MEDIAPOST, LLC

635 Petro Point Drive

Lake Charles, LA 70607

IN THE MATTER OF THE PETITION FOR EXEMPTIONOF:

MEDIAPOST, LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERALREGULATIONS

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 3 AND DJI INSPIRE 1 UNMANNED AIRCRAFT

SYSTEMS PURSUANT TO SECTION 333 OF

THE FAAMODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW112-95)

Submitted on July 24, 2015

MEDIAPOST, LLC 

Christopher Gerard Lognion, President

635 Petro Point Drive, Suite B

Lake Charles, LA 70607 

337-474-7678 Studio

337-540-7221 Mobile

chris@gomediapost.com
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TABLE OF CONTENTS

Page

GLOSSARY OFABBREVIATIONS.........................................................................................3

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

INTRODUCTION AND INTERESTS OFPETITIONER...................................................4

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

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

NAME AND ADDRESS OFPETITIONER. .......................................................... .8

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH MEDIAPOST, LLC 

SEEKS EXEMPTION ..............................................................................................8

THE EXTENT OF RELIEFMEDIAPOST, LLC SEEKS AND THE REASON 

MEDIAPOST, LLC SEEKS THERELIEF...................................................... 12

THE REASONS WHY GRANTING MEDIAPOST, LLC’S REQUEST

WOULD BE IN THE PUBLIC INTEREST ........................................................ 15

THE REASONS WHY GRANTING THE EXEMPTION WOULDNOT

ADVERSELY AFFECT SAFETY................................................................................. 19

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERALREGISTER. .... 34

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS 

AVAILABLE TO SUPPORT MEDIAPOST, LLC’S REQUEST........................34

CONCLUSION......................................................................................................................35

APPENDICES.........................................................................................36
3

GLOSSARYOFABBREVIATIONS

AGL Above Ground Level

AOI Area of Interrst

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate Of Authorization

FAA Federal AviationAdministration

FAR Federal AviationRegulation

GCS Ground Control Station

GPS Global Positioning System

HH Horizon Hobby Blade 350QX2AP

LOL Loss Of Link

NAS National Airspace System

NOTAM Notice ToAirman

PIC Pilot In Command

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

Section333 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 Take-Off and Landing
4

SUMMARY

MEDIAPOST, 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 System pursuant to Section 

333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will

permit to operate an Unmanned Aircraft System (UAS) for the commercial purpose

of conducting aerial video and photography of construction sites, real estate andlandscape

over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

A cinematographer and multimedia editor with more than 24 years of experience, Chris 

Lognion established MEDIAPOST, LLC in 1997. In 2000, he developed a 9,000 sq. ft. studio 

home for his film, video, photography and multimedia company, dedicating his efforts to 

producing high-quality, cost-effective film and video productions, as well as interactive 

training applications, promotional multimedia and duplication services.

The objective of MEDIAPOST, LLC and the Unmanned Aircraft System (DJI Phantom 3) 

and (DJI INSPIRE 1) aerial operations is to provide a more affordable, high-quality 

production system for a variety of governmental, commercial, public, and residential uses, 

specifically targeting

• Construction sites before and after

• Motion Picture / Television Commercials / Training Videos

• Real-estate marketing

• Economic development

• Private and governmental training 
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BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 3 UAS and DJI Inspire 1 UAS

MEDIAPOST, LLC seeks an exemption to operate DJI Phantom 3 and DJI Inspire 1 systems

for compensation or hire within the NAS. The DJI Phantom 3 and Inspire 1 are vertical 

takeoff and landing (VTOL) Unmanned Aircrafts (UA) with a Ground Control Station (GCS) 

utilizing electronic tablet or smart phone systems. The DJI Phantom 3 and Inspire 1 are 

equipped with four main rotors; driven by Lithium Polymer battery powered electric motors. 

The DJI Phantom 3 and Inspire 1 that will be operated by Chris Lognion of MEDIAPOST, 

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

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

Identification and Registration Marking.

BASIS FOR

PETITION

Petitioner, MEDIAPOST, 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), Section 333, Special Rules for Certain 

Unmanned AircraftSystems, hereby petitions the Administrator to 

commercially operate the DJI Phantom 3 and DJI Inspire 1 UAS's in the

National Airspace System (NAS), and for an exemption from the requirements 

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

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

In consideration of the speed, weight, size, and limited operating area associated 
6

with the unmanned aircraft and its operation, MEDIAPOST, LLC’S operation of DJI 

Phantom 3 and DJI Inspire 1 UAS's meets the conditions of FMRA Section 333 and 

therefore, will not require an airworthiness certificate in accordance with 14C.F.R. Part 

21, Subpart H.

Accordingly, MEDIAPOST, LLC requests relief from Sections91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth 

requirements for maintenance that only apply to aircraft with an airworthiness certificate.

MEDIAPOST, LLC submits that the requested relief is proper since an 

equivalent level of safety will be ensured. MEDIAPOST, LLC will use experienced 

personnel or technicians to perform maintenance, alterations, or preventivemaintenance

on the UAS's using the methods, techniques, and practices prescribed in theoperating

documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 and DJI Inspire 1 UAS's

Instruction Manuals). Furthermore, MEDIAPOST, LLC will document and maintain

all maintenance records for the DJI Phantom 3 and DJI Inspire 1 UAS's.

