UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: Cellcom Inc. FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1),91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF DJI PHANTOM 2 VISION+ AND DJI INSPIRE 1 UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Submitted on November 20, 2015 Cellcom Inc. 42650 Long Lake Rd. Ottertail, MN 56571 Tel: (218) 849-8087 almw@eot.com2 TABLE OF CONTENTS Page GLOSSARY OF ABBREVIATIONS...................................................................................3

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

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

BACKGROUND....................................................................................................................5

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

NAME AND ADDRESS OF PETITIONER.............................................................7 THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH Cellcom Inc. SEEKS EXEMPTION.................................................................8 THE EXTENT OF RELIEF Cellcom Inc. SEEKS AND THE REASON Cellcom Inc. SEEKS THE RELIEF.........................11 THE REASONS WHY GRANTING Cellcom Inc.’S REQUEST WOULD BE IN THE PUBLIC INTEREST .........................................................15THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY..........................................................................19 SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER......34ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT Cellcom Inc.’S REQUEST.........34 CONCLUSION....................................................................................................................36 APPENDICES........................................................................................383 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 CommandSection 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333 SO Safety Observer SOP Standard Operating Procedures UA Unmanned Aircraft UAS Unmanned Aircraft System VFR Visual Flight Rules VLOS Visual Line of Site VMC Visual Meteorological Conditions VTOL Vertical Takeoff and Landing4 SUMMARY Cellcom Inc. seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of theFAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Cellcom Inc. to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography of construction sites, real estate, and landsca pe

over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONERCellcom Inc. provides its clients with expertise and knowledge in advanced technologies and solutions to increase efficiency, productivity and effectiveness. Ce llcom Inc. has over 13 years of professional experience in Information Technology and is re cognized as an expert in network infrastructure, project management and Construction manageme nt. Cellcom Inc. has over 3 years recreational/hobby experience in all aspect s of aerial video and photography. The objective of Cellcom Inc.’s aerial video and photography operations is to provide high quality imaging for a variety of commercial, public, and resi dential uses, specifically targeting:

• Sourcing GIS tagged aerial images for use in Computer Assisted Mass Appraisal (CAMA) systems.

• Motion Picture Filming

• Aerial acquisitions used for inspections of public and private structures.

• Increase public knowledge of UAS and promote safe UAS operations.

• Search and Rescue operations utilizing Thermal imaging5 BACKGROUND Unmanned Aircraft Systems: DJI Phantom 2 Vision+, DJI Inspire 1 UASs+ DJI Ma trice 100 Cellcom Inc. seeks an exemption to operate DJI systems for compensation or hire within the NAS. The DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 are vert ical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Sta tion (GCS) utilizing electronic tablet or smart phone systems. The DJI Phantom 2 V ision+ has a maximum gross weight of approximately 2 pounds 11 ounces, while having a length of 16 inches width of 16 inches, height of 8 inches, and a maximum speed of approximately 29 knots. The DJI Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of approximately 42 knots. The DJI Matrice 100+ has a maximum gross weight of approximat ely 5 pounds 9 ounces, while having a length of 25 inches width of 25 inches, height of 8 inches,and a maximum speed of approximately 19 knots. The DJI Phantom 2 Vision+ and DJI Inspire 1+ Matrice 100 UAs are equipped with four main rotors; driven by Lithium Polymer battery powered electric motors. The DJI Phantom 2 Vision+ and DJI Inspire 1 UAs + DJI Matrice 100 that will be operated by Cellcom 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

.6 BASIS FOR PETITIONPetitioner, Cellcom 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 2 Vision+, DJI Inspi re 1 + DJI Matrice 100 UASs in the National Airspace System (NAS), and for an exempti on 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 associa ted with the unmanned aircraft and its operation, Cellcom Inc.’s operation of DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs meets the conditions of FMRA Sec tion 333 and therefore, will not require an airworthiness certificate in accordanc e with 14 C.F.R. Part 21, Subpart H. Accordingly, Cellcom Inc. requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements f or maintenance that only apply to aircraft with an airworthiness certificat e. Cellcom Inc. submits that the requested relief is proper since an equivalent le vel of safety will be ensured. Cellcom Inc. will use experienced personnel or techni cians to perform maintenance, alterations, or preventive maintenance on the UASs using the met hods,techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 Instruc tion Manual). Furthermore, Cellcom Inc. will document and maintain all maintenance records for the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs.7 Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command , is requested by Cellcom 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 demonstrate d, by meeting minimum flight- hour and currency requirements, that the PIC is able to safely operat e the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs in a manner consistent wi th this exemption, including evasive and emergency maneuvers and maintaining appropri ate distances from people, vessels, vehicles and structures. Cellcom Inc. seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness ,because the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Cellcom Inc. submits that he will ensure that the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs are in an airworthy condition, prior to every fl ight, by determining that the UASs are in compliance with the operating documents (i.e., Monthl yMaintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1 + DJI Matrice 100 Instruction Manual), and that the aircraft are in a condition for safe flight.Cellcom Inc. also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , as the DJI Phantom 2 Vision+ and DJI Inspire 1 + DJI Matrice 100 UAs will not have a typical barometric altimeter onboard. However, altitude information of the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 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 Cellcom Inc.’s operat ion of the8

