversely affected by granting e xemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), a nd 91.417(a) and (b). The FAA has previously granted relief specific to UAS in circum stances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 1106 2, 11063, 11064, 11065, 11066,31

11067, 11080, 11109, 11110, 11112, 11136, 11138, 11 150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 7. The FAA May Prescribe Any Other Conditions For S afe Operation.

In accordance with Section 333 of the FAA Moderniza tion and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Condi tions, Lashbro, LLC requests that the FAA prescribe special conditions for the intended o peration of the DJI Inspire 1 UASs, which contain such safety standards that the Admini strator finds necessary to establish a level of safety equivalent to that established by 1 4 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 condition s will permit safe operation of the UA for the limited purpose of conducting aerial video and photography over certain areas of the United States for compensation or hire. FMRA Se ction 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 f urther, 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 UAS in the NAS. Likewise, the Administrator may prescribe special c onditions pursuant to 14 C.F.R. § 21.16, for operation of the DJI Inspire 1 UAS, si nce the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropria te safety standards, due to the novel or unusual design features of the aircraft. Section 21 .16, entitled Special Conditions, states the following: If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an air craft, aircraft engine, or propeller because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and ame ndments thereto for the product.32 The special conditions are issued in accordance wit h Part 11 of this chapter and contain such safety standards for the aircraft, air craft 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 Lashbro, LLC i ntended operation of the DJI Inspire 1 UAS, which contain such safety standards that the A dministrator finds necessary to establish a level of safety equivalent to that esta blished by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91. 121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

F. A Summary That Can Be Published In The Federal Reg ister, stating: The Rules From Which Lashbro, LLC Seeks Exemption: Lashbro, LLC 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 Lashbro, LLC Seeks: This exemption will permit Lashbro, LLC to commerci ally 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 Ava ilable To Support Lashbro, LLC Request. This Petition is made pursuant to the FAA Moderniza tion 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, Lashbro , LLC request for exemption may be granted pursuant to the authority of FMRA Sectio n 333 and 14 C.F.R. Part 11, as set

forth above.33 FMRA Section 333 sets forth the requirements for co nsidering 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 s uch UAS to operate without airworthiness

certification. As discussed in detail above, Lashbro, LLC will ope rate the DJI Inspire 1 UAS safely in the NAS, without creating a hazard to use rs of the NAS, or the public, or otherwise pose a threat to national security.

CONCLUSION As set forth herein, Lashbro, LLC seeks an exemptio n pursuant to 14 C.F.R. §

11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI Inspire 1 UAS 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 and Reform Act of 2012, while also advancing the intere sts of the public, by allowing Lashbro, LLC to safely, efficiently, and economically operat e the DJI Inspire 1 UAS commercially

within the NAS.

WHEREFORE , in accordance with the Federal Aviation Regulatio ns and the FAA Modernization and Reform Act of 2012, Section 333, Lashbro, LLC respectfully requests that the Administrator grant this Petition for an e xemption 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 per mit Lashbro, LLC to operate the DJI34

Inspire 1 UAS commercially for the purpose of condu cting aerial video and photography

over certain areas of the United States.

Dated: August 25, 2015

Respectfully submitted, Lashbro, LLC /s/ Rodney B. Kolash

_________________________ Rodney B. Kolash 1258 Robin Street De Pere, Wisconsin 54115 Tel: (920) 360-600235 Appendices : A – DJI Inspire 1 Technical Specifications B – DJI Inspire 1 Monthly Maintenance Log

APPENDIX – A DJI Inspire 1 TECHNICAL SPECIFICATIONS Drone Sky Vision , LLC only utilizes safe and reliable UASs. DJI is an industry leader in small UAS production. DJI UASs are loaded with ground bre aking software enabling the user to set parameters which will not allow flight into control led airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJI so ftware provides real-time altitude and location information to the PIC via the linked moni tor (smart phone/tablet devices)

Aircraft MODEL T600 WEIGHT (BATTERY INCLUDED) 2935 g HOVERING ACCURACY (GPS MODE) Vertical: 0.5 m Horizontal: 2.5 m MAX ANGULAR VELOCITY Pitch: 300°/s Yaw: 150°/s MAX TILT ANGLE 35° MAX ASCENT SPEED 5 m/s MAX DESCENT SPEED 4 m/s MAX SPEED 22 m/s (ATTI mode, no wind) MAX FLIGHT ALTITUDE 4500 m MAX WIND SPEED RESISTANCE 10 m/s MAX FLIGHT TIME Approximately 18 minutes MOTOR MODEL36 DJI 3510 PROPELLER MODEL DJI 1345 INDOOR HOVERING Enabled by default OPERATING TEMPERATURE RANGE -10° to 40° C DIAGONAL DISTANCE 559 to 581 mm DIMENSIONS 438x451x301 mm

Gimbal MODEL ZENMUSE X3 OUTPUT POWER (WITH CAMERA) Static: 9 W In Motion: 11 W OPERATING CURRENT Station: 750 mA Motion: 900 mA ANGULAR VIBRATION RANGE ±0.03° MOUNTING Detachable CONTROLLABLE RANGE Pitch: -90° to +30° Pan: ±320° MECHANICAL RANGE Pitch: -125° to +45° Pan: ±330° MAX CONTROLLABLE SPEED Pitch: 120°/s Pan: 180°/s

