UNITED STATES OF AMERI CA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

WASHI NGTON, DC

Regulator Docket No. ______________

**IN THE MATTER OF THE PETITION FOR EXEMPTION OF:**

**GLOBAL AERIAL VIDEO ,**  **Inc FOR**  **AN EXEMPTION SEEING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS**  **61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND**  **91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF UN MANNED**  **AIRCRAFT PURSUANT TO SECTION 333 OF**  **THE FAA MODERNIZAION AND REFORM ACT OF 2012**

**(PUBLIC LAW 112 -**  **95)**

Submitted on November 10 , 2015 Global Aerial Video (GAV) 29W169 Spring Lake Drive Naperville, IL 60564 Phone: (630)370

- 17502 **GLOSSARY	OF	ABBREVIATIONS ................................**  **................................ ...........................**  **3 SUMMARY**  **................................ ................................**  **................................ ................................**  **.... 4**  **INTRODUCTION	AND INTEREST	OF	THE	PETITIONER**  **................................ ................**  **4 BACKGROUND**  **................................ ................................**  **................................ ............................**  **6 BASIS	FOR	PETITION**  **................................ ................................**  **................................ ...............**  **6 CONCLUSION**  **................................ ................................**  **................................ ............................**  **28**3 **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 GAV GCS Global Aerial Video Ground Control Station GPS Global Positioning System LOL Loss of Link NAS National Airspace Sy stem NOTAM Notice to Airman PI C Pilot In Command RPA Remotely Piloted Aircraft Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333 SO Safety Observer SOP Standard Operating Procedures UA Unmanned Aircraft UAS Unmanned Aircraft Sy stem VFR Visual Flight Rules VLOS Visual L ine of Site VMC Visual Meteorological Conditions VTOL Vertical Takeoff and Landing4 **SUMMARY** Global Aerial Video (GAV) 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 (UAS) pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit GAV to operate a Remotely Piloted Aircraft (RPA) or UAS for the commercial purpose of conducting aerial video and photography of construction sites, real estate property and the survey of buildings and structures for inspection purposes. AND/ OR...safel y, efficiently , and economically perform aerial video and photography of construction sites, real estate, survey , and inspect over certain areas of the United States. To assist other businesses in helping them grow from my services

.
**INTRODUCTION AND INTEREST OF THE PETITIONER** GAV is owned and operated by Joseph Fenn H ill

. Mr . Hill has successfull y operated UA and UAS equipment for over 2 ,8 00 flight hours over a period of three consecutive years without incident or interference both in rural and community

environments or settings. This flight experience extends to all ty pes of topograph y and regional conditions. This proper and professional operational experience has resulted in a zero incident rate . At all times the operation of the UAS and UA have been conducted within L OS (Line of Sight) and Day time standards at an altitude that has not exceeded 300 feet and alway s performed at a minimum distance of 5 miles from active FAA airfields and facilities . In addition, Mr. Hill has successfully completed the FAA Ground School programs at Ohio State University while also having pilote d several types of Cessna Aircraft as part of the FAA Pilot Pre

- License Instruction5 program s . As a result of this program training Mr. Hill has an exceptional knowledge of Flight Regulations and Rules associated with all aircraft operation as outlined in F AA practice standards. Mr. Hill also retains extensive knowledge of ground based technology required to operate UA and UAS equipment as it applies to GPS and ATIoperational techniques that allows for the SAFE operation of RC sy stems and equipment as wil l be used by GAV. This knowledge also extends to the SAFE pre

- flight inspection of navigational technology

and equipment while alway s maintaining all equipment as required or suggested b y the manufacturer of GAV equipment. Mr
. Hill has over 28 ye ars of b ackground with aircraft operation and safe flight service in the US. He has over 10 years’ experience of successful RC Hobbyist operation of UAS in a nonprofessional environment. If granted exemption, GAV will focus on commercial and public service applic ations to include , but not limited to; real estate advertising, mapping, building survey s and inspection s , motion picture filming, marketing, and the training and support for law enforcement, fire/rescue and other public service organizations. Primary operations will be for commercial, for profit, events. However, as a civic

- minded company
– GAV will alway s look to give back to and support the community by providing no cost services to appropriate events and organizations a s well as d civil entities