DJI Phantom 2 Vision+ and DJI Inspire 1 + DJI Matrice 100 UASs within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Sect ion 91.121. Additionally, Cellcom Inc. seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions . Cellcom Inc. submits that safety will not be affected by operation of the DJI Phantom 2 Vision+ and DJI Inspire 1 + DJI Matrice 100 UAS during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a tota l duration of approximately 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.In accordance with 14 C.F.R. § 11.81, Cellcom 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:

Cellcom Inc. 42650 Long Lake Rd. Ottertail, MN 56571 Tel: (218) 849-8087 Email: almw@eot.com B. The Specific Sections Of 14 C.F.R. From Which Cellcom Inc. Seeks Exe mption. 1. Cellcom 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 comma nd (PIC) of an aircraft that is carrying passengers or property for com pensation 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; and9 (2) The aircraft does not carry passengers or property for compensation or hire.

2. Cellcom 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 condit ion.

3. Cellcom 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 t hat 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 de

parture. 4. Cellcom 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. Cellcom 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—10 (a) Shall have that aircraft inspected as prescribed in subpart E of this part a nd shallbetween required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.] 6. Cellcom 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, prevent ive 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. Cellcom 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 accor dance with part 21 of this chapter. 8. Cellcom 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; and11(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. (iv) The current inspection status of the aircraft, including the time since th elast 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 saf ety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directiveinvolves 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 pr escribed: (1) The records specified in paragraph (a)(1) of this section shall be retaine d 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 retaine d 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 aircra ft is approved for return to service.12

C. The Extent Of Relief Cellcom Inc. Seeks And The Reason Cellcom Inc . Seeks The Relief. 1. Extent Of Relief Cellcom Inc. Seeks And The Reason Cellcom Inc. Se eks 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 airma n medical certificate, and who has met certain flight-hour and currency requirements, to conduct the pr oposed 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 aircr aft 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, Cellcom Inc. submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the DJI Pha ntom 2 Vision+ UAS or DJI Inspire 1 UAS+ DJI Matrice 100 UAS unless that PIC has met c ertain flight-hour and currency requirements, demonstrating that the PIC is able to sa fely operate either the DJI Phantom 2 Vision+ or DJI Inspire 1+ DJI Matrice 100 UAS in a manne r consistent with the operations specifications as described in this exemption, incl uding evasive and emergency maneuvers, as well as maintaining appropriate distances f rom people, vessels, vehicles and structures.13 Further, Cellcom Inc. submits that all flights of the DJI Phantom 2 Vision+ and DJI Inspire 1 + DJI Matrice 100 UASs, conducted by the PIC pursuant to the grant of this Peti

tion: (1) will be incidental to Cellcom Inc.’s business; and (2) will not carry pa ssengers or property for compensation or hire.

2. Extent Of Relief Cellcom Inc. Seeks And The Reason Cellcom Inc. Se eks Relief From Section 91.7(a). Relief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to the extent required to allow Cellcom Inc. to determine that the DJI Phantom 2 Vis ion+ and DJI Inspire 1 + DJI Matrice 100 UASs are in airworthy condition prior to every flig ht by ensuring that the UAS is in compliance with the operating documents (i.e., the Cellcom In c. Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 Instruction Manual). Cellcom Inc. seeks the requested relief because the DJI Phantom 2 Vision+ a nd DJI Inspire 1 + DJI Matrice 100 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Cellcom Inc. will ensure that the DJI P hantom 2 Vision+ and DJI Inspire 1 + DJI Matrice 100 UASs are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 Instruction Manual) pri or 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 Cellcom Inc. Seeks And The Reason Cellcom Inc. Se eks Relief From Section 91.121. Relief from Section 91.121, entitled Altimeter settings, may be required to al low flight operations of the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UA Ss, which utilize a barometric pressure sensor, GPS equipment, and a radio communications14

telemetry data link to downlink altitude information from the UA to the PIC at the gr ound 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), Cellcom Inc. seeks the requested relief because the DJI Phantom 2 Vision+ a nd DJI Inspire 1 + DJI Matrice 100 UA’s altimeter may be set on the ground to zero feet AGL, ra ther than the local barometric pressure or field altitude, before each flight. Considering the limited altitude of the proposed operations, relief from 14 CFR91.121 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 safet y will be maintained since the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UAs are equipped with a barometric pressure sensor and GPS equipment, which automatically en

