UNITED STATES OF AMERI CA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

WASHI NGTON, DC

Regulatory

Docket No. _______________

**IN THE**  **MATTE R O**  **F THE PETITION FOR EXEMPTION OF:**

MLT VIDEO PRODUCTIONS, LLC **FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF**

**TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.11**  **3(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 O F**  A **DJ I**  **INSPIRE 1 UNMANNED AIRCRAFT SYSTEMS** 

**PURSUANT TO SECTION 333 OF T**  **HE FAA MODERNIZATION AND REFORM ACT OF**  **2 0**  **1 2** 

**(PUBLIC LAW 112-95)**

Submitted on A pril 2 , 2015 MLT Video Productions, LLC Mike Pruett, CEO 411 North Broadway Rochester, MN 55906 Office: 507-281-3490 Cell: 507-261-12672 **TABLE OF CONTENTS** Page GLOSSARY OF ABBREVIATIONS...................................................................................3 SUMMARY.................................................................................................... .......................4
IN TRODUCTION AND INTERESTS OF PETITIONER....................................................4 BACKGROUND................................................................................................................... .4 BAS IS FOR PETITION.........................................................................................................5 NAME AND ADDRESS OF PETITIONER.............................................................7
THE SPECI FI C SECTIONS OF 14 C.F.R. FRO M WHI CH MLT Video Productions, LLC SEEKS EXEMPTI ON.................................................................8 THE EXTENT OF RELIEF MLT Video Pro d u ctions, LLC SEEKS AND THE REASON MLT Video Product ions, LLC SEEKS THE RELIEF.......... ...............11 THE REASONS WHY GRANTING MLT Video Productions, LLC REQUEST WOULD BE IN THE PUBLIC IN TEREST .........................................................15 THE REASONS WHY GRANTING THE EXEMPTI ON WOULD NOT ADVERSEL Y AFFECT SAFETY............................................. .............................19 SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGI STER......34 ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT MLT Video Productions, LLC REQUEST.........34

CONCL USION.............................................. ......................................................................35

EXHIBIT

.................................... ... ... ... ...........................................3 63 **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 Sy stem LOL Loss of Link NAS National Airspace Sy stem NOTAM Notice to Airman PI C Pilot I n Command Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333 SO Safety Observer SOP Standard Operating Procedures UA Unmanned Aircraft UAS Unmanned Aircraft Sy stem VFR Visual Flight Rules VLOS Visual L ine of Site VMC Visual Meteorological Conditions VTOL Vertical Takeoff and Landing4 **SUMMARY** MLT Video Productions, LLC seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91 .417(a) & (b), to operate an Unmanned Aircraft Sy stem pursuant to Section 333 of the FAA Moder n ization and R eform Act of 2012 (FMRA). This exemption will permit MLT Video Productions, LLC to oper ate an Unman n ed Aircraft Sy stem (UAS) for the co mmercial p urpose of co nducting aerial video an d photography of construction sites, real estate, and l andscap e o ver certain areas o f the
Un ited States.

**INTRODUCTION AND INTERESTS OF THE PETITIONER** MLT Video Productions, LLC is a marketing solutions company providing its clients with design and development of marketing materials incl uding photography and

v id eo g r ap h y . MLT Video Productions, LLC has over 28 years of professional experience in v id eo pr oduction and is recognized as an expert in corporate and traini ng video d ev elo p men t. MLT Video Productions has been building expertise in aerial video and
p h o to gr ap h y since 2013. The objective of MLT Video Productions, LLC aerial video and
p h o to gr ap h y operations is to provide high quality imaging for a variety of commercial,
p u b lic, an d r esidential uses, specifically targeting:

 Video Capture for industrial or training videos

 Inspections of public and private structures

 Video and Photographic Capture for real estate

 Search and Rescue operations in cooperation with local law enfo rcement5 **BACKGROUND** Unmanned Aircraft Sy stems: DJI Inspire 1 UAS MLT Video Productions, LLC seeks an exemption to operate DJ I systems for compensation or hire within the NAS. Th e DJ I I n spire 1 are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing el ectronic tablet o r

smart phone sy ste ms. The DJ I I nspire 1 has a maximum gro ss we ight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of app roximately 4 2 k no ts. The DJ I I n spire 1 UAs is equipped with four main r o to r s; driven by L ithium Poly mer ba ttery po wered electric
motors.

The DJI I n spire 1 UAs that will be o p erated b y MLT Video Productions, LLC will be registered in accordance with 49 U.S.C. 44103, Registration o f Aircra ft , as well as 14 C.F.R Part 47, Aircraft Registration , an d marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking

.