.6 **BACKGROUND**
GAV seeks exemption to operate a DJ I Inspire Pro 1 platform manufactured by DJIIndustries for commercial purposes in the United States National Airspace S ys tem
. The DJ I Inspire Pro 1 is a multirotor platform with Vertical Takeoff and Landing (VTOL) capabilities controlled by operators maintaining Visual Line of Sight (VLOS) using a full telemetry , GPS equipped, handheld ground station

. The DJ I Inspire Pro 1 is 11 inches tall, and 16.5 inches long and 16.5 inches wide. It was a max takeoff we ight with battery

and camera in stalled on 29 00 gram and a maximum speed of approximately 2 8 knots.

**BASIS FOR PETITION** Petitioner, GAV , pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereb y petitions the Administrator to commercial ly o perate the DJ I Inspire Pro 1 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 li mited operating area associated with the unmanned aircraft and its operation, GAV’s operation of DJ I Inspire Pro 1 meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, S ubpart H.7 Accordingl y, GAV requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that onl y apply to aircraft with an airworthiness certificate. GAV submits that the requested relief is proper, as an equivalent level of safety will be ensured. GAV will ensure all safety and maintenance procedures outline by the UAS manufacture are complied with. Only authorized personnel or technicians will perform mai ntenance on the UASs using the methods, techniques, and practices prescribed in the operating docum ents provided b y the UAS manufacture. All maintenance will be logged in the UAS maintenance record maintained b y GAV

. Relief from certain requirements of S ection 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested b y GAV to the extent necessary to allow a Pilot in Command (PI C) holding a private pilot or higher level certificate, m eeting minimum flight

- hour and currency requirements, that the PI C is able to safel y operate the Ty

phoon Q500 UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vess els, vehicles and structures. GAV seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness , because the DJ I Inspire Pro 1 UAS do es not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, GAV submi ts that all maintenance and care will be conducted to will ensure the DJ I Inspire Pro 1 is in an airworth y condition, prior to every flight, b y determining that the UASs are in compliance with the operating documents provided by the UAS manufacture , and that the aircraft are in a condition for safe flight.8 GAV seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , as the DJIInspire Pro 1 UA will not have a typical aircraft barometric altimeter onboard. Altitude is measured using barometric and Global Positioning Sy stem (GPS) sensors. The UA provides the information to the LOS operator via a GCS application for real time flight telematics

. The flight telematics aid the operator ensuring compliance and safe operation of the UA within visual line of sight, at or below 2 00 feet AGL , with the majority

of flights at or below 1 00 feel AGL , will ensure a level of safety equivalent to Section 91.121. Additionally , GAV seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions

. GAV submits that granting an exe mption is necessary due to the inherent limitations of electric UAS vehicles. Most if, not all small UAS’s are limited to a max imum of 20

- 25 minutes in total flight time

. O peration of the DJ I Inspire UA S will be conducted in daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR) will ensure the UA is operated in a safe manner compliant with applicable regulations

. In addition, a key built in safety

feature within the DJI’ s software automatically reduces it’s maximum altitude based on decreasing battery levels, ultimately

self

- landing the vehicle prior to total battery

depletion.
In accordance with 14 C.F.R. § 11.81, IVS provides th e following information in support of its petition for exemption: **1) Name And Address Of The Petitioner.**  The name and address of the Petitioner and point of contact is:9 Global Aerial Video (GAV) 29W169 Spring Lake Drive Naperville, IL 60564 Phone: (630)370

- 1750 2) **The Specific Sections Of 14 C.F.R. From Which** GAV **Seeks Exemption.** a) GAV **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: i) No person who holds a private pilot certificate may act as a pilot in command (PI C) of an aircraft that is carrying passengers or property for compensation or hire; nor may

that person, fo r compensation or hire, act as PIC of an aircraft. ii) A private pilot may , for compensation or hire, act as PI C of an aircraft in connection with any business or emplo ym ent if

— (1) The flight is onl y incidental to that business or employment; and (2) The aircraft does not carry passengers or property

for compensation or hire. b) GAV **Seeks Exemption From The Requirements Of Section 91.7(a).** Section 91.7, entitled Civil aircraft airworthiness , subsection (a), states the following: i) No person may

operate a civil aircra ft unless it is in an airworthy condition. c) GAV **Seeks Exemption From The Requirements Of Section 91.121.** Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part:10 i) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, b y reference to an altimeter that is set, when operating