Relief from certain requirements of Section 61.113(a) and (b), entitled Privatepilot

privileges and limitations: Pilot in command, is requested by MEDIAPOST, LLC to the

extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higherlevel

certificate, as well as an airman medical certificate, and who has demonstrated, by meeting 

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

Phantom 3 and DJI Inspire 1 UAS's in a manner consistent with this

exemption, including evasive and emergency maneuvers and maintainingappropriate

distances from people, vessels, vehicles and structures.

MEDIAPOST, LLC seeks relief from Section 91.7(a), entitled Civil aircraft

airworthiness, because the DJI Phantom 3 and DJI Inspire 1 UAS's do not require an 
7

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

MEDIAPOST, LLC submits that he will ensure that the DJI Phantom 3 and DJI Inspire 1

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

in compliance with the operating documents (i.e., Monthly MaintenanceLog,

and DJI Phantom 3 and DJI Inspire 1 UAS's Instruction Manuals), and that the aircraft are

in a condition for safe flight.

MEDIAPOST, LLC also seeks an exemption from the requirements of Section91.121, 

entitled Altimeter Settings, as the DJI Phantom 3 and DJI Inspire 1 UAS's will not have

a typical barometric altimeter onboard. However, altitude information of the

DJI Phantom 3 and DJI Inspire 1 UAS's will be provided to the PIC via Global

Positioning System (GPS) equipment and radio communications telemetry data link, 

which downlinks from the UAS to the GCS for active monitoring of the flight path.This 

altitude information, combined with MEDIAPOST, LLC’S operation of theDJI 

Phantom 3 and DJI Inspire 1 UAS's within visual line of sight, at or below 400 feet

AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, MEDIAPOST, LLC seeks an exemption from the requirements 

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

MEDIAPOST LLC submits that safety will not be affected by operation of the DJI 

Phantom 3 and DJI Inspire 1 UAS's during daylight hours in visual meteorological

conditions (VMC) under visual flight rules (VFR), with enough battery power to fly 

for a total duration of approximately 10 minutes for the intended photo shoot and, 

assuming normal cruising speed, to fly after that for at least 2.5 minutes for recovery 

andlanding.
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In accordance with 14 C.F.R. § 11.81, MEDIAPOST, LLC provides the following 

information in support of its petition for exemption:

A. Name And Address Of ThePetitioner

The name and address of the Petitioner and point of contactis:

MEDIAPOST, LLC 

Christopher Gerard Lognion, President

635 Petro Point Drive, Suite B

Lake Charles, A 70607 

337-474-7678 Studio

337-540-7221 Mobile

chris@gomediapost.com

B. The Specific Sections Of 14 C.F.R. From Which MEDIAPOST, LLC seeks 

Exemption

1. MEDIAPOST, LLC Seeks Exemption From The RequirementsOf 

Section 61.113(a) And (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot incommand, 

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

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

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

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

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

connection with any business or employment if—

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

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

2.MEDIAPOST, LLC Seeks Exemption From The RequirementsOf 

Section 91.7(a).
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Section 91.7, entitled Civil aircraft airworthiness, subsection (a), statesthe

following:

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

3. MEDIAPOST, LLC 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 orflight

level of that aircraft, as the case may be, by reference to an altimeter that is set, 

when operating--

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

(i) The current reported altimeter setting of a station along the route

and within 100 nautical miles of the aircraft;

(ii) 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) the case of an aircraft not equipped with a radio, the elevation ofthe

departure airport or an appropriate altimeter setting available before

departure.

4. MEDIAPOST, LLC Seeks Exemption From The RequirementsOf 

Section91.151(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. MEDIAPOST, LLC Seeks Exemption From The RequirementOf 

Section91.405(a).
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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 andshall

between required inspections, except as provided in paragraph (c) of this 

section, have discrepancies repaired as prescribed in part 43 of this chapter[.]

6. MEDIAPOST, LLC Seeks Exemption From The RequirementsOf 

Section 91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventivemaintenance, 

rebuilding, or alteration,subsection (a)(1), states the following:

(a) No person may operate any aircraft that has undergone maintenance,preventive

maintenance, rebuilding, or alteration unless--

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

43.7 of this chapter.

7. MEDIAPOST, LLC Seeks Exemption From The RequirementsOf 

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 ofthis 

chapter or

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

with part 21 of this chapter.

8. MEDIAPOST, LLC Seeks Exemption From The RequirementsOf 

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

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

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

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

include--

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

the work performed; and

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

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

aircraft for return to service.

(2) Records containing the following information:

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

each rotor.

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

propeller, rotor, and appliance.

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

are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time sincethe

last inspection required by the inspection program under which the

aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety 

directives including, for each, the method of compliance, the ADor 

Safety directive number and revision date. If the AD or safetydirective

involves recurring action, the time and date when the next action is 

required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each 

major alteration to the airframe and currently installed engines,rotors, 

propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods 

prescribed:

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

until the work is repeated or superseded by other work or for 1 year afterthe

work is performed.
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(2) The records specified in paragraph (a)(2) of this section shall be retained 

and transferred with the aircraft at the time the aircraft issold.

(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 aircraftis 

approved for return to service.

C. The Extent Of Relief MEDIAPOST, LLC Seeks And The Reason MEDIAPOST, 

LLC Seeks The Relief.

1. Extent Of Relief MEDIAPOST, LLC Seeks And The Reason

MEDIAPOST, LLC Seeks Relief From Section 61.113(a) And(b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and 

limitations: Pilot in command, is requested to the extent necessary to allow a PIC holdinga

private pilot or higher level certificate, as well as a current and valid airmanmedical

certificate, and who has met certain flight-hour and currency requirements, to conductthe

proposed UAS flight operations for compensation or hire.

