June, 11 2015 

Attn:

U. S. Department of Transportation Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Ave, SE Washington, DC 20590

RE: Mirror Mirror Digital Media, Inc

REQUEST AN EXEMPTION 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 

1/3, 3D Robotics Solo UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 

OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Matthew D. Pranzo

President

Mirror Mirror Digital Media, Inc.

5483 Fontaine Street 

San Diego, CA 92120

619-347-2694

pranzomatt@gmail.com

TABLE OF CONTENTS

Page 

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

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

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

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

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

1
NAME AND ADDRESS OF PETITIONER.........................................................................6 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH THE MIRROR MIRROR DIGITAL 

MEDIA, INC SEEKS 

EXEMPTION............................................................................................................7 

THE EXTENT OF RELIEF Mirror Mirror Digital Media, Inc SEEKS AND THE REASON THE

Mirror Mirror Digital Media, Inc SEEKS THE RELIEF...........

...................................................10

THE REASONS WHY GRANTING Mirror Mirror Digital Media, Inc REQUEST WOULD BE 

IN THE PUBLIC INTEREST ............................................................................................12 

THE REASONS WHY GRANTING THE EXEMPTION TO THE Mirror Mirror Digital Media, 

Inc WOULD NOT ADVERSELY AFFECT SAFETY..............................................................14

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER...................25 

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT THE Mirror Mirror Digital Media, Inc..................................................25 

CONCLUSION.....................................................................................................................25 

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) 

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

2
VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing

SUMMARY

Mirror Mirror Digital Media, 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 (DJI Phantom 1/3, 3D Robotics Solo)

pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This

exemption will permit Mirror Mirror Digital Media, Inc to operate an Unmanned Aircraft System

(UAS) for the commercial purpose of conducting aerial video and photography of construction

sites, residential and commercial real estate, civil landscapes and events over certain areas of the

United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

Mirror Mirror Digital Media, Inc has for over 20 years provided their clients (which include

private sector businesses and non-profits, along with local state and federal agencies) with

expertise and knowledge in video and multimedia marketing, advertising, public relations and

training using advanced technologies and solutions. Mirror Mirror Digital Media, Inc has worked

on hundreds of productions over the past 20years in all types of locations with a perfect client

and employee safety record. In the past we have supplied our clients aerial video and

photography using commercial aircraft. The objective of Mirror Mirror Digital Media, Inc and

our Unmanned Aircraft System (DJI Phantom 1/3, 3D Robotics Solo) aerial operations is to

provide a more affordable, high-quality production system for a variety of governmental,

commercial, public, and residential uses, specifically targeting

• Construction sites before and after

• Appraisals

• Real-estate marketing

• Economic development

• Civic landmarks

• Special event coverage

• Private and governmental training 

3
My staff has safely flown small RC electric quadcopters recreationally for approximately 2 

years without incident.

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 1/3, 3D Robotics Solo . UAS

Mirror Mirror Digital Media, Inc seeks an exemption to operate DJI Phantom 1/3, 3D Robotics

Solo system for compensation or hire within the NAS. The DJI Phantom 1/3, 3D Robotics Solo

is vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station

(GCS) utilizing electronic tablet or smart phone systems. The DJI Phantom 1/3, 3D Robotics

Solo has a maximum gross weight of approximately 2.8 lb. while having a diagonal dimension of

23.2”, a maximum speed of approximately 16.4’fps and a maximum flying height of 400'. The

DJI Phantom 1/3, 3D Robotics Solo is equipped with four main rotors; driven by Lithium

Polymer battery powered electric motors. 

The DJI Phantom 1/3, 3D Robotics Solo that will be operated by Mirror Mirror Digital Media,

Inc will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14

C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45,

Identification and Registration Marking.

BASIS FOR PETITION

Petitioner, Mirror Mirror Digital Media, 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 commercially operate the DJI Phantom 1/3, 3D Robotics Solo, UAS in the

National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and

91.417(a) & (b). 

In consideration of the speed, weight, size, and limited operating area associated with the

unmanned aircraft and its operation, Mirror Mirror Digital Media, Inc operation of DJI Phantom

1/3, 3D Robotics Solo UAS meets the conditions of FMRA Section 333 and therefore, will not

require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Accordingly, Mirror Mirror Digital Media, Inc requests relief from Sections 91.405(a), 91.407(a)

(1), 91.409(a)(1) & (a)(2), and 91.417Mirror Mirror Digital Media, Inc(a) & (b), as these

sections set forth requirements for maintenance that only apply to aircraft with an airworthiness

certificate. 