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

-- (a) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; (b) 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 (c) 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. d) GAV **Seeks Exemption From The Requirements Of Section 91.151(b).** Section 91.405, entitled Maintenance required, subsection (a), states the following: Each owner or operator of an aircraft

— (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, exc ept as provided in paragraph of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.] e) GAV **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:11 i) No person may

op erate any

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

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

§ 43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance wi th part 21 of this chapter. g) GAV **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: i) Except for work performed in accordance with §§ 91.41 1 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section:12 (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

— (2) A description (or reference to data acceptable to the Administrator) of the work performed; and (3) The date of completion of the work performed; and (4) The signature, and certificate number of the person approving the aircraft for return to service. ii) Records containing the following information: (1) The total time in service of the airframe, each engine, each propeller, and each rotor. (2) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance. (3) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (4) 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. (5) The current s tatus of applicable A irworthiness D irectives (AD) and safety directives including, for each, the method of compliance, the AD or safety13 directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required. (6) Copies of the forms prescribed b y § 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances. iii) The owner or operator shall retain the following records f or the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded b y other work or for 1 ye ar after the work is performed. (2) The records specified in paragraph (a)(2) of this sec tion 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 app roved for return to service. 3) **The Extent Of Relief** GAV **Seeks And The Reason** GAV **Seeks The Relief.** a) **Extent Of Relief GAV**  **Seeks And The Reason GAV**  **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 GAV personnel to determine that the DJ I Inspire UAS is in airworthy condition prior to every

flight by ensuring that the UAS is in compliance with the operating documents (i.e., the DJ I Standard14 Operating Proc edures (SOP) , Monthly Maintenance Log , and DJ I Inspire documentation). GAV seeks the requested relief because the DJ I In spire UAS do es not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, GAV personnel will ensure that the DJIInspire UAS is in airworthy condition based upon its compliance with the operating documents (i.e., Maintenance Lo g s , DJ I SOP and manufacture documentation) prior to every flight, and further, determine that the aircraft are in conditio n for safe flight, as stated in the conditions and limitations below.
b) **Extent Of Relief GAV**  **Seeks And The Reason GAV**  **Seeks Relief From Section 91.121.**  Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the DJ I Inspire Pro 1 utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude informatio n from the UA to the PI C at the 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), GAV seeks the requested relief as the DJI Inspire UA 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

wi th the applicable15 conditions and limitations stated below. As more fully set forth herein, an equivalent level of safety will be maintained since the DJ I Inspire Pro 1UA is equipped with a barometric pressure sensor and GPS equipment, which automatically

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

- up display

of th e GCS. c) **E xtent Of Relief**  **GAV Seeks And The Reason**  **GAV 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 UA during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR). GAV seeks the requested relief as the UAS does not utilize traditional aircraft combustible fuel, rather the UAS is battery powered

. Significantl y, as set forth below, the technical specifications of the DJ I Inspire Pro 1o perating documents, and GAV proposed operating limitations, ensure that GAV will safely operate the battery

powered DJ I Inspire during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR). d) **Extent Of Relief GAV**  **Seeks And The Reason GAV**  **Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b).**  Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b ) only appl y to aircraft with an airworthiness certificate, GAV requests relief from these Sections because the DJ I Inspire UA do es not require airworthiness16 certificates. As set forth more fully below, the DJI Inspire UA meet s the conditions of FMRA Sect ion 333 for operation without an airworthiness certificate. Accordingl y, GAV will only use authorized technicians to perform maintenance on the UAS using authorized methods. GAV will document all maintenance activities and keep the maintenance activity records for the GAV UAS. e) **The Reasons Why Granting GAV**  ’ **s Request Would Be In The Public Interest; That Is, How It Would Benefit The Public As A Whole.**  Granting GAV ’s Petition will further the public interest by allowing GAV to conduct training for GAV per sonnel as well as other parties interested in proper and safe recreational or commercially operating of UAS, employ ment of small UAS is efficient and more economical for certain type of activities such as construction site photography , land surveying, aeri al video and photography of real estate, special events, film sets, and landscape over certain areas of the United States. And/Or ...safel y, efficientl y, and economically perform aerial video and photograph y of construction sites, real estate, survey, and ins pect over certain areas of the United States. To assist other businesses in helping them grow from my services or rather, to fulfill their needs, whatever it may be." Additionall y, use of the small battery powered UAS will decrease congestion of the NAS fo r certain activities , reduce po llution, and provide benefits to the econom y.17 f) **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 Wh ich**  GAV **Seeks Exemption.** i) **Reasons Why DJI Inspire**  **Meet s**  **The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333.**  In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, GAV ’ s operation of the GAV UAS meet s 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 other wise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part: (1) 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. ii) Assessment of Unmanned Aircraft Systems.