sures 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 Cellcom Inc. Seeks And The Reason Cellcom Inc. Se eks 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 DJ I Phantom 2 Vision+ and DJI Inspire 1 + DJI Matrice 100 UAs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. Cellcom Inc. seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered DJI Phantom 2 Vision+ and DJI Inspire 1 + DJI Matrice 100 UAs will severely constrain15

the practicality of any aerial video or still photo flight operations that Cell com Inc. proposes to conduct pursuant to this Petition. Significantly, as set forth below, the technical specifications of the DJI Pha ntom 2Vision+ and DJI Inspire 1 UASs, the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 operating documents, and Cellcom Inc.’s proposed operating limitations, ens ure that Cellcom Inc. will safely operate the battery powered DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UAs during daylight hours in visual meteorological condi tions (VMC), under visual flight rules (VFR), with enough battery power to fly for a tota l duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

5. Extent Of Relief Cellcom Inc. Seeks And The Reason Cellcom Inc. Se eks 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, Cellcom Inc. r equests relief from these Sections because the DJI Phantom 2 Vision+ and DJI Inspire 1 + DJI Matric e 100 UASs do not require airworthiness certificates. As set forth more fully below, the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly , Cellcom Inc. will use trained technicians to perform maintenance, alterations, or pr eventive maintenance on the UASs using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the Cellcom Inc. Aerial Operations Manual, MonthlyMaintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1 + DJI Matrice 100 Instruction Manual). Furthermore, Cellcom Inc. will document and maintain all mai ntenance records for the DJI Phantom 2 Vision+ and DJI Inspire 1 + DJI Matrice 100 UASs.16

D. The Reasons Why Granting Cellcom Inc.’s Request Would Be In The Publi c Interest; That Is, How It Would Benefit The Public As A Whole. Granting the present Petition will further the public interest by allowing C ellcom Inc. to safely, efficiently, and economically perform aerial video and photogr aphy of construction sites, real estate, and landscape over certain areas of the United States. Additionally, use of the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of Cellcom Inc.’s proposed operati on of the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs will be realize d without implicating any privacy issues. 1. The Public Will Benefit From Decreased Congestion Of The NAS. The DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UAs are battery powered and serve as a safe, efficient, and economical alternative to the manne d aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of ma nned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJI Phant om 2Vision+ or DJI Inspire 1+ DJI Matrice 100 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 re duced. The DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UAs do not require an airpor t to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial vide o and photography missions would result in fewer aircraft that must be handled by air t raffic control during the ground, takeoff, departure, arrival, and landing phases of flight operat ions.17 2. The Public Will Benefit From The Safety And Efficiency Of The DJI Ph antom 2 Vision+ and DJI Inspire 1 UASs. Conducting aerial acquisitions with the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs, instead of manned aircraft, will greatly benefit t he public by drastically reducing the levels of air and noise pollution generated during traditio nal aerial video and still photography flight operations. By using battery power and electric motor s, the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs 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 aeria l video and photography, while burning approximately 20-30 gallons per hour of leaded aviation fuel. The DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UAs, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAs are pr opelled by battery powered electric motors, rather than an internal combustion eng ine. By using the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs 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 ope rations, will be substantially reduced or completely eliminated. Aside from the lack of fli ght crew members located onboard the aircraft, the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI M atrice 100 UAs (weighing approximately 2 pounds 11 ounces and 6 pounds 7.5 ounces and 5 pounds 2 ounces respectively, at their maximum gross weights with lengths of 16 inches and 17.3 inches and 25.6 inches respectively, widths of 16 inches and 17.7 inches and 25.6 inches respectively, and with no fuel on board), has less physical potential for coll ateral damage to life and property on the ground, and in the air, compared to the manned aircraft18

that typically conduct similar operations (weighing approximately 6,000 pounds wit h a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gal lons).3. Performing Aerial Video and Photography Operations With The DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs Will Benefit The Economy. In addition to being safe and efficient, the DJI Phantom 2 Vision+ and DJI Inspire 1 + DJI Matrice 100 UASs are also an economical alternative to using manned airc raft to conduct similar aerial operations. As such, operation of the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs will allow United States based compani es, like Cellcom 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 Age ncy (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operat ed companies must adopt new and alternative technology in order to remain competitive . Operating the battery powered DJI Phantom 2 Vision+ and DJI Inspire 1 + DJI Matr ice 100 UASs is one such technology that not only allows companies greater operational f lexibility compared to manned aircraft, but provides such flexibility without the high operati onal