Mirror Mirror Digital Media, Inc submits that the requested relief is proper since an equivalent

level of safety will be ensured. Mirror Mirror Digital Media, Inc will use experienced personnel

or technicians to perform maintenance, alterations, or preventive maintenance on the UAS using

the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly

Maintenance Log, and DJI Phantom 1/3, 3D Robotics Solo Instruction Manual). Furthermore,

Mirror Mirror Digital Media, Inc will document and maintain all maintenance records for the DJI

Phantom 1/3, 3D Robotics Solo UAS. 

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges

and limitations: Pilot in command, is requested by Mirror Mirror Digital Media, 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 flighthour and currency requirements, that the PIC is able to safely operate the DJI Phantom 1/3, 3D

Robotics Solo UAS in a manner consistent with this exemption, including evasive and

4
emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and

structures. 

The Mirror Mirror Digital Media, Inc seeks relief from Section 91.7(a), entitled Civil aircraft

airworthiness, because the DJI Phantom 1/3, 3D Robotics Solo UAS do not require an

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Mirror Mirror

Digital Media, Inc submits that they will ensure that the DJI Phantom 1/3, 3D Robotics Solo

UAS is in an airworthy condition, prior to every flight, by determining that the UAS are in

compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 1/3,

3D Robotics Solo Instruction Manual), and that the aircraft are in a condition for safe flight. 

Mirror Mirror Digital Media, Inc also seeks an exemption from the requirements of Section

91.121, entitled Altimeter Settings, as the DJI Phantom 1/3, 3D Robotics Solo UAS will not have

a typical barometric altimeter onboard. However, altitude information of the DJI Phantom 1/3,

3D Robotics Solo UAS will be provided to the PIC via Global Positioning System (GPS)

equipment and radio communications telemetry data link, which downlinks from the UA to the

GCS for active monitoring of the flight path. This altitude information, combined with Mirror

Mirror Digital Media, Inc's operation of the DJI Phantom 1/3, 3D Robotics Solo UAS within

visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section

91.121. 

Additionally, Mirror Mirror Digital Media, Inc seeks an exemption from the requirements of

Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. Mirror Mirror Digital

Media, Inc submits that safety will not be affected by operation of the DJI Phantom 1/3, 3D

Robotics Solo UAS during daylight hours in visual meteorological conditions (VMC) under

visual flight rules (VFR), with enough battery power to fly for a total duration of approximately

8 minutes. Battery power indicators are also able to show exactly how much battery power is

left, as well as how much time is needed to return safely back to point of take off.

In accordance with 14 C.F.R. § 11.81, Mirror Mirror Digital Media, 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:

Matthew D. Pranzo

President

Mirror Mirror Digital Media, Inc.

5483 Fontaine Street 

San Diego, CA 92120

619-347-2694

pranzomatt@gmail.com

5
B. The Specific Sections Of 14 C.F.R. From Which Mirror Mirror Digital Media, Inc Seeks

Exemption. 

1. Mirror Mirror Digital Media, Inc Seeks Exemption From The Requirements Of Section

61.113(a) And (b). 

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command,

subsections (a) and (b) prescribe the following, in relevant part: 

(a) No person who holds a private pilot certificate may act as a pilot in command

(PIC) of an aircraft that is carrying passengers or property for compensation or hire;

nor may that person, for compensation or hire, act as PIC of an aircraft. 

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in

connection with any business or employment if— 

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

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

2. Mirror Mirror Digital Media, IncMirror Mirror Digital Media, Inc Seeks Exemption

From The Requirements Of Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following: 

(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

3. Mirror Mirror Digital Media, Inc Seeks Exemption From The Requirements Of Section

91.121. 

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: 

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level

of that aircraft, as the case may be, 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. Mirror Mirror Digital Media, 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 under VFR conditions unless

(considering wind and forecast weather conditions) there is enough fuel to fly to the

first point of intended landing and, assuming normal cruising speed, to fly after that

for at least 20 minutes. 

5. Mirror Mirror Digital Media, Inc Seeks Exemption From The Requirement Of Section

91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following: Each

owner or operator of an aircraft— 

6
(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. Mirror Mirror Digital Media, 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, rebuilding, or alteration unless-- 

(1) It has been approved for return to service by a person authorized under § 43.7

of this chapter[.] 

7. Mirror Mirror Digital Media, Inc Seeks Exemption From The Requirements Of Sections

91.409(a)(1) And 91.409(a)(2). 

Section 91.409, entitled Inspections, subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an

aircraft unless, within the preceding 12 calendar months, it has had -- 

(1) An annual inspection in accordance with part 43 of this chapter and has been

approved for return to service by a person authorized by § 43.7 of this chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in accordance

with part 21 of this chapter. 