**BASIS FOR PETITION** Petitioner, MLT Video Productions, LLC , 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), Sectio n 333, Special Rules fo r C ertain Unma nn ed Aircraft Systems , h ereb y petitions the Administrator to commerciall y op erate the DJI
I n spire 1 UAS in the National Airspace S ys tem (NAS), and for an exemption from the6

requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, MLT Video Productions, LLC operation of
DJ I Inspire 1 UAS meets the conditions of FMRA Section 333 and therefore, will no t require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. According ly , MLT Video Pro d uctions, LLC requests relief from Sections 91.405(a), 91 .407(a)(1), 91

. 4 0 9 ( a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth req u ir ements for main tenance that onl y apply to aircraft with an airworthiness certificate. MLT Video Productions, LLC su bmits that the requested relief is proper sin ce an equivalent level of saf et y will be ensured. MLT Video Productions, LLC will u se experienced personnel or technicians to perform mainten an ce, alteratio n s, or preventive maintenance on the UAS using the met hods, techni ques, and practices prescribed in the operating documents (i.e., M o nthly Maintenan ce Lo g, and DJI I nsp ire 1 Instru ction Manual). Fu rthermore, MLT Video Productions, LLC will document and maintain all maintenance records for the DJI I nspire 1 UAS. Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in comman d , is requested b y MLT Video Productions, LLC to the extent nec essary to allow a Pilot in Command (PI C) holding a private pilot or higher level certificate, as well as an airman medical certificate, and who has demonstrated, by meeting minimum flight- h o u r and currency requirements, that the PI C is ab le to safely o perate the DJI I nspire 1 UAS in a manner consistent with this7

exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. MLT Video Productions, LLC seeks relief from Section 91.7(a), entitled Civil

a ircraft airworthiness , beca u se the DJ I I n sp ir e 1 UAS do not require an air worthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, MLT Video Productions, LLC submits that he will ensure that the DJ I Inspir e 1 UAS are in an airworthy condition, prior to every fligh t, b y determining that the UAS ar e in compliance with th e oper atin g d o cuments (i.e., Monthly Maintenance L o g, an d DJI I nsp ire 1 Instruction Manual), and that the aircraft are in a co ndition for saf e flight.

MLT Video Productions, LLC also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , as the DJ I Inspire 1 UAs wi ll n o t have a
t y p ical barometric altimeter onboard. However, altitude informatio n of the DJI I nsp ire 1 UAs will be provided to th e PI C v ia Global Positionin g Sy stem (GPS) equipment and

r adio communications telemetry d ata link, wh ich down links from the UA to the GCS for active monitoring of the flig ht path. This altitude information, comb ined with MLT Vid eo Productions, LLC operation of the DJ I I nspire 1 UAS within visual line of sight, at o r below 500 feet AGL, wil l ensure a level of safety equivalent to Section 91.12 1.

Additionally , MLT Video Productions, LLC seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requiremen ts for flight in VFR conditions

. MLT Video Productions, LLC submits tha t safet y will n o t be a ffected by

o peration of the DJI I nsp ir e 1 UAs during day light hours in visual meteorological conditions (VMC) under visual flight8

rules (VFR), with enough battery power to fly

for a total duration of approximately 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fl y after that for at least 4.5 minutes. In accordance with 14 C.F.R. § 11 .81, MLT Video Productions, LLC provides the following information in support of its petition for exemption: **A. Name A**  **nd Address Of The Petitioner.** The name and address of the Petitioner and point of contact is: MLT Video Productions, LLC Mike Pruett, CEO 411 North Broadway R ochester, MN 55906 Office: 507-281-3490 Cell: 507-261-1267 7 **B .**  **T he**  **Spec ific Sections Of 14 C.F.R.**  **From Which**  MLT Video Productions, LLC **Seeks Ex**  **emption. 1.**  MLT Video Productions, LLC **Seeks Exemption From The Requirements Of**  **Section 61.113(a) And (b).**  Section 61.113, entitled Private pilot privileges and limitations: Pilot in command , subsections (a) and (b) prescribe the following, in relevant part: (a) No person who holds a private pilot certificate may act as a pilot in command (PI C) of an aircraft that is carry ing passengers or propert y for compensation or hire; nor may

that person, for compensation or hire, act as PIC of an aircraft. (b) A privat e pilot may , for compensation or hire, act as PIC of an aircraft in connection with an y business or emplo ym ent if

— (1) The flight is only

incidental to that business or employ ment; and (2) The aircraft does not carry passengers or property

for compensati on or hire.

**2.** MLT Video Productions, LLC **Seeks Exemption From The Requirements Of Section**  **91.7(a).**9

Section 91.7, entitled Civil aircraft airworthiness , su bsection (a), states the following: ( a) No person may o p erate a civil aircraft unless it is in an airworthy co ndition.

**3.** MLT Video Productions, LLC **Seeks Exemption From The Requirements Of Section** 9 1 . 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 o r 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

-- (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 parag raph (a)(1)(i ) of this section, the current reported altimeter setting of an appro pr iate available station; or (iii) I n the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure.