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

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

connection with any business or employment if: (1) The flight is only incidental tothat

business or employment; and (2) The aircraft does not carry passengers or propertyfor 

compensation or hire.

As set forth more fully below, MEDIAPOST, LLC submits that an equivalent level 

of safety will be maintained because no PIC will be allowed to operate theDJI Phantom 3 

and DJI Inspire 1 UAS's unless that PIC has met certain flight-hour and And current 

requirements, demonstrating that the PIC is able to safely operate either the DJI Phantom 3 

and DJI Inspire 1 UAS's in a manner consistent with the operations specifications as 

described in this exemption, including evasive and emergencymaneuvers, as well as 

maintaining appropriate distances from people, vessels, vehicles andstructures.
13

Further, MEDIAPOST, LLC submits that all flights of the DJI Phantom 3 and DJI Inspire 1 

UAS's, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to 

MEDIAPOST, LLC’Sbusiness; and (2) will not carry passengers or property for compensation 

or hire.

2.Extent Of Relief MEDIAPOST, LLC Seeks And The Reason

MEDIAPOST, LLC Seeks Relief From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested tothe

extent required to allow MEDIAPOST, LLC to determine that the DJI Phantom 3 and DJI 

Inspire 1 UAS's are in airworthy condition prior to every flight by ensuring that the UAS is in 

compliance with the operating documents (i.e., the MonthlyMaintenance Log and DJI 

Phantom 3 and DJI Inspire 1 UAS's manuals.

MEDIAPOST, LLC seeks the requested relief because the DJI Phantom 3 and DJI 

Inspire 1 UAS's do not require an airworthiness certificate in accordance with 14

C.F.R. Part 21, Subpart H. Therefore, MEDIAPOST, LLC will ensure that the DJI Phantom 3 

and DJI Inspire 1 UAS's are in airworthy condition based upon its compliance with the 

operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 and DJI Inspire 1 

UAS's Instruction Manuals) prior to every flight, and further, determine that the aircraft are in 

condition for safe flight, as stated in the conditions and limitationsbelow.

3. Extent Of Relief MEDIAPOST, LLC Seeks And The Reason

MEDIAPOST, LLC Seeks Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow 

flight operations of the DJI Phantom 3 and DJI Inspire 1 UAS's, which utilize a barometric 

pressure sensor, GPS equipment, and a radio communications telemetrydata link to

downlink altitude information from the UA to the PIC at the ground control station
14

(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), MEDIAPOST, LLC 

seeks the requested relief because the DJI Phantom 3 and DJI Inspire 1 UAS's altimeter may

be set on the ground to zero feet AGL, rather than the local barometric pressure or field 

altitude, before each flight.

Considering the limited altitude of the proposed operations, relief from 14CFR

91.121 is sought to the extent necessary to comply with the applicable conditions and 

limitations stated below. As more fully set forth herein, an equivalent level of safety will

be maintained since the DJI Phantom 3 and DJI Inspire 1 UAS's are equipped with a 

barometric pressure sensor and GPS equipment, which automatically ensures that aground 

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 MEDIAPOST, LLC Seeks And The Reason

MEDIAPOST, 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 

Phantom 3 and DJI Inspire 1 UAS's during daylight hours in visual meteorological

conditions (VMC), under visual flight rules (VFR), for a total duration of 10 minutesto

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

at least 2.5 minutes. MEDIAPOST, LLC seeks the requested relief because without an 

exemption from Section 91.151(b), the flight time duration of the battery powered DJI 

Phantom 3 and DJI Inspire 1 UAS's will severely constrain the practicality of any aerial 

video or still photo flight operations that MEDIAPOST, LLC proposes toconduct pursuant 

to this Petition.
15

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

and DJI Inspire 1 UAS's operating documents and MEDIAPOST, LLC’S proposed operating 

limitations, ensure that MEDIAPOST, LLC will safely operate the battery powered DJI 

Phantom 3 and DJI Inspire 1 UAS's during daylight hours in visual meteorological 

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

total duration of 10 minutes to the first point of intended landing and, assuming normal 

cruising speed, to fly after that for atleast 2.5 minutes.

5.Extent Of Relief MEDIAPOST, LLC Seeks And The Reason

MEDIAPOST, 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) 

only apply to aircraft with an airworthiness certificate, MEDIAPOST, LLC requests

relief from these Sections because the DJI Phantom 3 and DJI Inspire 1 UAS's do not require

airworthiness certificates. As set forth more fully below, the DJI Phantom 3 and DJI Inspire 1 

UAS's meet the conditions of FMRA Section 333 for operation without an airworthiness

certificate. Accordingly, MEDIAPOST, LLC will use trained technicians to perform 

maintenance, alterations, or preventive maintenance on theUAS's using the methods, 

techniques, and practices prescribed in the UAS operating documents (i.e., the Aerial 

Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 and DJI Inspire 1 

UAS's). Furthermore, MEDIAPOST, LLC will document

and maintain all maintenance records for the DJI Phantom 3 and DJI Inspire 1 UAS's.

D.The Reasons Why Granting MEDIAPOST, LLC Request Would Be InThe

Interest; That Is, How It Would Benefit The Public As A Whole.
16

Granting the present Petition will further the public interest by allowing

MEDIAPOST, LLC to safely, efficiently, and economically perform aerial video and 

photography of construction sites, real estate, and landscape over certain areas of the

United States.