8. Mirror Mirror Digital Media, 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

registered owner or operator shall keep the following records for the periods specified

in paragraph (b) of this section: 

(1) Records of the maintenance, preventive maintenance, and alteration and

records of the 100-hour, annual, progressive, and other required or approved

inspections, as appropriate, for each aircraft (including the airframe) and each

engine, propeller, rotor, and appliance of an aircraft. The records must include-- 

(i) A description (or reference to data acceptable to the Administrator) of the

work performed; and 

(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person approving the aircraft

for return to service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each propeller, and

each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, propeller,

rotor, and appliance. 

(iii) The time since last overhaul of all items installed on the aircraft which

are required to be overhauled on a specified time basis. 

7
(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 and 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 retain the following records for the periods

prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall be retained until

the work is repeated or superseded by other work or for 1 year after the work is

performed. 

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

transferred with the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under § 43.11 of

this chapter shall be retained until the defects are repaired and the aircraft is

approved for return to service. 

C. The Extent Of Relief Mirror Mirror Digital Media, Inc Seeks And The Reason Mirror

Mirror Digital Media, Inc Seeks The Relief. 

1. Extent Of Relief Mirror Mirror Digital Media, Inc Seeks And The Reason Mirror Mirror

Digital Media, 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 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 and currency requirements, to conduct the proposed UAS flight operations for

compensation or hire. 

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a

private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any

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

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

As set forth more fully below, Mirror Mirror Digital Media, Inc submits that an equivalent level

of safety will be maintained because no PIC will be allowed to operate the DJI Phantom 1/3

UAS unless that PIC has met certain flight-hour and currency requirements, demonstrating that

the PIC is able to safely operate either the DJI Phantom 1/3, 3D Robotics Solo UAS in a manner

consistent with the operations specifications as described in this exemption, including evasive

and emergency maneuvers, as well as maintaining appropriate distances from people, vessels,

vehicles and structures.

Further, Mirror Mirror Digital Media, Inc submits that all flights of the DJI Phantom 1/3, 3D

Robotics Solo UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be

8
incidental to Mirror Mirror Digital Media, Inc business; and (2) will not carry passengers or

property for compensation or hire. 

2. Extent Of Relief Mirror Mirror Digital Media, Inc Seeks And The Reason Mirror Mirror

Digital Media, IncSeeks Relief From Section 91.7(a). 

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent

required to allow Mirror Mirror Digital Media, Inc to determine that the DJI Phantom 1/3, 3D

Robotics Solo UAS are in airworthy condition prior to every flight by ensuring that the UAS is

in compliance with the operating documents (i.e., Mirror Mirror Digital Media, IncMirror Mirror

Digital Media, Inc Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 1/3,

3D Robotics Solo Instruction Manual). 

Mirror Mirror Digital Media, Inc seeks the requested relief because the DJI Phantom 1/3 UAS do

not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Therefore, Mirror Mirror Digital Media, Inc will ensure that the DJI Phantom 1/3, 3D Robotics

SoloUAS are in airworthy condition based upon its compliance with the operating documents

(i.e., Monthly Maintenance Log, and DJI Phantom 1/3) prior to every flight, and further,

determine that the aircraft are in condition for safe flight, as stated in the conditions and

limitations below.

3. Extent Of Relief Mirror Mirror Digital Media, IncMirror Mirror Digital Media, Inc

Seeks And The Reason Mirror Mirror Digital Media, 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 Phantom 1/3, 3D Robotics Solo UAS, which utilize a barometric pressure

sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude

information from the UA to the PIC at the ground control station (GCS). Since the FAA requires

that any altitude information concerning UAS operations be reported to air traffic control (ATC)

in feet above ground level (AGL), Mirror Mirror Digital Media, Inc seeks the requested relief

because the DJI Phantom 1/3, 3D Robotics Solo UA’s altimeter may be set on the ground to zero

feet AGL, rather than the local barometric pressure or field altitude, before each flight. 

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 1/3, 3D Robotics Solo UAS are equipped with a barometric pressure sensor and GPS

equipment, which automatically ensures that a ground level pressure setting will be established

prior to each flight, and provides the PIC with altitude information of the UA on the heads-up

display of the GCS. 

4. Extent Of Relief Mirror Mirror Digital Media, Inc Seeks And The Reason The Mirror

Mirror Digital Media, 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 1/3 UAS

during daylight hours in visual meteorological conditions (VMC), under visual flight rules

(VFR), for a total duration of 23 minutes. Mirror Mirror Digital Media, Inc seeks the requested

relief because without an exemption from Section 91.151(b), the flight time duration of the

battery powered DJI Phantom 1/3, 3D Robotics Solo UAS will severely constrain the practicality

9
of any aerial video or still photo flight operations that Mirror Mirror Digital Media, Inc proposes

to conduct pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the DJI Phantom 1/3 UAS, the

DJI Phantom 1/3 operating documents, and Mirror Mirror Digital Media, Inc’s proposed

operating limitations, ensure that Mirror Mirror Digital Media, Inc will safely operate the battery

powered DJI Phantom 1/3 UAS during daylight hours in visual meteorological conditions

(VMC), under visual flight rules (VFR), with enough battery power to fly for a total duration of

23 minutes.