**4.** MLT Video Productions, LLC **Seeks Exemption From The Requirements Of Section**  **9 1**  **. 1**  **5 1**  **(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.** MLT Video Productions, LLC **Seeks Exemption F rom The Requirement**  **Of Section**  **9 1.405(a).** 10 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, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.] **6.** MLT Video Productions, LLC **Seeks Exemption From The**  **Requirements Of Section**  **91.407(a)(1)** Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration , subsection (a)(1), states the following: (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration un less-- (1) It has been approved for return to service b y a person authorized under § 43.7 of this chapter[.]
**7.** MLT Video Productions, LLC **Seek s 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, wi thin 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 o f an airworthiness certificate in accordance with part 21 of this chapter.
**8.** MLT Video Productions, LLC **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:11 (1) Records of the maintenance, preventive maintena nce, and alteratio n and records of the 100-hour, annual, progressive, and other require d or approved inspections, as appropriate, for each aircraft (includ ing the airframe) and each engine, propeller, rotor, and appliance of a n aircraf t. Th e r eco r d s must include-- (i) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of completion of the work performed; and (iii) The signature, and certificate number of the person approving the aircraft for return to service. (2) Records containing the following information: (i) The total time in service of the airframe, each engine, each propeller, and each rotor. (ii) Th e 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 in spection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safety dire ctives including, for each, the method of compliance, the AD or safet y directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms prescribed b y § 43.9(d) of this chapter for each major alteration to the airframe and currentl y installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded b y other work or for 1 ye ar after the work is performed.12 ( 2 ) The records specified in paragraph (a)(2) of this section shal l be retain ed 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. **C. The Extent Of Relief** ML T Video Productions, LLC **Seeks And The Reason** MLT Video Productions, LLC **Seeks The Relief.**  **1. Ext**  **ent Of Relief** MLT Video Productions, LLC **Seeks And The Reason**  MLT Video Productions, LLC **Seeks Relief From Section 61.113(a) And (b).**  Relief from Section 61.113(a) a nd (b) entitled Private pilot privileges and limitations: Pilot in command , is requested to the extent necessary to allow a PI C holding a private pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met certain flight

- hour and currency requirements, to conduct the proposed UAS flight operations for compensation or hire. This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may , for compensation o r hire, act as PI C of an aircraft in connection with an y business or emplo ym ent if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or propert y for compensation or hire. As set forth more fully below, MLT Video Productions, LLC submits that an equivalent level of safet y will be maintained b ecause no PIC will be allowed to operate the
DJ I Inspire 1 UAS unless that PIC has met certain flight -hou r and currency requirements, d e monstrating that the PIC is able to safel y o p erate either the DJI In spir e 1 UAS in a

mann er consistent with the operations specifications as described i n this exemption, including ev asive and emergency maneuvers, as well as maintai ning appropriate distances from people, vessels, vehicles and structures.13 Further, MLT Video Productions, LLC submits that all flights of the DJI
I n spire 1 UAS, conducted by the PI C pursu ant to the grant of this Petition: (1) will b e inciden tal to MLT Video Productions, LLC business; and (2) will not carry p assengers or propert y for compensation or hire. **2 .**  **E x**  **t ent Of Relief**  MLT Video Productions, LLC **Seeks And The Reason**  MLT Video Productions, LLC **Seeks Relief From Section 91.7(a).**  Relief from Section 91.7(a) entitled Civi l aircraft airworth iness , is requested to the extent required to allow MLT Video Productions, LLC to determine that the DJI I nspire 1 UAS are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., the ML T Video Productions, LLC Aerial Operations Manual, Monthly Maintenance Log, and DJ I Inspire 1 Instruction Manual).

MLT Video Productions, LLC seeks the requested relief because the DJI I nspire 1 UA S do not require an airworthiness certificate in accordance with 14 C.F .R. Part 21, Subpart H. Therefore, MLT Video Productio ns, LLC will ensure that the DJ I Inspire 1 UAS are in airworthy condition based upon its compliance with t he operat ing documents (i.e ., Monthly Maintenance Log, and DJI I nspire 1 Instruction Manual) prior to every f light, and further, determine that the aircraft are in condition fo r safe flight, as stated in the conditions and limitations below

. **3. E**  **x t**  **ent Of Relief** MLT Video Productions, LLC **Seeks And The Reason**  MLT Video Productions, LLC **Seeks Relief From Section 91.121.**  Relief from Section 9 1.121, entitled Altimeter settings , may be required to allow flight operations of the DJI I nspire 1 UAS , which utilize a barometric pr essure sensor, GPS equipment, and a radio communications telemetry d ata link to downlink altitude info r mation from the UA to the PIC at the ground control station14

(GCS). Since the F AA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above gro und level (AGL), MLT Video Productions, LLC see ks the requested relief b ecause the DJ I In spire 1 UA’s altimeter
may b e set on the ground to zero feet AGL , rather than the local barometric pre ssure or f ield altitude, before each flight. Considering the limited altitude of the proposed operations, relief from 14 CFR 9 1

. 121 is sought to the extent necessary to comply with the applicable conditions and limitations stated below. As more full y set forth herein, an equivalent level of safet y will b e maintained since the DJI I nspire 1 UAs are equipped with a barometric pressure sensor and GPS equipment, which automaticall y ensures that a ground level pressure setting will be established prior to each flight, and p rovides the PI C with altitude information of the UA on the heads -u p d isplay o f the GCS. **4. E**  **x t**  **ent Of Relief** MLT Video Productions, LLC **Seeks And The Rea**  **s o**  **n** MLT Video Productions, LLC **Seeks Relief From Section 91.151(b).**  Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions , is requested to the extent required to allow flights of the battery powered DJI
I n spir e 1 UAs during day light hours in visual m eteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to th e first point of intended land ing and , assuming normal cruising speed, to fly after that fo r at least 4.5 mi nutes. MLT Video Productions, LLC seeks the requested relief because without an ex emption from Section 91.151(b), the fligh t time duration of the battery powered DJI I nspire 1 UAs w ill severel y constrain th e practicality of any aerial video o r still photo flight operati ons that MLT Video Productions, LLC proposes to conduct pursuant to this Petition.15 Significantl y, as set forth below, the technical specifications of the DJ I Inspire 1 UAS, the DJI I n spi re 1 operating documents, and MLT Video Productions, LLC
p r o p o sed operating limitations, ensure that MLT Video Productions, LLC will safel y