Additionally, use of the DJI Phantom 3 and DJI Inspire 1 UAS's will decrease 

congestion of the NAS, reduce pollution, and provide significant benefits tothe

the economy. Notably, the benefits of MEDIAPOST, LLC’S proposed operation ofthe

DJI Phantom 3 and DJI Inspire 1 UAS's will be realized without implicating any privacy

issues.

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

The DJI Phantom 3 and DJI Inspire 1 UAS's are battery powered and serve as a safe,

efficient, and economical alternative to the manned aircraft traditionally utilized

to obtain aerial imagery. By reducing the amount of manned aircraft needed to performaerial

acquisitions, an exemption allowing the use of the DJI Phantom 3 and DJI Inspire 1 UAS's 

would reduce the amount of manned aircraft in the NAS, reduce noise andair pollution, as 

well as increase the safety of life and property in the air and on theground.

Furthermore, by reducing the number of manned aircraft operating in the NAS, 

congestion around airports caused by arriving and departing aircraft will be reduced.The

DJI Phantom 3 and DJI Inspire 1 UAS's do not require an airport to takeoff or land. 

Likewise, a reduction of manned aircraft conducting aerial video and photography 

missions would result in fewer aircraft that must be handled by air traffic controlduring 

the ground, takeoff, departure, arrival, and landing phases of flightoperations.

2. The Public Will Benefit From The Safety And Efficiency Of The DJI 

Phantom 3 and DJI Inspire 1 UAS's.
17

Conducting aerial acquisitions with the DJI Phantom 3 and DJI Inspire 1 UAS's

instead of manned aircraft, will greatly benefit the public by drasticallyreducing

the levels of air and noise pollution generated during traditional aerial video and still

photography flight operations. By using battery power and electric motors, the DJI 

Phantom 3 and DJI Inspire 1 UAS's produce no air pollution, and is themost viable 

environmentally conscious alternative to the cabin class, six cylinderinternal combustion 

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

approximately 20-30 gallons per hour of leaded aviation fuel. The DJI Phantom 3 and DJI 

Inspire 1 UAS's, while reducing the carbon footprint of aerial acquisitions, also eliminates 

noise pollution, as the UA's are propelled by batterypowered electric motors, rather than 

an internal combustion engine.

By using the DJI Phantom 3 and DJI Inspire 1 UAS's to perform aerial acquisitions, 

the substantial risk to life and property in the air and on the ground, whichis usually 

associated with traditional manned aircraft flight operations, will besubstantially reduced

or completely eliminated. Aside from the lack of flight crew members located onboard the

aircraft, the DJI Phantom 3 and DJI Inspire 1 UAS's (weighing under 10 pounds 0 ounces

at their maximum gross weights (and with no fuel on board) has less physical potential for 

collateral damage to life and property on the ground, and in the air, compared tothe

manned aircraft that typically conduct similar operations (weighing approximately6,000 

pounds, and a fuel capacity of 180 gallons.
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3. Performing Aerial Video and Photography Operations With DJI 

Phantom 3 and DJI Inspire 1 UAS's Will Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 3 and DJI Inspire 1 UAS's are also 

an economical alternative to using manned aircraft to conduct similar aerial operations. As such,

operation of the DJI Phantom 3 and DJI Inspire 1 UAS's will allow United States based

companies, like MEDIAPOST, LLC’S to remain competitive

and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation 

fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded 

aviation fuels, U.S. owned and operated companies must adopt new andalternative

technology in order to remain competitive. Operating the battery powered DJI Phantom 3 

and DJI Inspire 1 UAS's is one such technology that not only allows companies greater 

operational flexibility compared to manned aircraft, but provides such flexibilitywithout

the high operational cost of a traditional manned aircraft.

By operating the DJI Phantom 3 and DJI Inspire 1 UAS's, companiessuch as 

MEDIAPOST, LLC’S can remain competitive and profitable and therefore, provide greater job

stability to employees and contractors, which will ultimately contribute to

growth of the U.S. economy. Improved financial performance of U.S. companies, through 

commercial use of the DJI Phantom 3 and DJI Inspire 1 UAS's, provides a stable workforce that 

increases consumer spending, improves local, state, and federaltax

revenues and allows companies to invest in research and development in order toremain 

competitive both in the United States and abroad.

4.There Are No Privacy Issues.

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

decades, MEDIAPOST, LLC’S proposed operation of the DJI Phantom 3 and DJI Inspire 1 

UAS's will not implicate any privacy issues. Specifically, the DJI Phantom 3 and DJI Inspire 1 
19

UAS's will be operated only in compliance with operating documents (i.e.Aerial Operations

Manual, Monthly Maintenance Log, and the DJI Phantom 3 and DJI Inspire 1 UAS's Instruction

Manual) which requires property owner involvement as well as local law enforcement

notification, and in accordance with the Federal Aviation

Regulations, including the minimum altitude requirements of 14 C.F. R. § 91.119.

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety,

Or How The Exemption Would Provide A Level Of Safety At Least Equal To That 

Provided By The Rule From Which MEDIAPOST, LLC SeeksExemption.

1. Reasons Why The DJI Phantom 3 and DJI Inspire 1 UAS's Meet The

Conditions Of The FAA Modernization and Reform Act of 2012(FMRA) 

Section 333.

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

with the unmanned aircraft and its operation, MEDIAPOST, LLC’S operation ofthe DJI 

Phantom 3 and DJI Inspire 1 UAS's meet the conditions of FMRA Section 333, and will 

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

Section 333 provides authority for a UAS to operate without airworthiness 

certification and sets forth requirements for considering whether a UAS will create a

hazard to users of the NAS or the public, or otherwise pose a threat to nationalsecurity.