5. Extent Of Relief Mirror Mirror Digital Media, Inc Seeks And The Reason Mirror Mirror

Digital Media, 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), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to

aircraft with an airworthiness certificate, Mirror Mirror Digital Media, Inc requests relief from

these Sections because the DJI Phantom 1/3 UAS do not require airworthiness certificates. As set

forth more fully below, the DJI Phantom 1/3 UAS meet the conditions of FMRA Section 333 for

operation without an airworthiness certificate. Accordingly, Mirror Mirror Digital Media, Inc

will use trained technicians to perform maintenance, alterations, or preventive maintenance on

the UAS using the methods, techniques, and practices prescribed in the UAS operating

documents (i.e., the Mirror Mirror Digital Media, Inc Aerial Operations Manual, Monthly

Maintenance Log, and DJI Phantom 1/3 Instruction Manual). Furthermore, Mirror Mirror Digital

Media, Inc will document and maintain all maintenance records for the DJI Phantom 1/3 UAS. 

D. The Reasons Why Granting Mirror Mirror Digital Media, 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 Mirror Mirror Digital

Media, Inc to safely, efficiently, and economically perform aerial video and photography of

construction sites, real estate, events and civic landscape over certain areas of the United States. 

Additionally, use of the DJI Phantom 1/3 UAS will decrease congestion of the NAS, reduce

pollution, and provide significant benefits to the economy. Notably, the benefits of Mirror Mirror

Digital Media, Inc’s proposed operation of the DJI Phantom 1/3 UAS will be realized without

implicating any privacy issues. 

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

The DJI Phantom 1/3 UAS are battery powered and serve 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 acquisitions, an exemption allowing the use

of a DJI Phantom 1/3 UAS would reduce the amount of manned aircraft in the NAS, reduce

noise and air pollution, as well as increase the safety of life and property in the air and on the

ground. 

Furthermore, 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 1/3

UAS do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft

conducting aerial video and photography missions would result in fewer aircraft that must be

10
handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of

flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 1/3 UAS. 

Conducting aerial acquisitions with the DJI Phantom 1/3 UAS, 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 still photography flight operations. By using battery power

and electric motors, the DJI Phantom 1/3 UAS produce no air pollution, and is the most viable

environmentally conscious alternative to the cabin class, six cylinder internal combustion engine

aircraft that are typically utilized for aerial video and photography, while burning approximately

20-30 gallons per hour of leaded aviation fuel. The DJI Phantom 1/3 UAS, while reducing the

carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAS are propelled

by battery powered electric motors, rather than an internal combustion engine. 

By using the DJI Phantom 1/3 UAS to perform aerial acquisitions, the substantial risk to life and

property in the air and on the ground, which is usually associated with traditional manned aircraft

flight operations, will be substantially reduced or completely eliminated. Aside from the lack of

flight crew members located onboard the aircraft, the DJI Phantom 1/3 UAS (weighing

approximately 2.8 pounds at their maximum gross weight with diagonal dimension of 23.2

inches, and with no fuel on board), has less physical potential for collateral damage to life and

property on the ground, and in the air, compared to the manned aircraft that typically conduct

similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42

feet, a length of 34 feet, and a fuel capacity of 180 gallons). 

3. Performing Aerial Video and Photography Operations With The DJI Phantom 1/3 UAS 

Will Benefit The Economy. 

In addition to being safe and efficient, the DJI Phantom 1/3 UAS are also an economical

alternative to using manned aircraft to conduct similar aerial operations. As such, operation of

the DJI Phantom 1/3 UAS will allow United States based companies, like Mirror Mirror Digital

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

with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory

actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new

and alternative technology in order to remain competitive. Operating the battery powered DJI

Phantom 1/3 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 Phantom 1/3 UAS, companies such as Mirror Mirror Digital Media, 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

financial performance of U.S. companies, through commercial use of the DJI Phantom 1/3 UAS,

provides a stable workforce that increases consumer spending; improves local, state, and federal

tax revenues; and allows companies to invest in research and development in order to remain

competitive both in the United States and abroad. 

4. There Are No Privacy Issues. 

Similar to the manned aerial acquisition flight operations that have been conducted for decades,

Mirror Mirror Digital Media, Inc’s proposed operation of the DJI Phantom 1/3 UAS will not

implicate any privacy issues. Specifically, the DJI Phantom 1/3 UAS will be operated only in

11
compliance with operating documents (i.e., Mirror Mirror Digital Media, Inc Aerial Operations

Manual, Monthly Maintenance Log, and DJI Phantom 1/3 Instruction Manual) which requires

property 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 Mirror Mirror Digital Media, Inc Seeks Exemption. 