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

--18 (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 a uthorization, 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). iii) Requirements for Safe Operation.

--If the Secretary determines unde r 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 , GAV submits the DJ I Inspire UA can be operate d safel y in the NAS pursuant to FMRA Section 333, as demonstrated b y: (A ) the characteristics of the DJ I Inspire UA ; ( B ) the pilot certification requirement; and ( C ) the specific operating limitations.

A. **The Sp ecifications Of**  **DJI Inspire** UA **Demonstrate Its Safe Characteristics.**  DJI Inspire 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

. GAV UAS utilizes four counter

- rotating propellers for extreme19 balance, control and stability that is aided by

GPS and other on board sensors. In the event of an unexpected loss of communication with the UAS it will return to a pre

- defined location at a pre

- determined altitude AGL. If the UAS has returned to the pre

- defined location and altitude with a low battery the UAS will safely

land at the pre - determined location. In addition the Inspire has factory

installed firmware that prevent it from being activated or flown in close proximity to any ai rport in the US. *Note: DJ I Inspire customer support has an available firmware download that is on ly

released to customers that meet their screening process that does allow operation in proximity to airports.

B. FORMATION HERE **.** The technical specifications of the DJ I Inspire Pro 1 is set forth by the Ty phoon Q500 manufacturer is as follows:

 **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 Service Ceiling Above Sea Level**  **4500 m (Software altitude limit: 120 m above takeoff point)**   **Max Wind Speed Resistance 10 m/s**   **Max Flight Time Approximately 18 minutes**   **Motor Model DJI 3510H** 20  **Propeller Model DJI 1345T**   **Indoor Hovering Enabled by default**   **Operating Temperature Range -**  **10° to 40° C**  **Diagonal Distance 559 to 581 mm**   **Dimensions 438x451x301 mm**   **Power Spectral Density 9.06mW/MHz**  C. **Flights Of the**  **DJI Inspire Will Be Conducted Pursuant To**  **Specific Operating Limitations.**
a. GAV’ s weigh less than 55 pounds; b. GAV only

operates its UASs below 400 feet;
c. GAV UASs only

operate for 5

- 2 0 minutes per flight; d. GAV remote control pilots operate GAV UASs by visual line of sight (VLOS) at all times.
e. GAVremote control pilots have downlink video backup via gro und station, should they lose sight of the UAS; f. GAV UASs have GPS flight modes whereb y the y hover and then slowly

land if communication with the remote control pilot is lost or battery power is low; g. GAV activel y anal ys es electronic flight data and oth er sources of information to constantly update and enhance safety protocols; h. GAV alway s obtains all necessary permissions and permits prior to operation; and, GAV has procedures in place to abort flights in the event of safety breaches or potential danger

.21 i. The pre

- flight inspection by GAV personnel must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents. j. If the UA loses communications for a pre

- defined period of time or loses its GPS signal, it must return to a pre

determined location within the planned operating area and land or be recovered in accordance with the operating documents. k. Any incident, accident, or flight operation that transgre sses the lateral or vertical boundaries of the operational area as defined b y 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) pe r instructions contained on the NTSB Web site: www.ntsb.gov. g) **Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely Affect Safety.**  GAV 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 UAS unless that PI C has demonstrated, b y meeting minimum flight

- hour and currency requirements, that the P IC is able to safely

operate the UAS in a manner consistent with the exemption,22 including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering GAV ’s proposed area of operations, and the operating limitations set forth