Specifically, FMRA Section 333 states the following, in part:

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

later than 180 days after the date of enactment of this Act, the Secretaryof

Transportation shall determine if certain unmanned aircraft systems may

operate safely in the national airspace system before completion of theplan 

and rulemaking required by section 332 of this Act or the guidance required by

section 334 of this Act.
20

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

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, UnitedStates 

Code, is required for the operation of unmanned aircraft systems 

identified under paragraph (1).

(c) Requirements for Safe Operation.--If the Secretary determines underthis 

section that certain unmanned aircraft systems may operate safely in the

national airspace system, the Secretary shall establish requirements for the safe

operation of such aircraft systems in the national airspace system.

In seeking this exemption, MEDIAPOST, LLC submits that the DJI Phantom 3 and 

DJI Inspire 1 UAS's can operate safely in the NAS pursuant to FMRA Section333, as 

demonstrated by: (a) the characteristics of the DJI Phantom 3 and DJI Inspire 1 UAS's; (b) the

pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The DJI Phantom 3 and DJI Inspire 1 UAS's 

Demonstrate Its Safe Characteristics.

The DJI Phantom 3 and DJI Inspire 1 UAS's 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.

i. Technical Specifications Of The DJI Phantom 3 and DJI Inspire 1 

UAS's

The technical specifications of the DJI Phantom 3 and DJI Inspire 1 UAS's are set forth

by the DJI Phantom 3 and DJI Inspire 1 UAS's Specifications and Data Sheet, attached hereto

as Exhibit A and B.
21

ii. The DJI Phantom 3 and DJI Inspire 1 UAS's GPS Flight And

Navigation Modes Enable The UAS's To Remain Within A 

Defined Operational Area.

The DJI Phantom 3 and DJI Inspire 1 UAS's may be operated in both manual and 

fully autonomous flightmodes, i.e. Return To Home. 

iii. The DJI Phantom 3 and DJI Inspire 1 UAS's 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 3 and DJI Inspire 1 UA's will remain 

stationary in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 3 and DJI 

Inspire 1 UA’s due 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 descend to the takeoff position and shutdown.

A complete description of the Failsafe Functions of the DJI Phantom 3 and DJI Inspire 

1 UAS's are set forth in the User Manuals, attached hereto as Exhibit C and D.

iv. The DJI Phantom 3 and DJI Inspire 1 UAS's GCS And Its 

Operation.

A complete description of the operation and specifications of the DJI Phantom 

3 and DJI Inspire 1 UAS's GCS and flight control software is provided

hereto as Exhibits C and D.

b. Flight Operations Of DJI Phantom 3 and DJI Inspire 1 UAS's Are

Limited To The Line Of Sight Of A Certificated Pilot in Command With 

A SafetyObserver.

MEDIAPOST, LLC 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 3 and DJI 

Inspire 1 UAS's. Additionally, a safety observer will assist all pilots during flight time.

c. Flights Of DJI Phantom 3 and DJI Inspire 1 UAS's Will Be

Conducted Pursuant To Specific Operating Limitations.
22

In seeking this exemption, MEDIAPOST, LLC proposes to commercially operate 

DJI Phantom 3 and DJI Inspire 1 UAS's for the special purposeof conducting aerial 

video and photography over certain areas of United States, pursuantto the following 

specific operating limitations:

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

aircraft described in the operating documents, rotorcraft UAS's weighing less 

than 55 pounds maximum gross weight: DJI Phantom 3 and DJI Inspire 1

Unmanned Aircraft Systems. Proposed operations of any other aircraft will

require a new petition or a petition to amend this grant.

2. UAS operations under this exemption will be limited to conductingoperations 

for the purpose of aerial video and photography.

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

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

level (AGL), as indicated by the procedures specified in the operating 

documents unless a special request is made and approved by ATC. All altitudes 

reported to ATC must be in feet AGL.

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

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

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

medical certificate.
23

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 tosatisfy 

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 mustbe

designated before the flight and cannot transfer his or her designation for the

duration of the flight. The PIC must ensure that the SO can perform the

functions prescribed in the operating documents.

8. The SO must not perform any other duties beyond assisting the PIC with seeing 

and avoiding other air traffic and other ground based obstacles/obstructions and 

is not permitted to operate the camera or other instruments.

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

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

discrepancy exists between the conditions and limitations contained in thegrant

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

conditions and limitations contained in the grant of exemption takeprecedence

and must be followed. Otherwise, the operator must follow the procedures as 

outlined in its operating documents. The operator may update or revise its 

operating documents. It is the operator’s responsibility to track such revisions 

and present updated and revised documents to the Administrator uponrequest. 

The operator must also present updated and revised documents if it petitionsfor 

extension or amendment to the grant of exemption. If the operator determines 

that any update or revision would affect the basis upon which the FAAgranted 

the exemption, then the operator must petition for amendment to its grant of 

exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if 

questions arise regarding updates or revisions to the operating documents.

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

condition for safe flight. If the inspection reveals a condition that affectsthe

safe operation of the UAS, the aircraft is prohibited from operating untilthe

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 inthe

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 theUAS 

operation or flight characteristics, e.g. replacement of a flight critical

component, must undergo a functional test flight. The PIC who conductsthe

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.
24

13. The operator must follow the UAS manufacturer’s aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limitrequirements.