1. Reasons Why The DJI Phantom 1/3 UAS Meet The Conditions Of The FAA

Modernization and Reform Act of 2012 (FMRA) Section 333. 

In consideration of the size, weight, speed, and limited operating area associated with the

unmanned aircraft and its operation, Mirror Mirror Digital Media, Inc’s operation of the DJI

Phantom 1/3 UAS meet the conditions of FMRA Section 333, and will not require an

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Section 333 provides authority for a UAS to operate without airworthiness certification and sets

forth requirements for considering whether a UAS will create a hazard to users of the NAS or the

public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the

following, in part: 

(a) In General.--Notwithstanding any other requirement of this subtitle, and not later

than 180 days after the date of enactment of this Act, the Secretary of Transportation

shall determine if certain unmanned aircraft systems may operate safely in the

national airspace system before completion of the plan and rulemaking required by

section 332 of this Act or the guidance required by section 334 of this Act. 

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under

subsection (a), the Secretary shall determine, at a minimum-- 

(1) which types of unmanned aircraft systems, if any, as a result of their size,

weight, speed, operational capability, proximity to airports and populated

areas, and operation within visual line of sight do not create a hazard to users

of the national airspace 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 paragraph (1). 

(c) Requirements for Safe Operation.--If the Secretary determines under this section

that certain unmanned aircraft systems may operate safely in the national airspace

system, the Secretary shall establish requirements for the safe operation of such

aircraft systems in the national airspace system. 

In seeking this exemption, Mirror Mirror Digital Media, Inc submits that the DJI Phantom 1/3

UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the

characteristics of the DJI Phantom 1/3 UAS; (b) the pilot certification requirement; and (c) the

specific operating limitations. 

a. The Specifications Of The DJI Phantom 1/3 UAS Demonstrate Its Safe Characteristics.

The DJI Phantom 1/3 UAS does not create a hazard to users of the NAS or the public, or

otherwise pose a threat to national security considering its size, weight, speed, and operational

capability. 

12
i. Technical Specifications Of The DJI Phantom 1/3 UAS. 

The technical specifications of the DJI Phantom 1/3 UAS are set forth by the DJI Phantom 1/3

User Manual, attached hereto as Appendix A. 

ii. The DJI Phantom 1/3 UAS Global Positioning Modes Enable The UAS To 

Remain Within A Defined Operational Area. 

The DJI Phantom 1/3 UAS may be operated in both manual and global positioning flight modes.

A complete description of the flight and navigational modes of the DJI Phantom 1/3 UAS is

provided at pages 11 of the DJI Phantom 1/3 User Manual attached hereto as Appendix A. 

iii. The DJI Phantom 1/3 UAS Are Designed For Automatic Return To Home Point 

Or Hover In The Event Of Loss Of The Control Link Or Navigation. 

When the Control Link is lost, the DJI Phantom 1/3 UAS will remain stationary, in flight, for 3

seconds or more. If, after 3 seconds, the DJI Phantom 1/3 UAS does not reacquire control link

data from the GCS, the UAS will assume that the Control Link is lost and the 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 1/3 UAS are set forth at

pages 12 through 14 of the DJI Phantom 1/3 User Manual, attached hereto as Appendix A. 

iv. The DJI Phantom 1/3 GCS And Its Operation.

A complete description of the operation and specifications of the DJI Phantom 1/3 GCS and

flight control software is provided at pages 23 through 29 of the DJI Phantom 1/3 User Manual.

DJI Phantom 1/3 User Manual is attached hereto as Appendix A. 

b. Flight Operations Of DJI Phantom 1/3 UAS Is Limited To The Line Of Sight Of A 

Certificated Pilot in Command With A Safety Observer. 

Mirror Mirror Digital Media, Inc video production staff will be the only persons to act as a pilot

in command (PIC) of the DJI Phantom 1/3 UAS. Additionally, a safety observer will assist him at

all times during flight time. 

c. Flights Of DJI Phantom 1/3 UAS Will Be Conducted Pursuant To Specific Operating 

Limitations. 

In seeking this exemption, Mirror Mirror Digital Media, Inc proposes to commercially operate 

DJI Phantom 1/3 UAS for the special purpose of conducting aerial video and photography over 

certain areas of United States, pursuant to the following specific operating limitations.

1. Operations authorized by this grant of exemption will be limited to the following

aircraft described in the operating documents, rotorcraft UAS weighing less than 55

pounds maximum gross weight: DJI Phantom 1/3 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 limited to conducting operations for

the purpose of aerial video and photography. 