cost of a traditional manned aircraft. By operating the DJI Phantom 2 Vision+ and DJI Inspire 1 + DJI Matrice 100 UASs, companies such as Cellcom Inc., can remain competitive and profitable, and the refore, provide greater job stability to employees and contractors, which will ul timately contribute to growth of the U.S. economy. Improved financial performance of U.S. companie s, through commercial use of the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matric e 100 UASs, provides a stable workforce that increases consumer spending; improves loc al,19

state, and federal tax revenues; and allows companies to invest in research a nd 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 fordecades, Cellcom Inc.’s proposed operation of the DJI Phantom 2 Vision+ and DJI Inspire 1 + DJI Matrice 100 UASs will not implicate any privacy issues. Specifical ly, the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs will be operated only in compliance with operating documents (i.e., the Cellcom Inc. Aerial Operations Manual, MonthlyMaintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1 + DJI Matrice 100 Instruction Manual) which requires property owner involvement as well as local l aw enforcement notification, and in accordance with the Federal Aviation Regulations, including t he 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 Cellcom Inc. Seeks Exemption. 1. Reasons Why The DJI Phantom 2 Vision+ and DJI Inspire 1 + DJI Matrice 100 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 associa ted with the unmanned aircraft and its operation, Cellcom Inc.’s operation of the DJI Phant om2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will crea te a hazard to20

users of the NAS or the public, or otherwise pose a threat to national security. Spec ifically, 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 ofTransportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the plan andrulemaking 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 StatesCode, is required for the operation of unmanned aircraft systems identified under paragraph (1). (c) Requirements for Safe Operation.--If the Secretary determines under this se ction that certain unmanned aircraft systems may operate safely in the nationalairspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system. In seeking this exemption, Cellcom Inc. submits that the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI Pha ntom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs; (b) the pilot certification re quirement; and (c) the specific operating limitations.

a. The Specifications Of The DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs Demonstrate Its Safe Characteristics.The DJI Phantom 2 Vision+ and DJI Inspire 1 + DJI Matrice 100 UASs do 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.21i. Technical Specifications Of The DJI Phantom 2 Vision+ and DJI Inspire 1 UASs. The technical specifications of the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs are set forth by the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJ I Matrice 100 Specifications and Data Sheet, attached hereto as Exhibit A and B and C.

ii. The DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs Autonomous Flight And Navigation Modes Enable The UASs To Remain Within A Defined Operational Area.The DJI Phantom 2 Vision+ and DJI Inspire 1 + DJI Matrice 100 UASs may be operated in both manual and fully autonomous flight modes. A complete description of theflight and navigational modes of the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs is provided at pages 25-35 of the DJI Phantom 2 Vision+ and pages 12-16 and 45-50 of the DJI Inspire 1 + DJI Matrice 100 User Manuals, attached hereto as Ex hibit

D and E and F.

iii. The DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs Are Designed For Automatic Return To Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation. When the Control Link is lost, the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UAs will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UAs do not reacquire control link data from the GCS, the UAs will assume that the Control Link is lost and the UAs will return to the home position (i.e., failsafe mode) via GPS, and will desce nd to the takeoff position and shutdown. A complete description of the Failsafe Functions of the DJI Phantom 2 Vision+ UAS are set forth at pages 27 through 29 and for the DJI Inspire 1 at pages 13 through 1522

of the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 User Manuals, atta ched

hereto as Exhibit D and E and F.

iv. The DJI Phantom 2 Vision+ and DJI Inspire 1 + DJI Matrice 100 GCS And Its Operation. A complete description of the operation and specifications of the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 GCS and flight control software is provi ded at pages 32 through 43 of the DJI Phantom 2 Vision+ User Manual and pages 40 through 47 of the DJI Inspire 1 User Manual. DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Ma trice

100 User Manuals are attached hereto as Exhibits D and E and F.

b. Flight Operations Of DJI Phantom 2 Vision+ and DJI Inspire 1 + DJI Matrice 100 UASs Are Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer. Cellcom Inc. will only utilize certificated pilots who possess a current and valid airman medical certificate to act as a pilot in command (PIC) of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs. Additionally, a safety observer will assist all pi lots during flight