14. The operator must 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's operated under this exemption must comply with allmanufacturer 

Safety Bulletins.

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

corrective action taken against discrepancies discovered betweeninspections.

17. The PIC must possess at least a private pilot certificate and at least acurrent

third-class medical certificate.

18. The operator may not permit any PIC to operate unless the PIC meetsthe

operator’s qualification criteria and demonstrates the ability to safelyoperate

the UAS in a manner consistent with how the UAS will be operated underthe

exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours must be logged in a manner consistent with 14C.F.R.

§61.51(b). Flights for the purposes of training the operator’s PIC's are

permitted under the terms of the exemption. However, training operationsmay 

only be conducted during dedicated training sessions. During training, 

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

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

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

91.119.

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

19.1. All operations must be conducted under visual meteorological

conditions (VMC). If flight at night is required, a special request will be made 

at theFAA office closest to proposed area of operations. Flights under special 

visualflight 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 operationis 

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 2,000feet

horizontally from a cloud or when visibility is less than 3 statute miles fromthe

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 UAS with 25% battery power 

remaining.

25. The operator must obtain an Air Traffic Organization (ATO) issuedCertificate

of Waiver or Authorization (COA) prior to conducting any operations underthe

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 inaccordance

with airspace requirements in the ATO issued COA including class of airspace, 

altitude level and potential transponder requirements.

26. All aircraft operated in accordance with the exemption must be identifiedby 

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 UAS 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 timethe

UAS is operating. These documents must be made available to the

Administrator or any law enforcement official upon request.

29. The UAS must remain clear and yield the right of way to all mannedaviation 

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:
26

a. Barriers or structures are present that sufficiently protectnonparticipating 

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

operator must ensure that nonparticipating persons remain undersuch 

protection. If a situation arises where nonparticipating persons leave such 

protection and are within 500 feet of the UA, flight operations must cease

immediately and/or;

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

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

permission and the PIC has made a safety assessment of the risk of 

operating closer to those objects and determined that it does notpresent

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 authorizedrepresentative. 

Permission from land owner/controller or authorized representative will be

obtained for each flight to be conducted.

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

vertical boundaries of the operational area as defined by the applicableCOA 

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

hours. Accidents must be reported to the National Transportation Safety Board 

(NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

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

And (b) Would Not Adversely AffectSafety.

MEDIAPOST, LLC submits that the equivalent level of safety establishedby 

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

the DJI Phantom 3 and DJI Inspire 1 UAS's unless that PIC has demonstrated, by meeting 

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

Phantom 3 and DJI Inspire 1 UAS in a manner consistent with the exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures.

Considering MEDIAPOST, LLC’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. 
27

11062); and the airmanship skills necessary to safely operate the DJI Phantom 3 and DJI 

Inspire 1 UAS, MEDIAPOST, LLC submits that the additional manned airmanship

experience of a commercially certificated pilot would not correlate to the airmanship 

skillsnecessary for MEDIAPOST, LLC’S specific proposed flight operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to 

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

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112,

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

MEDIAPOST, LLC will not allow any PIC to operate the DJI Phantom 3 and DJI 

Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum

flight-hour requirements of the DJI Phantom 3 and DJI Inspire 1 UAS training and currency 

requirements, that the PIC is able to safely operate the DJI Phantom 3 and DJI Inspire 1 

UAS's in a manner consistent with this exemption, including evasive and emergency 

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

structures.

Specifically, the PIC must have accumulated and logged, in a mannerconsistent

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 hourrequirements, 

the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency

purposes).
28

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight

experience that was obtained in compliance with applicable regulations will ensurean 

equivalent level of safety during MEDIAPOST, LLC’Sproposed operations.The

Administrator has held that prior documented flight experience that was obtained in 

compliance with applicable regulations would ensure safe operations, stating asfollows:

In Exemption No. 11062, the FAA required that prior to conducting operationsfor 

the purpose of motion picture filming (or similar operations), the PIC must have

accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of

total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS 

pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062,the

PIC must also have accumulated and logged a minimum of 5 hours as a UASpilot

operating the same make and model of UAS to be used for operations under the

exemption. For clarification, the FAA considers these minimum hourrequirements 

to be inclusive rather than additive; i.e. 5 hours make and model time may be

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

the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the

PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for 

currency purposes). The FAA finds that at a minimum, the flight-hour requirements 

in Exemption No. 11062 are appropriate to practice and build proficiency in the

skills necessary to safely conduct the petitioner’s proposed operations. TheFAA

also finds that prior documented flight experience that was obtained incompliance

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

and experience-building flights can also be conducted under the grant ofexemption 

to accomplish the required flight time. During training, proficiency, and

experience-building flights the PIC is required to operate the UA with appropriate

distances in accordance with 14 C.F.R91.119.

Exemption No. 11138 at page 15.

Accordingly, MEDIAPOST, LLC will ensure safe operations by notallowing any

PIC to operate the DJI Phantom 3 and DJI Inspire 1 UAS unless that PIC has

demonstrated, by meeting minimum flight-hour and currency requirements, that thePIC 

is able to safely operate the DJI Phantom 3 and DJI Inspire 1 UAS in a manner consistent 

with the exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles andstructures.
29

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 bemaintained 

because prior to every flight, MEDIAPOST, LLC will ensure that the DJI Phantom 3 and 

DJI Inspire 1 UAS is in an airworthy condition based upon theUAS’s compliance with its 

operating documents and as stated in the conditions andlimitations herein. Additionally,

the FAA has previously granted relief from Section 91.7(a) specific to UAS, in 

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

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112,

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

4. Reasons Why An Exemption From The Requirements Of Section 91.121 

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained 

because the altitude information of the DJI Phantom 3 and DJI Inspire 1 UAS's will be 

provided to the PIC via GPS equipment and a radio communications telemetry data link, 

which downlinks from the UA to the GCS for active monitoring of the flight pathand altitude. 