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

4. The UA must be operated at an altitude of no more than 400 feet above ground level

(AGL), as indicated by the procedures specified in the operating documents unless a

special request is made and approved by ATC. All altitudes reported to ATC must be in

feet AGL. 

5. The UAS must be operated within visual line of sight (VLOS) of the PIC at all

times. This requires the PIC to be able to use human vision unaided by any device

13
other than corrective lenses, as specified on the PIC’s FAA-issued airman medical

certificate. 

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not

permitted. 

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy

the VLOS requirement as long as the PIC always maintains VLOS capability. The SO

and PIC must be able to communicate verbally at all times. Electronic messaging or

texting is not permitted during flight operations. The PIC must be designated before

the flight and cannot transfer his or her designation for the duration of the flight. The

PIC must ensure that the SO can perform the functions prescribed in the operating

documents. 

8. The SO must not perform any other duties beyond assisting 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 instruments. 

9. The operating documents and the grant of exemption must be accessible during

UAS operations and made available to the Administrator upon request. If a

discrepancy exists between the conditions and limitations contained in the grant of

exemption and the procedures outlined in the operating documents, the conditions and

limitations contained in the grant of exemption take precedence and must be followed.

Otherwise, the operator must follow the procedures as outlined in its operating

documents. The operator may update or revise its operating documents. It is the

operator’s responsibility to track such revisions and present updated and revised

documents to the Administrator upon request. The operator must also present updated

and revised documents if it petitions for extension or amendment to the grant of

exemption. If the operator determines that any update or revision would affect the

basis upon which the FAA granted the exemption, then the operator must petition for

amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS-80)

may be contacted if questions arise regarding updates or revisions to the operating

documents. 

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition

for safe flight. If the inspection reveals a condition that affects the safe operation of

the UAS, the aircraft is prohibited from operating until the necessary maintenance has

been performed and the UAS is found to be in a condition for safe flight. The Ground

Control Station must be included in the preflight inspection. All maintenance and

alterations must be properly documented in the 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,

14
alterations, and status of replacement/overhaul component parts must be noted in the

aircraft records, including total time in service, description of work accomplished,

and the signature of the authorized person returning the UAS to service. 

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

Safety Bulletins. 

16. The authorized person must make an entry in the aircraft record of the corrective

action taken against discrepancies discovered between inspections. 

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

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 will be operated under the exemption,

including evasive and emergency maneuvers and maintaining appropriate distances

from persons, vessels, vehicles and structures. PIC qualification flight hours must be

logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of

training the operator’s PICs are permitted under the terms of the exemption. However,

training operations may only be conducted during dedicated training sessions. During

training, proficiency, and experience-building flights, all persons not essential for

flight operations are considered nonparticipants, and the PIC must operate the UA

with appropriate distance from nonparticipants in accordance with 14 C.F.R. §

91.119. 

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1.

All operations must be conducted under visual meteorological conditions (VMC). If

flight at night is required, a special request will be made at the FAA office closest to

proposed area of operations. Flights under special visual flight rules (SVFR) are not

authorized. 

20. The UA may not operate within 5 nautical miles of an airport reference point as

denoted on a current FAA-published aeronautical chart unless a letter of agreement

with that airport’s management is obtained, and the operation is conducted in

accordance with a NOTAM as required by the operator’s COA. The letter of

agreement with the airport management must be made available to the Administrator

upon request. 

21. The UA may not be operated less than 500 feet below or less than 2,000 feet

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 

22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in

accordance with the operating documents. 

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

in accordance with the operating documents. 

24. The PIC is prohibited from beginning a flight unless (considering wind and

forecast weather conditions) there is enough power to fly at normal cruising speed to

the intended landing point and land the UA with 25% battery power remaining. 

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

Waiver or Authorization (COA) prior to conducting 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 48 hours prior to the

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operation. All operations shall be conducted in accordance with airspace requirements

in the ATO issued COA including class of airspace, altitude level and potential

transponder requirements. 

26. All aircraft operated in accordance with the exemption must be identified by serial

number, registered in accordance with 14 C.F.R. part 47, and have identification (NNumber) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must

be as large as practicable. 

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

and control of the UA must comply with the Federal Communications Commission

(FCC) or other appropriate government oversight agency requirements. 

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available

to the PIC at the Ground Control Station of the UAS any time the UAS is operating.

These documents must be made available to the Administrator or any 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 500 feet from all nonparticipating

persons (persons other than the PIC, SO, operator trainees or essential persons),

vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating

persons from the UA and/or debris in the event of an accident. The operator

must ensure that nonparticipating persons remain under such protection. If a

situation arises where nonparticipating persons leave such protection and are

within 500 feet of the UA, flight operations must cease immediately and/or; 

b. The aircraft is operated near vessels, vehicles or structures where the

owner/controller of such vessels, vehicles or structures has granted permission

and the 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 present an undue hazard to those persons per § 91.119(a). 