- above; combined with the Owner/operator’s extensive training and experience, including holding both a private and commercial fixed and rotor wing certifications ensures that all GAV ’s operations will be conducted in a safe manner. 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). GAV will not all ow any PI C to operate the UAS unless that PI C has demonstrated, b y meeting minimum flight

- hour requirements or UAS training and currency requirements, that the PI C is able to safely operate the UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Specificall y, the PI C 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 day s (for currency

purposes). As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with appl icable regulations will ensure an23 equivalent level of safety during GAV ’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 PI C must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating th e 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 day s (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 safel y conduct the petitioner’s proposed operations. The FAA also finds that prior documented flight experience that was ob tained in compliance with applicable regulations would satisfy this requirement. Training, proficiency , and experience

- building flights can also be conducted under the grant of exemption to accomplish the required flight time.24 During training, proficiency , and experience

- building flights the PI C is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15. Accordingl y, GAV will ensure safe operations by not allowing any P IC to operate the UAS unless that PI C has demonstrated, by meeting minimum flight

- hour and currency

requirements, that the PI C is able to safel y operate the UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate dis tances from people, vessels, vehicles and structures. h) **Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety.**  The equivalent level of safety established b y Section 91.7(a) will be maintained utilizing pre flight SOP , GAV wi ll ensure that the UAS is in an airworth y 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)

. i) **Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety.**  The equivalent level of safety established b y Section 91.121 will be maintained because the altitude information of the UA will be provided to the PI C25 v ia 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 GAV ’ s operation of the UA within visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information will be generated b y GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically establi shed b y 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). j) **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 saf ety established by

14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the UAS; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingl y, GAV will ensure that it will safel y operate the battery powered UA during daylight hours in VFR conditions. Here, as in Exemption No. 11109, the technical specifications of theUAS; the limitations on the proposed flight operations; and the location of the pro posed operations, will ensure an equivalent level of safety established b y 14 C.F.R.26 Section 91.151(b). Furthermore, safety will be ensured as the UAS provide audible and visual warnings to the PIC at the GCS when the UAs experiences low battery voltage. At the critically

low battery

level, the UAS will descend and land automatically

. Significantl y, previous exemptions granted b y 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 previousl y granted relief from Se ction 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, 11 157, 11158, 11159, 11160, 11161). k) **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, GAV 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 as GAV will use only authorized technicians to perform maintenanc e on the UASs using the authorized methods, techniques, and practices

.27 Furthermore, GAV will document and maintain all maintenance records for the DJIUAS

. The UAS will be inspected as prescribed b y the operating documents, GAV will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). Likewise, the exemption sought will not adversel y affect safety as GAV will only use authorized technicians to preform maintenance on the UAS using the authorized methods , techniques, and practices Furthermore, the exemption sought would maintain an equivalent level of safety established b y Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the UAS will be performed b y authorized technicians. Maintenance will be documented and maintained utilizing the maintenance log. Significantl y, previous exemptions granted b y the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversel y affected when the technical characteristics and operating limitations of the UAS are considered. In consideration of GAV ’s proposed operating limitations, the operating documents, and the technical aspects of the DJ I In spire , GAV submits that safety will not be a dversel y affected b y 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 previousl y granted relief specific to UAS in circumstances similar, in all material respects, to those pres ented herein (e.g. Exemption Nos. 11062, 11063,28 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

**C ONCLUSION**  As set forth herein, GAV 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 DJ I Inspire UA commerciall y, without an airworthin ess certificate, for the purpose of conducti ng 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 th e public, by allowing GAV to safel y, efficiently , and
e conomicall y operate the UAS commerciall y within the NAS. **WHEREFORE** , in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, GAV respectfull y 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 GAV to operate the UAS commerciall y for the purpose of conducting aerial video and photography over certain areas of the United States. GAV respectfull y requests that FAA exercise its authority to issue the exemption sought by GAV pursuant to the Federal Aviation Act, 85 P. L. 726 (1958), as amended (the "Act") without delay

.29 Sincerel y,

Joseph F. Hill Global Aerial Video (GAV) 29W169 Spring Lake Drive Naperville, IL 60564 Phone: (630)370

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