This altitude information, combined with MEDIAPOST, LLC’S operation of the DJI Phantom 

3 and DJI Inspire 1 UAS's within visual line of sight, at or below 400 feet AGL, will ensure a

level of safety equivalent to Section 91.121. The altitude

information will be generated by GPS equipment installed on board the aircraft. Priorto 

each flight, a zero altitude initiation point is automatically established by the UAS'sat

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 Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 

14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJI 

Phantom 3 and DJI Inspire 1 UAS's; (2) the limitations on the proposed flight operations;

and (3) the location of the proposed flight operations. Accordingly, Christopher Gerard 

Lognion will ensure that he will safely operate the battery powered DJI Phantom 3 and 

DJI Inspire 1 UAS's during daylight hours in VFR conditions, with enough battery power 

to fly for a total duration of 10 minutes to the first point ofintended

landing and, assuming normal cruising speed, to fly after that for at least 2.5minutes.

Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 3 and 

DJI Inspire 1 UAS's the limitations on the proposed flight operations and the the location 

of the proposed operations, will ensure an equivalent level of safety establishedby 14 

C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Phantom 3 and 

DJI Inspire 1 UAS's provide audible and visual warnings to the PIC at the GCS when the 

UA's experiences low battery voltage, the first warning occurring at approximately 30% 

remaining battery power, and again at approximately 10%remaining battery power. At the 

critically low battery level, the DJI Phantom 3 and DJI Inspire 1 UAS's will descend and

land automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151 

establish that safety is not adversely affected when the technical characteristics and 

operating limitations of the UAS are considered. Relief has been granted for manned 

aircraft to operate at less than the minimums prescribed in Section 91.151, including 

Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously grantedrelief
31

from Section 91.151 specific to UAS in circumstances similar in all material respectsto 

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, MEDIAPOST, LLC submits that the equivalentlevel of

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

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

because MEDIAPOST, LLC will use trained technicians to perform maintenance, 

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

practices prescribed in the operating documents i.e., the Operations Manual, Monthly 

Maintenance Log, and DJI Phantom 3 and DJI Inspire 1 UAS's Instruction Manual.

Furthermore, MEDIAPOST, LLC will document and maintain all maintenancerecords for 

the DJI Phantom 3 and DJI Inspire 1 UAS's.

Since the DJI Phantom 3 and DJI Inspire 1 UAS's will be inspected as prescribed by

the operating documents,MEDIAPOST, LLC will maintain the equivalent level of safety 

established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI 

Phantom 3 and DJI Inspire 1 UAS's User Manuals are attached hereto as Exhibit C and D; a 

copy of the DJI Phantom 3 and DJI Inspire 1 UAS's Maintenance LOG is attached hereto as 

ExhibitE.

Likewise, the exemption sought will not adversely affect safety because

MEDIAPOST, LLC will use trained technicians to perform maintenance, alterationsor 

preventive maintenance on the UAS using the methods, techniques, and practices 
32

prescribed bythe operating documents.

Furthermore, the exemption sought would maintain an equivalent level ofsafety 

Established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI 

Phantom 3 and DJI Inspire 1 UAS's will be performed by trained technicians. Maintenance

will be documented and maintained utilizing the monthly maintenance log.

Significantly, previous exemptions granted by the FAA concerningSections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is 

not adversely affected when the technical characteristics and operating limitations ofthe

UAS are considered.

In consideration of MEDIAPOST, LLC’S proposed operating limitations, the

operating documents, and the technical aspects of the DJI Phantom 3 and DJI Inspire 1 

UAS's, MEDIAPOST, LLC submits that safety will not be adversely affected by granting 

exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a) (2), and 

91.417(a) and (b). The FAA has previously granted relief specific to UASin circumstances 

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

11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136,

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

7. The FAA May Prescribe Any Other Conditions For SafeOperation.

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, MEDIAPOST, LLC requests 

that the FAA prescribe special conditions for the intended operation of the DJI Phantom 3 

and DJI Inspire 1 UAS's, which contain such safety standards that the
33

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 UA's for the limited purpose of 

conducting aerial video and photography over certain areas of the United Statesfor 

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

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

a threat to national security and further, provides the authority for such UAS tooperate

without airworthiness certification in accordance with any requirements that must be

established for the safe operation of the UAS in the NAS.

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

§21.16, for operation of the DJI Phantom 3 and DJI Inspire 1 UAS's, since the

airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate

safety standards, due to the novel or unusual design features of the aircraft. Section21.16, 

entitled Special Conditions, states the following:

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

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

because of a novel or unusual design feature of the aircraft, aircraft engine or 

propeller, it may prescribe special conditions and amendments thereto for the product. 

The special conditions are issued in accordance with Part 11 of this chapter and 

contain such safety standards for the aircraft, aircraft engine or propeller asthe

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, theFAA

may prescribe special conditions for MEDIAPOST, LLC’S intended operation of theDJI 

Phantom 3 and DJI Inspire 1 UAS's, which contain such safety standards that the
34

administrator finds necessary to establish a level of safety equivalent to that established by 

14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 

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

F.A Summary That Can Be Published In The Federal Register stating: The Rules 

From Which MEDIAPOST, LLC Seeks Exemption:

MEDIAPOST, LLC seeks exemption from the requirements of 14 C.F.R Sections 

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

(a)(2), and 91.417(a) & (b).