32. All operations shall be conducted over private or controlled-access property with

permission from the land owner/controller or authorized representative. Permission

from land owner/controller or authorized representative will be obtained for each

flight to be conducted.

 33. Any incident, accident, or flight operation that transgresses the lateral or vertical

boundaries of the operational area as defined by the applicable COA must be reported

to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be

reported to the National Transportation Safety Board (NTSB) per instructions

contained on the NTSB Web site: www.ntsb.gov. 

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b)

Would Not Adversely Affect Safety.

Mirror Mirror Digital Media, Inc submits that the equivalent level of safety established by

Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI

Phantom 1/3 UAS unless that PIC has demonstrated, by meeting minimum flight-hour and

16
currency requirements, that the PIC is able to safely operate the DJI Phantom 1/3 UAS in a

manner consistent with the exemption, including evasive and emergency maneuvers and

maintaining appropriate distances from people, vessels, vehicles and structures. 

Considering Mirror Mirror Digital Media, Inc’s proposed area of operations, and the operating

limitations set forth-above; the parallel nature of private pilot aeronautical knowledge

requirements to those of commercial pilot requirements (See Exemption No. 11062); and the

airmanship skills necessary to safely operate the DJI Phantom 1/3 UAS, Mirror Mirror Digital

Media, Inc submits that the additional manned airmanship experience of a commercially

certificated pilot would not correlate to the airmanship skills necessary for Mirror Mirror Digital

Media, 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. Exemption Nos.

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150,

11153, 11156, 11158, 11159, 11160, 11161). 

Mirror Mirror Digital Media, Inc will not allow any PIC to operate the DJI Phantom 1/3 UAS

unless that PIC has demonstrated, by meeting minimum flight-hour requirements or the DJI

Phantom 1/3 UAS training and currency requirements, that the PIC is able to safely operate the

DJI Phantom 1/3 UAS in a manner consistent with this exemption, including evasive and

emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and

structures. 

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. §

61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those

hours as a UAS pilot operating the same make and 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 safety

during Mirror Mirror Digital Media, 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 pilot including at least 10 hours logged as a UAS pilot with a multi-rotor

UAS. Prior to operations under Exemption No. 11062, the PIC must also have

accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make

and model of UAS to be used for operations under the exemption. For clarification, the

FAA considers these minimum hour requirements to be inclusive rather than additive; i.e.

5 hours make and model time may be included in the 10 hours of multi-rotor time and the

10 hours may be included in the total 25 hours of UAS rotorcraft time. 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 Exemption No. 11062 are appropriate to practice and build proficiency in

the skills necessary to safely conduct the petitioner’s proposed operations. The FAA also

finds that prior documented flight experience that was obtained in compliance with

applicable regulations would satisfy this requirement. Training, proficiency, and

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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 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, Mirror Mirror Digital Media, Inc will ensure safe operations by not allowing any

PIC to operate the DJI Phantom 1/3 UAS unless that PIC has demonstrated, by meeting

minimum flight-hour and currency requirements, that the PIC is able to safely operate the DJI

Phantom 1/3 UAS in a manner consistent with the exemption, including evasive and emergency

maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not

Adversely Affect Safety. 

The equivalent level of safety established by Section 91.7(a) will be maintained because prior to

every flight, Mirror Mirror Digital Media, Inc will ensure that the DJI Phantom 1/3 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 respects, to those presented herein (e.g. Exemption Nos.

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150,

11153, 11156, 11157, 11158, 11159, 11160, 11161). 

4. Reasons Why 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 1/3 UAS will be provided to the PIC via GPS equipment

and a radio communications telemetry data link, which downlinks from the UA to the GCS for

active monitoring of the flight path and altitude. This altitude information, combined with Mirror

Mirror Digital Media, Inc’s operation of the DJI Phantom 1/3 UAS within visual line of sight, at

or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude

information will be generated by GPS equipment installed onboard the aircraft. Prior to each

flight, a zero altitude initiation point is automatically established by the UAS at ground level. 

The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063,

11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157,

11158, 11159, 11160, 11161). 

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not

Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R.

Section 91.151(b) as a result of (1) the technical specifications of the DJI Phantom 1/3 UAS; (2)

the limitations on the proposed flight operations; and (3) the location of the proposed flight

operations. Accordingly, Mirror Mirror Digital Media, Inc will ensure that it will safely operate

the battery powered DJI Phantom 1/3 UAS during daylight hours in VFR conditions, with

enough battery power to fly for a total duration of 23 minutes. 