time. c. Flights Of DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100

UASs Will Be Conducted Pursuant To Specific Operating Limitations. In seeking this exemption, Cellcom Inc. proposes to commercially operate D JI Phantom 2 Vision+ and DJI Inspire 1 UASs for the special purpose of conducting aerialvideo 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 follow ing aircraft described in the operating documents, rotorcraft UASs weighing l ess than 55 pounds maximum gross weight: DJI Phantom 2 Vision+ and DJI Inspire 1 + DJI Matrice 100 Unmanned Aircraft Systems. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant.23 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 500 feet above groundlevel (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 alltimes. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA-issued airm an 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 sati sfy 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 bedesignated 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 duringUAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations contained in the grant ofexemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption take precedence andmust 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 a rise regarding updates or revisions to the operating documents.2410. 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 s afe 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 forsafe 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 UA S operation or flight characteristics, e.g. replacement of a flight critica l 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 keepingrequirements, in accordance with the operating documents. Maintenance, inspection, 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 UASs operated under this exemption must comply with all manufacturer Safety Bulletins.16. The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections. 17. The PIC must possess at least a private pilot certificate and at least a current third- class medical certificate.18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safely operat e theUAS 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 qualifi cation 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 t he terms of the exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experi-25 ence-building flights, all persons not essential for flight operations are cons idered 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 asdenoted 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 Certific ate 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 operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspa ce, altitude level and potential transponder requirements. 26. All aircraft operated in accordance with the exemption must be identified by se

rial number, registered in accordance with 14 C.F.R. part 47, and have identification (N- Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable.26 27. Before conducting operations, the radio frequency spectrum used for operationand 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 nonpartici patingpersons 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 theowner/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 orvertical 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

.27 2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety. Cellcom Inc. submits that the equivalent level of safety established by Sect ion 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs unless that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely ope rate the DJI Phantom 2 Vision+ or DJI Inspire 1 + DJI Matrice 100 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appro

priate distances from people, vessels, vehicles and structures.Considering Cellcom 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 2 Vision+ or DJI I nspire 1+

DJI Matrice 100 UAS, Cellcom Inc. submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airma nship skills necessary for Cellcom 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 present ed herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). Cellcom Inc. will not allow any PIC to operate the DJI Phantom 2 Vision+ or DJI Inspire 1+ DJI Matrice 100 UAS unless that PIC has demonstrated, by meeting mi nimum flight-hour requirements or the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS training and currency requirements, that the PIC is able to safely operate the DJI Phantom 2 V ision+ or28

DJI Inspire 1+ DJI Matrice 100 UAS in a manner consistent with this exempti on, 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 consistentwith 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 pur

poses).As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equi valent level of safety during Cellcom 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 forthe 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 oftotal 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 pilotoperating 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 mustaccomplish 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 tha t prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experi encebuilding flights can also be conducted under the grant of exemption to accomplish29 the required flight time. During training, proficiency, and experience-buildi ng flights the PIC is required to operate the UA with appropriate distances in accor dance with 14 C.F.R 91.119. Exemption No. 11138 at page 15. Accordingly, Cellcom Inc. will ensure safe operations by not allowing any PIC to operate the DJI Phantom 2 Vision+ or DJI Inspire 1+ DJI Matrice 100 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 2 Vision+ or DJI Inspire 1+ DJI M atrice 100 UAS in a manner consistent with the exemption, including evasive and emergency ma neuvers and maintaining appropriate distances from people, vessels, vehicles and str uctures. 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, Cellcom Inc. will ensure that the DJI Phantom 2 Vision+ or DJI Inspire 1+ DJI Matrice 100 UAS is in an airworthy condition based upon the UAS’s compliance with its operating documents and as stated in the conditions and limitations her ein. Additionally, the FAA has previously granted relief from Section 91.7(a) specifi c to UAS, in circumstances similar, in all material respects, to those present ed 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 2 Vision+ and DJI Inspire 1+ DJI Ma

trice 100 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 the30

flight path and altitude. This altitude information, combined with Cellcom Inc.’s oper ation of the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UAs within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Se ction 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 automat ically established by the UASs at ground level.The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e .g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 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 Pha ntom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs; (2) the limitations on the pr oposed flight operations; and (3) the location of the proposed flight operations. Accordingl y, Cellcom Inc. will ensure that it will safely operate the battery power ed DJI Phantom 2 Vision+ and DJI Inspire 1 UAs during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safety establi shed by31

14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs provide audible and visual warnings to the PIC at the GCS when the UAs experiences low battery voltage, the first w arning occurring at approximately 33% remaining battery power, and again at approximate ly 10% remaining battery power. At the critically low battery level, the DJI Phant om Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs 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 charac teristics 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, Cellcom Inc. submits that the equivalent level of sa fety with regard to the regulatory maintenance and alteration requirements establ ished by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because Cellcom Inc. will use trained technicians to perform maintenance, a lterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., the Cellcom Inc. Aerial Operations Manual, Monthl y32

Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 Instruction Manual). Furthermore, Cellcom Inc. will document and maintain all mai ntenance records for the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs. Since the DJI Phantom 2 Vision+ and DJI Inspire 1 + DJI Matrice 100 UASs will be inspected as prescribed by the operating documents, Cellcom Inc. will mai ntain 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 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 User Manuals are attached hereto as Exhibit C and D; a copy of the DJI Phantom 2 V ision+ and DJI Inspire 1 UAS Maintenance LOG is attached hereto as Exhibit E. Likewise, the exemption sought will not adversely affect safety because Cel lcom Inc. will use trained technicians to perform maintenance, alterations or prevent ive maintenance on the UAS using the methods, techniques, and practices prescribed by the opera ting

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 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs 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 limi tations of the

UAS are considered.33 In consideration of Cellcom Inc.’s proposed operating limitations, the operating documents, and the technical aspects of the DJI Phantom 2 Vision+ and DJI Inspire 1+ D JI Matrice 100 UASs, Cellcom Inc. submits that safety will not be adversely a ffected 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 present ed 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, Cellcom Inc. requests that the FAA prescribe special conditions for the intended operation of the DJI Phantom 2 Visi on+ and DJI Inspire 1+ DJI Matrice 100 UASs, which contain such safety standards that t he 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 conducti ng aerial video and photography over certain areas of the United States for compensati on or hire. FMRA Section 333 sets forth the requirements for considering whether a UA S will create a hazard to users of the NAS or the public, or otherwise pose a threat to nati onal security; and further, provides the authority for such UAS to operate without airworthi ness certification in accordance with any requirements that must be established for the safe operation of the UAS in the NAS.34 Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs, 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 airc raft. 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 eng ine, or propeller because of a novel or unusual design feature of the aircraft, aircraft engi ne 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 propell er as the FAA finds necessary to establish a level of safety equivalent to that establi shed 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 D JI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs, which contain such safety standards that the Administrator finds necessary to establish a level of safe ty 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).

F. A Summary That Can Be Published In The Federal Register, stating: The Rules From Which Cellcom Inc. Seeks Exemption: Cellcom 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 Cellcom Inc. Se eks:35 This exemption will permit Cellcom Inc. to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States.

G. Any Additional Information, Views, Or Arguments Available To Support Cellc om 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, Cellcom Inc.’s request for ex emption 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 nati onal security; and further, provides the authority for such UAS to operate without airworthi ness

certification. As discussed in detail above, Cellcom Inc. will operate the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs safely in the NAS, without creating a ha zard to users of the NAS, or the public, or otherwise pose a threat to national security.

CONCLUSION As set forth herein, Cellcom Inc. seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs commercially, without an airworthiness certificate, for the limite d 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 manda te of the36

FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing Cellcom Inc. to safely, efficiently, and economically oper ate the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs commercially within the

NAS.

WHEREFORE , in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, Cellcom 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 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs commercially for the pu rpose of conducting aerial video and photography over certain areas of the United States

. Dated: November 20, 2015

Respectfully submitted,

Cellcom Inc.

_________________________ Cellcom Inc. 42650 Long Lake Rd. Ottertail, MN 56571 Tel: (218) 849-8087 almw@eot.com37

Appendices: A – DJI Phantom 2 Vision+ Specifications Data Sheet B – DJI Inspire 1 Specifications Data Sheet C – DJI Matrice 100 Specifications Data Sheet D – DJI Phantom 2 Vision+ Manufacturer’s User Manual E – DJI Inspire 1 Manufacturer’s User Manual F– DJI Matrice 100 Manufacturer’s User Manual G – Monthly Maintenance Log

APPENDIX – A

DJI PHANTOM 2 VISION+ TECHNICAL SPECIFICATIONS Cellcom Inc. only utilizes safe and reliable UASs. DJI is an industry lea der in small UAS production. DJI UASs are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameter s can also be set to limit flight to no higher than a predetermined and set altitude as well as lim it flight to a predetermined and set distance. In addition, DJI software provides real-time a ltitude and location information to the PIC via the linked monitor (smart phone/tablet devices)

1.1 DJI Phantom 2 Vision+

1.1.1 Aircraft 1.1.1.1 Supported Battery – DJI 5200mAH LiPo Battery 1.1.1.2 Weight (Battery & Propellers Included) – 2lbs 11.810oz (1242g) 1.1.1.3 Hover Accuracy (Ready to Fly) – Vertical: .8m; Horizontal: 2.5m 1.1.1.4 Max Yaw Angular Velocity - 200  /s 1.1.1.5 Max Tilt Angel - 35  1.1.1.6 Max Ascent Speed – 6m/s38 1.1.1.7 Max Descent Speed – 2m/s 1.1.1.8 Max Flight Speed – 15m/s (NOT RECOMMENDED)

1.1.2 Gimbal 1.1.2.1 Working Current – Static: 750mA; Dynamic: 900mA 1.1.2.2 Control Accuracy - ±0.03  1.1.2.3 Controlable Range – Pitch: -90  - 0  1.1.2.4 Maximum Angular Speed – Pitch: 90  /s

1.1.3 Camera 1.1.3.1 Operating Temperature Range - 32  F - 104  F (0  C - 40  C) 1.1.3.2 Sensor Size – 1/2.3” 1.1.3.3 Effective Pixels – 14M 1.1.3.4 Resolution – 4384x3288 4.1.3.5 HD Video Recording – 1080p30 & 720p 4.1.3.6 Recording Field of View - 110  /85 

1.1.4 Transmitter 1.1.4.1 Operating Frequency – 5.728GHz – 5.85GHz 1.1.4.2 Communication Distance (unobstructed) – FCC Compliance: 800m 1.1.4.3 Receiver Sensitivity (1%PER) - -93dBm 1.1.4.4 Transmitter Power – FCC Compliance: 100mW 1.1.4.5 Working Voltage – 120mA@3.7V 1.1.5 Range Extender 1.1.5.1 Operating Frequency – 2412-2462MHz 1.1.5.2 Communication Distance (unobstructed) – 500-700m 1.1.5.3 Transmitter Power – 20dBm 1.1.5.4 Power Consumption – 2W39 APPENDIX – B DJI INSPIRE 1 Pro TECHNICAL SPECIFICATIONS Cellcom Inc. only utilizes safe and reliable UASs. DJI is an industry lea der in small UAS production. DJI UASs are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameter s can also be set to limit flight to no higher than a predetermined and set altitude as well as lim it flight to a predetermined and set distance. In addition, DJI software provides real-time a ltitude and location information to the PIC via the linked monitor (smart phone/tablet devices) 2.2 DJI Inspire 1

2.2.1 Aircraft 2.2.1.1 Model – T600 2.2.1.2 Weight (Battery Included) – 6lbs 7.5291oz ( 2935g) 2.2.1.3 Hovering Accuracy (GPS Mode) – Vertical: 0. 5m; Horizontal: 2.5m 2.2.1.4 Max Angular Velocity – Pitch: 300 0 /s; Yaw: 150 0 /s 2.2.1.5 Max Tilt Angle - 35 0 2.2.1.6 Max Ascent Speed – 5m/s 2.2.1.7 Max Descent Speed – 4m/s 2.2.1.8 Max Speed – 22m/s (ATTI mode, no wind – NOT RECOMMENDED) 2.2.1.9 Max Flight Altitude – 4500m 2.2.1.10 Max Wind Resistance – 10m/s 2.2.1.11 Max Flight Time – Approximately 18 minutes 2.2.1.12 Motor Model – DJI 3510 2.2.1.13 Propeller Model – DJI 1345 2.2.1.14 Operating Temperature Range – 14 0 F to 104 0 F (-10 0 C to 40 0 C) 2.2.1.15 Dimensions – 17 1⁄4” x 17 3⁄4” x 12”

2.2.2 Gimbal 2.2.2.1 Model – ZENMUSE X5 2.2.2.2 Output Power (with camera) – Static: 9W; In Motion: 11W 2.2.2.3 Operating Current – Static: 750mA; In Motio n: 900mA 2.2.2.4 Angular Vibration Range - ±0.03 0 2.2.2.5 Mounting – Detachable 2.2.2.6 Controllable Range – Pitch: -90 0 to +30 0 ; Pan: ±320 0 2.2.2.7 Mechanical Range – Pitch: -125 0 to 45 0 ; Pan: ±330 040 2.2.2.8 Max Controllable Speed – Pitch: 120 0 /s; Pan: 180 0 /s

2.2.3 Camera 2.2.3.1 Name – X3 2.2.3.2 Model – FC350 2.2.3.3 Total Pixels – 12.76M 2.2.3.4 Effective Pixels – 12.4M 2.2.3.5 Image Max Size – 4000x3000 2.2.3.6 ISO Range – 100-3200 2.2.3.7 Field of View - 94 0 2.2.3.8 CMOS – Sony EXMOR 1/2.3” 2.2.3.9 HD Video Recording – UHD(4K): 4096x2160p24/ 25, 3840x2160p24/25/30; FHD: 1920x1080p24/25/30/48/50/6 0; HD: 1280x720p24/25/30/48/50/60 2.2.3.10 Operating Temperature Range - 32 0 F - 104 0 F (0 0 C - 40 0 C)

2.2.4 Transmitter 2.2.4.1 Name – C1 2.2.4.2 Operating Frequency – 5.728-5.850GHz; 2.400 -2.483GHz 2.2.4.3 Communicating Distance (unobstructed) – 200 0m 2.2.4.4 Output Power – 9W 2.2.4.5 Operating Temperature Range - 14 0 F to 104 0 F (-10 0 C to 40 0 C) 2.2.4.6 Battery – 600mAh LiPo 2S

APPENDIX – C41 DJI Matrice 100 TECHNICAL SPECIFICATIONS Cellcom Inc. only utilizes safe and reliable UASs. DJI is an industry lea der in small UAS production. DJI UASs are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameter s can also be set to limit flight to no higher than a predetermined and set altitude as well as lim it flight to a predetermined and set distance. In addition, DJI software provides real-time a ltitude and location information to the PIC via the linked monitor (smart phone/tablet devices)

2.2 DJI Matrice 100

2.2.1 Aircraft 2.2.1.1 Model – DJI E-Series 620D 2.2.1.2 Weight (Battery Included) – 6lbs 7.5291oz ( 2935g) 2.2.1.3 Hovering Accuracy (GPS Mode) – Vertical: 0. 5m; Horizontal: 2.5m 2.2.1.4 Max Angular Velocity – Pitch: 300 0 /s; Yaw: 150 0 /s 2.2.1.5 Max Tilt Angle - 35 0 2.2.1.6 Max Ascent Speed – 5m/s 2.2.1.7 Max Descent Speed – 4m/s 2.2.1.8 Max Speed – 22m/s (ATTI mode, no wind – NOT RECOMMENDED) 2.2.1.9 Max Flight Altitude – 4500m 2.2.1.10 Max Wind Resistance – 10m/s 2.2.1.11 Max Flight Time – Approximately 40 minutes 2.2.1.12 Motor Model – DJI 3510 2.2.1.13 Propeller Model – DJI 1345s 2.2.1.14 Operating Temperature Range – 14 0 F to 104 0 F (-10 0 C to 40 0 C) 2.2.1.15 Dimensions – 25.6” x 25.6”

2.2.2 Gimbal 2.2.2.1 Model – ZENMUSE X5 2.2.2.2 Output Power (with camera) – Static: 9W; In Motion: 11W 2.2.2.3 Operating Current – Static: 750mA; In Motio n: 900mA 2.2.2.4 Angular Vibration Range - ±0.03 0 2.2.2.5 Mounting – Detachable 2.2.2.6 Controllable Range – Pitch: -90 0 to +30 0 ; Pan: ±320 0 2.2.2.7 Mechanical Range – Pitch: -125 0 to 45 0 ; Pan: ±330 0 2.2.2.8 Max Controllable Speed – Pitch: 120 0 /s; Pan: 180 0 /s

2.2.3 Camera42 2.2.3.1 Name – X5 2.2.3.2 Model – Zenmuse X5 2.2.3.3 Total Pixels – 16MP 2.2.3.4 Effective Pixels – 12.4M 2.2.3.5 Image Max Size – 4000x3000 2.2.3.6 ISO Range – 100-3200 2.2.3.7 Field of View - 94 0 2.2.3.8 CMOS – Sony EXMOR 1/2.3” 2.2.3.9 HD Video Recording – UHD(4K): 4096x2160p24/ 25, 3840x2160p24/25/30; FHD: 1920x1080p24/25/30/48/50/6 0; HD: 1280x720p24/25/30/48/50/60 2.2.3.10 Operating Temperature Range - 32 0 F - 104 0 F (0 0 C - 40 0 C)

2.2.4 Transmitter 2.2.4.1 Name – C1 2.2.4.2 Operating Frequency – 5.728-5.850GHz; 2.400 -2.483GHz 2.2.4.3 Communicating Distance (unobstructed) – 200 0m 2.2.4.4 Output Power – 9W 2.2.4.5 Operating Temperature Range - 14 0 F to 104 0 F (-10 0 C to 40 0 C) 2.2.4.6 Battery – 600mAh LiPo 2S

APPENDIX – D43 DJI Phantom 2 Vision+ Manufacturer’s User Manualhttp://download.dji-innovations.com/downloads/phantom_2/en/PHANTOM2_User_Manual_v1.2_en.pdf

APPENDIX – E DJI Inspire 1 Manufacturer’s User Manual

http://192.168.1.1:8181/http:/download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.0_en.pdf

APPENDIX – F DJI Matrice 100 Manufacturer’s User Manual

http://192.168.1.1:8181/http:/download.dji-innovations.com/downloads/dev/Matrice/en/M100_User_Manual_v1.0_en.pdf44 APPENDIX – G Maintenance Log

**Date issue discovered**  **Date issue**

**resolved Issue Descrip** 

**tion/Mainenance Conducted**  **Repair/ Maintance**

**performed By**

**Airframe Motor**  **Propellers Flight Control Update**  **Gimbal Misc** 45