A Brief Description Of The Nature Of The Exemption MEDIAPOST, LLC 

Seeks:

This exemption will permit MEDIAPOST, LLC to commercially operatean 

Unmanned Aircraft System (UAS) for the purpose of conducting aerial videoand 

photography over certain areas of the United States.

G. Any Additional Information, Views, Or Arguments Available To Support

MEDIAPOST, LLC’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, MEDIAPOST, 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 UASwill

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

security and further, provides the authority for such UAS to operate withoutairworthiness 

certification.

As discussed in detail above, MEDIAPOST, LLC will operate the DJI Phantom 3 

and DJI Inspire 1 UAS's safely in the NAS, without creating a hazard to users of the 

NAS, or the public, or otherwise pose a threat to nationalsecurity.
35

CONCLUSION

As set forth herein, MEDIAPOST, LLC seeks an exemption pursuant to 14

C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of2012 

(FMRA), which will permit safe operation of the DJI Phantom 3 and DJI Inspire 1 UAS's

commercially, without an airworthiness certificate, for the limited purpose

of conducting aerial video and photography over certain areas of the UnitedStates. 

By granting this Petition, the FAAAdministrator 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 MEDIAPOST, LLC to safely, efficiently, and 

economically operate the DJI Phantom 3 and DJI Inspire 1 UAS's commercially 

within the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and theFAA

Modernization and Reform Act of 2012, Section 333, MEDIAPOST, LLC 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 MEDIAPOST, LLC to operate the DJI 

Phantom 3 and DJI Inspire 1 UAS's commercially for the purpose of conducting aerial video and 

photography over certain areas of the UnitedStates.

Dated: July 24, 2015

Respectfully submitted,

Christopher Gerard Lognion

MEDIAPOST, LLC
36

APPENDICES:

A – DJI Phantom 3Specifications

B – DJI Inspire 1 Specifications 

C – DJI Phantom 3 User Manual

D – DJI Inspire1 UserManual

E - Monthly Maintenance Log

40

APPENDIX –A

DJI PHANTOM 3 TECHNICAL SPECIFICATIONS

MEDIAPOST, LLC only utilizes safe and reliable UAS's. DJI is an industry leaderin 

small UAS production. DJI UAS's are loaded with ground breaking software enabling the

user to set parameters which will not allow flight into controlled airspace. Parameterscan 

also be set to limit flight to no higher than a predetermined and set altitude as well as limit

flight to a predetermined and set distance. In addition, DJI software providesreal-time

altitude and location information to the PIC via the linked monitor, DJI Phantom 3 Radio 

ControlTransmitter.

DJI Phantom 3

Weight (Including Battery And Propellers) 1280 g (2.8 lbs)

Diagonal Size (Including Propellers) 590 mm

Max Ascent Speed 5 m/s

Max Descent Speed 3 m/s

Hover Accuracy Vertical: +/- 0.1 m (when Vision Positioning is 

 active) or +/- 0.5 m

Horizontal: +/- 1.5 m

Max Speed 16 m/s (ATTI mode, no wind)

Max Altitude Above Sea Level 6000 m

Operating Temperature 0°C to 40°C

GPS Mode GPS/GLONASS

A Link to more detailed specifications: http://www.dji.com/product/phantom-3/spec
41

APPENDIX –B

DJI INSPIRE 1TECHNICALSPECIFICATIONS

MEDIAPOST, LLC only utilizes safe and reliable UAS's. DJI is an industry leaderin 

small UAS production. DJI UAS's are loaded with ground breaking software enabling

the user to set parameters which will not allow flight into controlled airspace. 

Parameterscan also be set to limit flight to no higher than a predetermined and set

altitude as well as limit flight to a predetermined and set distance. In addition, DJI

software providesreal-time altitude and location information to the PIC via the linked 

RC Transmitter.

DJI Inspire 1

Weight (Battery Included) 2935 g (6.4 lbs)

Hovering Accuracy (GPS Mode) Vertical: 0.5 m - Horizontal: 2.5 m

Max Angular Velocity Pitch: 300°/s - Yaw: 150°/s

Max Tilt Angle 35°

Max Ascent Speed 5 m/s

Max Descent Speed 4 m/s

Max Speed 22 m/s (ATTI mode, no wind)

Max Flight Altitude 4500 m

Max Wind Speed Resistance 10 m/s

Max Flight Time Approximately 18 minutes

Operating Temperature Range -10° to 40° C

Diagonal Distance 559 to 581 mm

Dimensions 438x451x301 mm

A Link to more detailed specifications: http://www.dji.com/product/inspire-1/spec
42

APPENDIX – C

DJI Phantom 3 – Manufacturer's User Manual

http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professiona

l_User_Manual_v1.2_en.pdf
43

APPENDIX – D

DJI INSPIRE 1 Manufacturer’s User Manual

http://download.djiinnovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.2_en.

pdfAPPENDIX - E
44

MEDIAPOST, LLC 

Monthly Maintance and Repair Log

Aircraft:

Hours:

Date:

Date Issue

Discovered

Date Issue

Resolved

Issue Decription/MaintanceConducted Repair/Maintanc

e Performed By

Airframe

Motors

Propellers

Flight Control

Update

Gimbal

Misc