18
Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 1/3 UAS; 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 1/3 UAS provide audible and visual warnings to the

PIC at the GCS when the UAS experiences low battery voltage, the first warning occurring at

approximately 33% remaining battery power, and again at approximately 10% remaining battery

power. At the critically low battery level, the DJI Phantom 1/3 UAS 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

UAS are considered. Relief has been granted for manned aircraft to operate at less than the

minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650.

Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos.

8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110,

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

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, Mirror Mirror Digital Media, Inc submits that the equivalent level of

safety with regard to the regulatory maintenance and alteration requirements established by

Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because

Mirror Mirror Digital Media, Inc will use trained technicians to perform maintenance,

alterations, or preventive maintenance on the UAS using the methods, techniques, and practices

prescribed in the operating documents (i.e., Mirror Mirror Digital Media, Inc Aerial Operations

Manual, Monthly Maintenance Log, and DJI Phantom 1/3 Instruction Manual). Furthermore,

Mirror Mirror Digital Media, Inc will document and maintain all maintenance records for the DJI

Phantom 1/3 UAS. 

Since the DJI Phantom 1/3 UAS will be inspected as prescribed by the operating documents,

Mirror Mirror Digital Media, Inc will maintain the equivalent level of safety established by

Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI Phantom 1/3 User Manuals

are attached hereto as Appendix A and B; a copy of the DJI Phantom 1/3 UAS Maintenance LOG

is attached hereto as Appendix C. 

Likewise, the exemption sought will not adversely affect safety because Mirror Mirror Digital

Media, 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 sought 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 1/3 UAS

will be performed by trained technicians. Maintenance will be documented and maintained

utilizing the monthly 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 operating limitations of the UAS are considered. 

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In consideration of Mirror Mirror Digital Media, Inc’s proposed operating limitations, the

operating documents, and the technical aspects of the DJI Phantom 1/3 UAS, Mirror Mirror

Digital Media, Inc submits that safety will not be adversely affected by granting exemption from

14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The

FAA has previously granted relief specific to UAS in circumstances similar, in all material

respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066,

11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159,

11160, 11161). 

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

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and

14 C.F.R. § 21.16 entitled Special Conditions, Mirror Mirror Digital Media, Inc requests that the

FAA prescribe special conditions for the intended operation of the DJI Phantom 1/3 UAS, which

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

equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b),

91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

Such special conditions will permit safe operation of the UAS for the limited purpose of

conducting aerial video and photography over certain areas of the United States for

compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a

UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national

security; and further, provides the authority for such UAS to operate without airworthiness

certification in accordance with any requirements that must be established for the safe operation

of the UAS in the NAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R.

§ 21.16, for operation of the DJI Phantom 1/3 UAS, since the airworthiness regulations of 14

C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or

unusual design features of the aircraft. Section 21.16, entitled Special Conditions, states the

following: 

If the FAA finds that the airworthiness regulations of this subchapter do not contain

adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller

because of a novel or unusual design feature of the aircraft, aircraft engine or 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 Leading Edge’s intended operation of the DJI Phantom 1/3 UAS, which

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

equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a)

& (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a)

& (b).

• A Summary That Can Be Published In The Federal Register, stating: The

Rules From Which Mirror Mirror Digital Media, Inc Seeks Exemption: 

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Mirror Mirror Digital Media, 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 Mirror Mirror Digital Media, Inc

Seeks: 

This exemption will permit Mirror Mirror Digital Media, 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.

• Any Additional Information, Views, Or Arguments Available To Support

Mirror Mirror Digital Media, Inc’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, Mirror Mirror Digital Media, 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 public, or otherwise pose a threat to national security; and

further, provides the authority for such UAS to operate without airworthiness certification. 

As discussed in detail above, Mirror Mirror Digital Media, Inc will operate the DJI Phantom 1/3

UAS safely in the NAS, without creating a hazard to users of the NAS, or the public, or

otherwise pose a threat to national security. 

CONCLUSION

As set forth herein, Mirror Mirror Digital Media, 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 1/3 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 interests of the public, by allowing Mirror Mirror Digital Media, Inc to safely,

efficiently, and economically operate the DJI Phantom 1/3 UAS commercially within the NAS. 

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

Modernization and Reform Act of 2012, Section 333, Mirror Mirror Digital Media, Inc

respectfully requests that the Administrator grant this Petition for an exemption from the

requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Leading Edge to operate the

DJI Phantom 1/3 UAS commercially for the purpose of conducting aerial video and photography

over certain areas of the United States.

Dated: June 10, 2015

Respectfully submitted,

Matthew D. Pranzo

President

Mirror Mirror Digital Media, Inc.

5483 Fontaine Street 

21
San Diego, CA 92120

619-347-2694

pranzomatt@gmail.com

http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.2_en.pdf

http://download.djiinnovations.com/downloads/phantom/en/PHANTOM_Advanced_Manual_en.pdf

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