o p erate the battery powered DJ I In spire 1 UAs during day light hours in visual meteorological conditions (VMC), u n d er visual flight rules (VFR), with enough battery power to fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising sp eed, to fl y after that for at least 4.5 minutes.

**5. E**  **x t**  **ent Of Relief** MLT Video Productions, LLC **Seeks And The Reason** MLT Video Productions, LLC **Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) &**  **(a)(2), And 91.417(a) &**  **(b).** Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b)

o nly apply to aircraft with an airwort hiness certificate, MLT Video Productions, LLC requests relief from these Sections becaus e the DJ I I nspire 1 UAS do not require airworthiness certificates. As set forth more fu ll y b elow, the DJI I nspire 1 UAS meet the conditions of FMRA Section 333 for operation without an airworthiness cert ificate. Accordingly, MLT Video Produ ctions, LLC will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practi ces prescribed in the UAS operating documents (i.e., the MLT Video Productions, LLC Aerial Operations Manual, Monthly Maintenance Log, and DJ I
I n spire 1 I nstruction Manual). Furthermore, MLT Video Productions, LLC will document and maintain all mainte nance records for the DJI I n spire 1 UAS. **D. The Reasons Why Granting** MLT Video Productions, LLC **Request Would Be In The Public**  Interest; That Is, How It Would Benefit The Public As A Whole.16 Granting the present Petition will further the public interest b y allowing MLT Video Productions, LLC to safely , efficiently , and economically perform aerial video and photography o f construction sites, real estate, and landscape over certain areas of the United States. Additionally , use of the DJI I nspire 1 UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the eco n o m y. Notabl y, the benefits

o f MLT Video Pr o ductions, LLC pr o posed operation o f the DJI I n spire 1 UAS will be

r ealized without implicating any privacy issues. **1. The Public Will Benefit From Decreased Congestion Of The NAS.** The DJI Inspire 1 UAs are battery p o wered and serve as a safe, efficient, a nd economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery . By reducing the amount of manned aircraft needed to perfo rm aerial acquisitions, an exemption allowing the use of a DJ I Inspire 1 UAS would reduce the amount of manned aircra ft in the NAS, reduce noise and air pollution, as well as increase the safet y

o f life and propert y in the air and on the ground. Furthermore, b y reducing the number of manned aircraft operating in the NAS, congesti on around airports caused b y arriving and departing aircraft will be reduced. The
DJI I nspire 1 UAs do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography mis sions would result in fewer aircraft that must be handled b y air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations. **2. The Public Will Benefit From The Safety And Efficiency Of The**  **DJI Inspire 1**  **UAS.**17 C onducting aerial acquisitions with the DJ I I nsp ire 1 UAS, instead of manned aircraft, will gr eatl y benefit the p ub lic by drastically red u cing the levels of air and noise pollution generated during tradit ional aerial video and still photograph y fligh t operations. By using battery power and electr ic motors, the DJI I nspire 1 UAS p ro du ce no air
p o llution, and is the most viable environmentall y conscious alternative to the cabin c lass, six cy linder internal combustion engine aircraft that are t ypicall y utilized for aerial video and photography , while burning appr oximately 20-30 gallons per h o ur of leaded aviation fuel. The DJ I I nspire 1 UAs, wh ile reducing the car bon footprint of aerial acquisitions, also eliminates noise pollution, as the UAs are p r opelled by battery po wered electric motors, rather than an internal combustion engine.

B y using the DJ I Inspire 1 UAS to perform aeria l acquisitions, the substantial risk to life and property in the air and on the ground, which is u sually associated with traditional manned aircraft flight operations, will be substantially r educed or completel y eliminated. Aside from the lack of flight cr ew members lo cated onboard the aircraft, the
DJI I nspire 1 UAs (weighing approximately 2 pounds 11 ounces and 6 pounds 7.5 ounces respectively, at their maximum gross weights with lengths of 16 inches and 17.3 inches respectively, widths of 16 inches an d 17.7 inches respectively, and with n o f u el on board), h as less physical potential for collateral damage to life and propert y on the ground, and in the air, compared to the manned aircraft that ty pically conduct similar operations ( weighing approximately 6 ,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity o f 180 gallons).18 **3. Performing Aerial Video and Photography Operations With The**  **DJI Inspire 1**  UAS **Will Bene fit The Economy.**  In addition to being safe and efficient, the DJ I In spir e 1 UAS are also an economical alternative to using manned aircraft to conduct similar aer ial operations. As such, operatio n o f

the DJI I n spire 1 UAS will allow United States based companies, like MLT Video Productions, LLC , to remain co mp etitive and contribute to growth of the U.S.
economy . Specifically, with th e r ising cost of aviation fuel and the Environmental
Pr o tection Agency (“EPA”) reg ulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and al ternative techn ology in order to

r emain competitive. Operating the battery powered DJI I nsp ire 1 UAS is one such technology th at not only allows com panies greater op erational flexibility compared to manned aircraft, but pr o v ides such flexibility without the hig h op erational cost of a
tr ad itio n al manned aircraft.
B y operating the DJ I Inspire 1 UAS, companies such as MLT Video Productions, LLC , can remain competitive and profitable, and therefore, provide greater j ob stability
to emp loy ees a n d contractors, which will ultimately contribute to growth of the U.S.

econom y. Improved finan cial performance of U.S. companies, through co mmercial use of th e DJI I nspire 1 UAS, provides a stable workforce that increases consumer spending; improves local, state, and federal tax re venues; and allows companies to invest in

res earch and development in order to remain competitive both in the United States and abroad. **4. There Are No Privacy Issues.** Similar to the manned aerial acquisition f light operations that have been conducted f or decades, MLT Video Productio ns, LLC proposed operatio n o f the DJI I n spir e 119

Inspire 1 UAS will not implicate any privacy issues. Specifically, the DJI Inspire 1 UAS will be operated only in compliance with operating documents (i.e., MLT Video Productions, LLC Aerial Operations Manual, Monthly Mainte nance Log, and DJI Inspire 1 Instruction Manual) which requir es property owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Re gulations, including the minimum altitude requirements of 14 C.F.R. § 91.119. **E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety,** Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which MLT Video Productions, LLC Seeks Exemption.

**1. Reasons Why The**  **DJI Inspire 1 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 associate d with the unmanned aircraft and its operation, MLT Video Productions, LLC operation of the DJI I nspire 1 UAS meet the conditions of FMRA Section 333, an d will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart
H. Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national se curit y. Specificall y, FMRA Section 333 states the following, in part: (a ) In General.

-- Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall deter mine 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.20 (b ) Assessment of Unmanned A ircraft Systems.

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

-- (1 ) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security; and (2 ) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1). (c) Requirements for Safe Operation.

-- If the Secretary determines under this sect ion 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, MLT Video Productions, LLC submits that the and DJI I n sp ir e 1 UAS can operate safely in the NAS pursuant to FMRA Section 333, as d emo n str ated by: (a) the characteristics of the DJI Inspire 1 UAS; ( b ) th e p ilot certification requirement; and ( c) the specific operating limitations.

**a. T**  **he Specifications Of The**  **DJI Inspire 1 UAS**  **Demonstrate Its Safe Characteristics.**  The DJ I Inspire 1 UAS do not create a hazard to users of the NAS or the public, or otherwise pose a threat to national securit y considering its size, weight, speed, and operational capability

.21 **i. The**  DJI Inspire 1 UAS **Autonomous Flight And Navigation Modes**  **Enable The UAS To Remain Within A Defined Operational Area.** 
The DJI Inspire 1 UAS may be operated in manual and fully autonomous flight modes. A complete description of the flight and navigational modes of the DJI Inspire 1 UAS is provided pages 12-16 and 45-50 of the DJI Inspire 1 User Manuals, attached hereto: as Exhibit B

.

**ii. The**  DJI Inspire 1 UAS **Are Designed For Automatic Return To**  **Home Point Or Hover In The Event Of**  **Loss Of The Control Link**  **Or Navigation.** When the Control Link is lost, the DJI Inspire 1 UAs will rem ain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Inspire 1 UAs do not reacquire control link data f rom 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 descend to the takeoff positio n and shutdown. A complete description of th e Failsafe Functions of the DJI Inspire are on pages 13 through 15 of

the DJI Inspire 1 User Manuals, attached hereto: as Exhibit B.

**i** ii **. T**  **he DJI Insp**  **ire 1 GCS And Its**  Operation.
A complete description of the operation and specifications of the DJ I Inspire 1 GCS and flight control software is provided at p ages 40 through 47 of the DJ I I n spir e 1 User Manual are attached hereto as Exhibits B22 **b. Flight Operations Of**  DJI Inspire 1 UAS **Are Limited To The Line Of Sight Of A Certificated Pilot in Command**  **W ith**  **A Safety Observer.**

MLT Video Produ ctions, LLC will only utilize certificated pilots who possess a current and valid airman med ical certificate to act as a pilot in command (PI C) of th e DJ I Inspire 1 UA S

. Additionally , a safet y observer will assist all pilots dur ing flight time.

**c. Flights Of**  DJI Inspire 1 UAS **Will Be Conducted Pursuant To** 

**Specific Operating Limitations.** In seeking thi s exemption, MLT Video Productions, LLC p roposes to commercially o p erate DJ I Inspire 1 UA S for the sp ecial purpose of conducting aerial vi d eo and photograph y over certain areas of United States, pursuant to the following
sp ecific operating l imitations: 1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documen ts, rotorcraft UAS weighing less than 55 pounds maximum gross weight: DJ I Inspire 1 Unman ned Aircraft S ys tems. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant. 2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photograph y. 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 ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved b y 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 PI C at all times. This requires the PIC to be able to use human vision unaided by an y device ot her than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate.23 6. The use of first person view (FPV) b y the PI C or safet y observer (SO) is not permitted. 7. All operations must utilize a safet y observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC alway s maintains VL OS capability

. The SO and PI C must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PI C must ensure that the SO can perform the functions prescribed in the operating docume nts. 8. The SO must not perform any other duties bey ond assisting the PI C 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 documen ts and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy

exists between the conditions and limitations contained in the grant of exemption and the procedures outlined in t he operating documents, the conditions and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise it s 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 am endment 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 I ntegration Of fice (AFS

- 80) may

be contacted if questions arise regarding updates or revisions to the operating documents. 10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properl y documented in the aircraft records. 11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical com ponent, must undergo a functional test flight. The PI C 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 e quipment, not already covered in the relevant sections of the operating documents.24 13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. 14. The operator mus t carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature of the authorized person returning the UAS to service. 15. Each UAS operated under this exemption must comply with all manuf acturer 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 PI C must possess at least a private pilot certificate and at least a current third

- class med ical certificate. 18. The operator may

not permit any

PIC to operate unless the PI C meets the operator’s qualification criteria and demonstrates the ability to safel y operate the UAS in a manner consistent with how the UAS will be operated under the exem ption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator’s PICs are permitted under the terms of the exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency , and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PI C must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119. 19. UAS operations may

not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized. 20. The UA may

not operate within 5 nautical miles of an airport reference point as denoted on a current FAA-published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request.25 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 PI C.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 PI C must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating document s. 24. The PI C is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 25% battery power remaining. 25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting an y operations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not m ore than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requirem ents. 26. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (N - Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable. 27. Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency require ments. 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 an y time the UAS is operating. These documents must be made available to the Administrator or an y law enforcement official upon request. 29. The UA must remain clear and yi eld the right of way to all manned aviation operations and activities at all times. 30. The UAS may

not be operated b y 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 PI C, SO, operator trainees or essential persons), vessels, vehicles, and structures unless:26 a. Barriers or structures are present that suf ficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protectio n and are within 500 feet of the UA, flight operations must cease immediately

and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PI C h as made a safet y 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 PI C, 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 wil l be obtained for each flight to be conducted. 33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Off ice (AFS

- 80) within 24 hours. Accidents must be reported to the National Transportation Safet y Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

. **2. Reasons Why An Exemption From The Requiremen ts Of Section 61.113(a)**  **And (b) Would Not Adversely Affect Safety.** MLT Video Productions, LLC submits that the equivalent level of safet y established by Section 61.113(a) and (b) will b e maintained because no PIC will be allowed to operate the DJI Inspire 1 UAS unless that PI C has demonstrated, by meeting minimum flight-ho u r an d currency r equirements, that the PI C is able to saf ely

o p erate the DJ I I nspire 1 UAS in a man n er consistent with the exemption, includin g evasive and emergency maneuvers and maintaining appropriate distances from p eop le,

v essels, vehicles an d structures. Considering MLT Video Productions, LLC proposed area of operations, and the operating l imit ations set forth -above; the parallel nature of private pilot aeronautical knowledge27

requirements to those of commercial pilot requirements (Se e Exemption No. 11062); and the airmanship skills necessary to safel y operate the DJ I I n s p ire 1 UAS, MLT Video
Pr o d u ctions, LLC sub mits that the additional manned airmanship experience of a

co mmerciall y certificated pilot would not co r relate to the airmanship skills necessary for MLT Video Productions, LLC specific proposed flight operations. The FAA has previousl y 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, 1 1153, 11156, 11158, 11159, 11160, 11161). MLT Video Productions, LLC will not allow an y P IC to o p er ate the DJI I nspire 1 UAS unless that PI C has demonstrated, by meeting minimum flight-ho u r

r equirements or the DJI Ins pire 1 UAS training and curren cy requirements, that the PIC is ab le to safel y op erate the DJ I Inspire 1 UAS in a manner consistent with this exemption, including evasive and em ergency maneuvers and maintaining appropriate distances f

rom people, vessels, vehicles an d 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 PI C must accomplish 3 takeoffs and landings in the preceding 90 day s (for currency purposes).28 As in Exemption Nos. 11062, 11138, and 11153, prior documented flight
expe rience that was obtained in compliance with applicable regulations will ensure an equivalent level of safet y during MLT Video Production s, LLC proposed o perations. The Ad ministrator has held that prior documented flight experience that was obtained in compliance wit h 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 lo gged, 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 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 m ake 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 PI C 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 safely conduct the petitioner’s proposed operations. The FAA als o finds that prior documented flight experience that was obtained 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 accompl ish the required flight time. During training, proficiency , and experience

- building flights the PI C is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15. Accordingl y, MLT Video Productions, LLC will ensure safe operatio ns by n o t allowing any PI C to o p erate the DJI Inspire 1 UAS unless that PIC has d emonstrated, by meeting minimum flight-hour and curr en cy requiremen ts, that th e PIC is able to safely operate the DJI Inspire 1 UAS in a manner con sistent with th e exemption, including evasive and emergency maneuv ers and maintaining app ropriate distances from people, vessels, vehicles and structures.29 **3. Reasons Why An Exemption From The Requirements Of Section 91.7(a)**  **Would Not Adversely Affect Safety.** The eq u iv alen t level of safet y estab lished b y Section 91. 7(a) will be maintained b ecause prior to every flight, MLT Video Productions, LLC will ensure that the DJ I Inspire 1 UAS is in an airwor th y condition based upon the UAS’ s compliance with its operating documents and as stated in the conditions and limitations herein. A dd itionally , th e FAA has previously g r an ted r elief from Section 91.7(a) specific to UAS, in circumstances similar, in all mater ial respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). **4. Reasons Why An Exemption From The Requireme nts Of Section 91.121**  **Would Not Adversely Affect Safety.** The equiv alent level of safet y established b y Sectio n 9 1

. 1 2 1 will be maintained because the altitude information of the DJ I Inspire 1 UAs will be pro vid ed to the PI C via GPS equipment and a radio communicatio n s telemetry d ata link, which do wnlinks from th e UA to the GCS for active monitoring of the flight path and altitude. This altitu d e information, combined with MLT Video Produ ctions, LLC oper at ion of the DJI I nspire 1 UAs within visual line of sight, at or below 500 feet AG L, will ensure a level of safet y equivalent to Section 91.121. The altitude information will b e generated b y GPS
eq uipment installed o nboard the airc raft. Prior to each flight, a zero altitude initiation
p oint is automatically established by the UAS at ground level. The FAA has previously

granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).30 **5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Ad**  **versely 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
I n spire 1 UAS; (2) th e limitation s on the pr o p o sed flight operation s; and (3) the location of the proposed flig ht operations. Accordingl y, MLT Video Productions, LLC will ensu re th at it will saf

ely operate th e b attery p owered DJI I nsp ire 1 UAs du rin g d aylight hours in VFR co nditions, with en ough b attery p ower to fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming

n o r mal cruising speed, to fly after that for at least 4.5 minutes.
Her e, as in Exemption No. 11109, the technical specific ations of the DJ I Inspir e 1 UAS; the limitations on the proposed flight operations; and the lo cation of the proposed

o p erations, will ensure an equivalent level of safety established b y 14 C.F.R. Section 91.151(b). Furthermore, sa f ety will be ensured as the DJ I I n spire 1 UAS provide audible and visual warnings to the PI C at the GCS when the UAs experiences low battery voltage, the first warning occurring at approximately 3 3% remaining battery power, and again at approximately 1 0 % r emaining battery p ower. At the critically low battery level, the DJ I Inspire 1 UAS will descend and land automatically

.

Significantl y, previous exemptions granted b y the FAA concerning Section 91.151

es tablish that safet y is not adversel y 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
E xemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief31

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, 1 1063, 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, MLT Video Productions, LLC submits that the equivalent level of s afet y with regard to th e r egulatory maintenance and alteration

r equirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met b ecause MLT Video Productions, LLC will use trained technicians to perform mainten ance, alterations, or p reventive mainten ance on the UAS

u sin g th e methods, techniques, and practices prescr ibed in the o p erating docu men ts (i.e. , MLT Video Productions, LLC Aerial Op erations Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, MLT Video Productions, LLC will document and maintain all maintenance record s f o r the DJI Inspire 1 UAS

. Sin ce the DJI Inspire 1 UAS will b e inspecte d as p rescrib ed b y th e operating d o cu ments, MLT Video Productions, LLC will maintain the equivalent level of safet y established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)( 2) . A copy of th e DJI
I nspire 1 User Manuals are attached hereto as Exhibit B ; a cop y of th e DJI I nspire 1 UAS Maintenance LOG is attached hereto as Exhibit C

.

Likewise, the exemption sought will not adversel y affect saf ety because MLT Video Productions, LLC will use trained technicians to perform maintenance, alterations or preventive32

maintenance on the UAS using the methods, techniques, and practices prescribed by the operating documents. Furthermore, the exem ption 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 I nspire 1 UAS will be performed b y trained technicians. Maintenance will be d o c umented and maintained utilizing the monthly 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 safet y is not adversel y affected whe n the technical characteristics and operating limitations of the UAS are considered. In consideration of MLT Video Productions, LLC proposed operating limitations, the operating d ocuments, and th e technical aspects of the DJI Inspire 1 UAS , MLT Video
Pr oductions, LLC submits that safety will not be adversely affected by g ranting 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 prev io usl y granted relief specific to UAS in circumstanc es similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). **7. The FAA May Prescribe Any Other Conditions For Safe Operation.**  In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions , MLT Video Productions, LLC requests that the FAA prescribe special conditions for the intended op eration of the DJI Inspire 1 UAS , wh ich contain such safet y standards that the33

Administrator finds necessary to establish a level of safet y equivalent to that established b y 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.11 3(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAs for the limited purpose of conducting aerial video and photograph y over certain area s of the United States for compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the a uthority for such UAS to operate without airworthiness certification in accordance with any requirements that must be established for the safe operation of the UAS in the NAS. Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F .R. § 21.16, for operation of the DJI Inspire 1 UAS , since th e airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safet y standards, due to the novel or unusual design features of the aircraft. S ection 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 safet y standards for an aircraft, aircraft engine, or propeller because of a nov el or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety

standa rds for the aircraft, aircraft engine or propeller as the FAA finds necessary

to establish a level of safety equivalent to that established in the regulations. See 14 C.F.R. § 21.16. Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA
may prescribe special conditions for L eading Edge’s intended operation of the DJ I
I nspire 1 UAS, which contain such safet y standards that the34

Administr ator finds necessary to establish a level of safet y equivalent to that established b y 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 S**  **ummary That Can Be Published In The Federal Register,**  **stating: The Rules From**  **W hich**  MLT Video Product ions, LLC **Seeks Exemption:**
MLT Video Productions, LLC seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&( b), 91.7(a), 91.121, 91.151 ( b ), 91.405(a), 91.407(a) (1 ) , 91.409(a)(1) & (

a )(2), and 91.41 7 (

a) & ( b ). **A Brief Description Of The Nature Of The Exemption** MLT Video Product ions, LLC **Seeks:** Th is exemption will permit MLT Video Productions, LLC to commercia lly operate an Unmanned Aircraft System (UAS) for the p u rpose of conducting aerial video and photography over certain areas of the United States. **G. Any Additional Information, Views, Or Arguments Available To Support**  MLT Video Productions, LLC **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 th e NAS. As such, MLT Video Productions, LLC request for exemption
may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national securit y; and further, provides the authority for such UAS to op erate without airworthiness certification. As discussed in detail above, MLT Video Productions, LLC will operate the
DJ I I n spire 1 UAS safel y in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a thre at to national securit y.35 **CONCLUSION**

**W HEREFORE**  , in accordance with the Fed eral Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, MLT Video Productions, LLC respectfully re q u ests that the Administrator g rant this Petition for an exemption f r om the requir ements of 1 4 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 MLT Video Productions, LLC to operate the DJI I nspire 1 UAS commercially fo r the purpose of conducting aerial

v id eo and photography ove r certain areas o f the United States.
Date d : A p r il 2 , 2015

_________________________ Respectfully submitted: Mike Pruett CEO MLT Video Productions, LLC 411 North Broadway Rochester, MN 55906 As set forth herein, MLT Video Productions, LLC 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 Inspire 1 UAS commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing MLT Video Productions, LLC to safely, efficiently, and economically operate the DJI Inspire 1 UAS commercially within the NAS.36 Mike Pruett CEO MLT Video Produ ctions, LLC 4 11 N orth Broadway Rochester, MN 55906 Office: 507-281-3490 Cell: 507-261-1267 7 Exhibit : A

– DJ I Inspire 1 Specifications Data Sheet B

– DJ I I n spire 1 Manufacturer’s User Manual C

– Monthly Maintenance L og39 E XHIBIT: A A **DJI INSPIRE 1 TECHNICAL SPECIFICATIONS**  MLT Video Produ ctions, LLC only utilizes safe and reliable UAS. DJI is an industry leader in small UAS production. DJ I UAS are loaded w ith ground b r eaking softwar e enabling the user to set parameters which will not allow f light into controlled airspace. Parameters can also be s et to limit flig h t to no higher than a predeter mined and set altitude as well as limit flig h t to a p redetermined an d set distance. In addition, DJ I software p rovides real -time altitude and l o cation information to the PI C via the linked monitor (smart phone/t ablet 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: 1500 /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 0F to 1040F (

- 10 0C to 400C) 2.2.1.15 Dimensions

– 17 1⁄4” x 17 3⁄4” x 12”
2.2.2 Gimbal 2.2.2.1 Model

– ZENMUSE X3 2.2. 2.2 Output Power (with camera) – Static: 9W; In Motion: 11W 2.2.2.3 Operating Current – Static: 750mA; In Motion: 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 +300; Pan: ±3200 2.2. 2.7 Mechanical Range – Pitch:

- 125 0 to 450; Pan: ±3300 2.2.2.8 Max Controllable Speed

– Pitch: 1200/s; Pan: 1800/s
2.2.3 Camera 2.2.3.1 Name

– X3 2.2.3.2 Model

– FC350 2.2.3.3 Total Pixels – 12.76M40 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: 1920x1080p24/25/30/48/50/60; HD: 1280x720p24/25/30/48/50/60 2.2.3.10 Operat ing Temperature Range

- 32 0F

- 104 0F (00C

- 40 0C)
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)

– 2000m 2.2.4.4 Output Power

– 9W 2.2.4.5 Operating Temperatur e Range

- 14 0F to 1040F (

- 10 0C to 400C) 2.2.4.6 Battery

– 600mAh LiPo 2S42 APPENDIX

– B DJI I nspire 1 Manufacturer’s User Manual43 EXHIBIT

– C Monthly Maintenance Log

month:_________year:________ **UAS**

**__________** Date Issue Discovered Date Issue

Addressed Software Updates

Airframe
Engines
Propellers

Camera Gimbal
Landing Gear

Vibration Dampening

Other: **MONTHLY MAINTENANCE**  **LOG**

Issue Description Maintenance Conducted Maintenance Performed By: Print Sign