Camera NAME X3 MODEL FC350 TOTAL PIXELS 12.76M EFFECTIVE PIXELS 12.4M IMAGE MAX SIZE 4000x3000 ISO RANGE 100-3200 (video)37 100-1600 (photo) ELECTRONIC SHUTTER SPEED 8s

- 1/8000s FOV (FIELD OF VIEW) 94° CMOS Sony EXMOR 1/2.3” LENS 20mm (35mm format equivalent)f/2.8 focus at ∞ 9 Elements in 9 groups Anti-distortion STILL PHOTOGRAPHY MODES Single shoot Burst shooting: 3/5/7 frames Auto Exposure Bracketing (AEB): 3/5 bracketed frame s at 0.7EV Bias Time-lapse VIDEO RECORDING MODES UHD (4K): 4096x2160p24/25, 3840x2160p24/25/30 FHD: 1920x1080p24/25/30/48/50/60 HD: 1280x720p24/25/30/48/50/60 MAX BITRATE OF VIDEO STORAGE 60 Mbps SUPPORTED FILE FORMATS FAT32/exFAT Photo: JPEG, DNG Video: MP4/MOV (MPEG-4 AVC/H.264) SUPPORTED SD CARD TYPES Micro SD Max capacity: 64 GB. Class 10 or UHS-1 rating requi red. OPERATING TEMPERATURE RANGE 0° to 40° C

Remote Controller NAME C1 OPERATING FREQUENCY 922.7~927.7 MHz (Japan Only) 5.725~5.825 GHz 2.400~2.483 GHz TRANSMITTING DISTANCE (OUTDOOR AND UNOBSTRUCTED) 2 km EIRP 10dBm@900m, 13dBm@5.8G, 20dBm@2.4G VIDEO OUTPUT PORT USB, mini-HDMI POWER SUPPLY Built-in battery38 CHARGING DJI charger DUAL USER CAPABILITY Host-and-Slave connection MOBILE DEVICE HOLDER Tablet or Phone MAX MOBILE DEVICE WIDTH 170mm OUTPUT POWER 9 W OPERATING TEMPERATURE RANGE -10° to 40° C STORAGE TEMPERATURE RANGE Less than 3 months: -20° to 45° C More than 3 months: 22° to 28° C CHARGING TEMPERATURE RANGE 0-40° C BATTERY 6000 mAh LiPo 2S

Charger MODEL A14-100P1A VOLTAGE 26.3 V RATED POWER 100 W

Battery (Standard) NAME Intelligent Flight Battery MODEL TB47 CAPACITY 4500 mAh VOLTAGE 22.2 V BATTERY TYPE LiPo 6S High voltage battery ENERGY 99.9 Wh NET WEIGHT 570 g OPERATING TEMPERATURE RANGE -10° to 40° C STORAGE TEMPERATURE RANGE Less than 3 months: -20° to 45° C More than 3 months: 22° C to 28° C39 CHARGING TEMPERATURE RANGE 0° to 40° C MAX CHARGING POWER 180 W

Battery (Optional) NAME Intelligent Flight Battery MODEL TB48 CAPACITY 5700 mAh VOLTAGE 22.8 V BATTERY TYPE LiPo 6S ENERGY 129.96 Wh NET WEIGHT 670 g OPERATING TEMPERATURE RANGE -10° to 40° C STORAGE TEMPERATURE RANGE Less than 3 months: -20 to 45° C More than 3 months: 22° to 28° C CHARGING TEMPERATURE RANGE 0° to 40° C MAX CHARGING POWER 180 W

Vision Positioning VELOCITY RANGE Below 8 m/s (2 m above ground) ALTITUDE RANGE 5-500 cm OPERATING ENVIRONMENT Brightly lit (lux > 15) patterned surfaces OPERATING RANGE 0-250 cm

DJI GO App MOBILE DEVICE SYSTEM REQUIREMENTS iOS 8.0 or later, Android 4.1.2 or later SUPPORTED MOBILE DEVICES * Compatible with iPhone 5s, iPhone 6, iPhone 6 Plu s, iPad Air, iPad Air Wi- Fi + Cellular, iPad mini 2, iPad Wi-Fi + Cellular, iPad Air 2, iPad Air 2 Wi- Fi + Cellular, iPad mini 3, and iPad mini 3 Wi optimized for iPhone 5s, iPhone 6, and iPhone 6 Plu s. * Compatible with Samsung tabs 705c, Samsung S6, Sa msung S5, Samsung NOTE4, Nexus 9, Google Nexus 7 II, Ascend Mate7, Nubia Z7 mini, SONY Z3 EXPERIA, MI 3, MI PAD *Support for additional Android devices available a s testing and development continues.40 APPENDIX – B Monthly Maintenance Log

UAS #_____ Date Issue Maintenance Initials Performed Firmware Check Frame Engines Propellers Camera Gimbal Landing Gear Vibration Other: