MEDIAPOST, LLC

635 Petro Point Drive

Lake Charles, LA 70607

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

MEDIAPOST, LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

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

91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL

OPERATION OF D JI PHANTOM 3 AND DJI INSPIRE 1 UNMANNED AIRCRAFT

SYSTEMS PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112

- 95)

Submitted on 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.com2 TABLE OF CONTENTS

Page

GLOSSARY OF ABBREVIATIONS

................................ ................................ ......................... 3

SUMMARY

................................ ................................ ................................ ................................ ............ 4

INTRODUCTION AND INTERESTS OF PETITIONER.

................................ .................. 4

BACKGROUND

................................ ................................ ................................ ..................... 5

BASIS FOR PETITION

................................ ................................ ................................ ........ 5

NAME AND ADDRESS OF PETITIONER.

................................ .......................... . 8

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

SEEKS EXEMPTION

................................ ................................ .............................. 8

THE EXTENT OF RELIEF MEDIAPOST, LLC SEEKS AND THE REASON

MEDIAPOST, LLC SEEKS THE RELIEF...................................................... 1 2

THE REASONS WHY GRANTING MEDIAPOST, LLC’S REQUEST

WOULD BE IN THE PUBLIC INTEREST

.......... ................................ .............. 15

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

ADVERSELY AFFECT SAFETY

................................ ................................ ................. 19

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER.

.... 34

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS

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

.................. 34

CONCLUSION

................................ ................................ ................................ ...................... 35

APPENDICES.........................................................................................363 GLOSSARY OF ABBREVIATIONS

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 Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

HH Horizon Hobby Blade 350QX2AP

LOL Loss Of Link

NAS National Airspace System

NOTAM Notice To Airman

PIC Pilot In Command

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

Section 333 SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line Of Site

VMC Visual Meteorological Conditions

VTOL Vertical Take

- Off and Landing4 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 and landscape

over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

A cinematographer and multimedia editor with more than 2 4 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, pub lic, and residential uses,

specifically targeting

• Construction sites before and after

• Motion Picture / Television Commercials / Training Videos

• Real

- estate marketing

• Economic development

• Private and governmental training5 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 system s

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

takeoff and landing (VTOL) Unmanned Aircraft s (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 pow ered 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 Aircraft Systems , 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 req uirements

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 associated6 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 14 C.F.R. Part

21, Subpart H.

Accordingly, MEDIAPOST , LLC requests relief from Sections 91.405(a),

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

requirements for maintenance that 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 preventive maintenance

on the UAS's using the methods, techniques, and pra ctices prescribed in the operating

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

Instruction Manual s ). Furthermore, MEDIAPOST, LLC will document and maintain

all maintenance records for the DJI Phantom 3 and DJI Inspir e 1 UAS's

.

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

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 higher level

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 consiste nt with this

exemption, including evasive and emergency maneuvers and maintaining appropriate

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 an7 airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such,

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 Maintenance Log,

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

in a condition for safe flight.

MEDIAPOST, LLC also seeks an exemption from the requirements of Section 91.121,

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 inform ation, 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.

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

and landing.8 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 The Petitioner

The name and address of the Petitioner and point of contact is:

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 Requirements Of

Section 61.113(a) And (b).

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

,

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

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

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

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

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

connection with any business or employment if

—

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

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

2. MEDIAPOST, LLC Seeks Exemption From The Requirements Of

Section 91.7(a).9 Section 91.7, entitled Civil aircraft airworthiness , subsection (a), states the

following:

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

3. 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 or flight

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

when operating

--

(1) Below 18,000 feet MSL, to

--

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

and within 100 nautical miles of the aircraft;

(ii) 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 of the

departure airport or an appropriate altimeter setting available before

departure.

4. MEDIAPOST, LLC Seeks Exemption From The Requirements Of

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 Requirement Of

Section91.405(a).10 Section 91.405, entitled Maintenance required

, subsection (a), states the following:

Each owner or operator of an aircraft

—

(a) Shall have that aircr aft 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. MEDIAPOST, 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 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 Requirements Of

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

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

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

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

--

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

been approved for return to service by a person authorized by § 43.7 of this

chapter or

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

with part 21 of this chapter.

8. MEDIAPOST, 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 o wner or operator shall keep the following records for the periods

specified in paragraph (b) of this section:11 (1) Records of the maintenance, preventive maintenance, and alteration and

records of the 100

- hour, annual, progressive, and other required or approved

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

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

include

--

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

the work performed; and

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

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

aircraft for return to service.

(2) Records containing the following information:

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

each rotor.

(ii) The current status of life

- limited parts of each airframe, engine,

propeller, rotor, and appliance.

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

are required to be overhauled on a specified time basis.

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

last inspection required by the inspection program under which the

aircraft and its appliances are maintained.

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

directives including, for each, the method of compliance, the AD or

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

involves recurring action, t he 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 reta in the following records for the periods

prescribed:

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

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

work is performed.12 (2) The records specified in paragraph (a)(2) of this section shall be retained

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

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

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

approved for return to service.

C. The Extent Of Relief 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 Secti on 61.113(a) And (b).

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

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

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

certificate, and who has met certain flight

- hour and currency requirements, to conduct the

proposed UAS flight operations for compensation or hire.

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

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

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

business or employment; and (2) The aircraft does not carry passengers or pr operty for

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 the DJI 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 evas ive and emergency maneuvers, as well as

maintaining appropriate distances from people, vessels, vehicles and structures.13 Further, MEDIAPOST, LLC submits that all flights of the DJI Phantom 3 and DJI Inspire 1

UAS's

, conducted by the PIC pursu ant 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 to the

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 ensurin g that the UAS is in

compliance with the operating documents (i.e., the Monthly Maintenance 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 a n 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 Manual s ) prior to every flight, and further, determine that the aircraft are in

condition for safe flight, as stated in the conditions and li mitations below.

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 telemetry data link to

downlink altitude information from the UA to the PIC at the ground control station14 (GCS). Since the FAA requires that any a ltitude 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 14 CFR

91.121 is sought to the extent necessary to comply with the applicable conditions an d

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 a ground

level pressure setting will be established prior to each flight, and provides the PIC with

altitude information of the UA on the heads

- up display of the GCS.

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

MEDIAPOST, LLC Seeks Relief From Se ction 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 minutes to

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

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 to conduct 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 th at 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 mi nutes to the first point of intended landing and, assuming normal

cruising speed, to fly after that for at least 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 Pha ntom 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 tech nicians to perform

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

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

Operations Manual, Monthly Main tenance 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 In The

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 to the

the econo my. Notably, the benefits of MEDIAPOST, LLC’S proposed operation of the

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 perform aerial

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 and air pollution, as

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

.

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

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

DJI Phantom 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 control during

the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. Th e 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 drastically reducing

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

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

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

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

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

approximately 20

- 30 gallons per hour of leaded avi ation 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 battery powered 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, which is usually

associated with traditional manned aircraft flight operations, will be substantially re duced

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 to the

manned aircraft that typically conduct similar operations (weighing approximately 6,000

pounds, and a fuel capacity of 180 gallons.18 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 con tribute to growth of the U.S. economy. Specifically, with the rising cost of aviation

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

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

technology in order to remain competitive. Operating the battery powered DJI Phantom 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 flexibility without

the high operational cost of a traditional manned aircraft.

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

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

stability t o 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 federal tax

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

competitive both in the United States and abroad.

4. There Are No Privacy Issues.

Similar to the manned aerial ac quisition 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 119 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

notif ication, 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 Seeks Exemption.

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 of the 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 UA S will create a

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

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

(a) In General.

-- Notwithstanding any other requirement of this subtitle, and not

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

Transportation shall determine if certain unmanned aircraft systems may

operate safely in the national airspace system before completion of the plan

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

section 334 of this Act.20 (b) Assessment of Unmanned Aircraft Systems.

-- In making the determination under

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

--

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

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

populated areas, and operation within visual line of sight do not create

a hazard to users of the national airspace system or the public or pose a

threat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or

airworthiness certification under section 44704 of title 49, United States

Code, is required for the operation of un manned aircraft systems

identified under paragraph (1).

(c) Requirements for Safe Operation.

-- If the Secretary determines under this

section that certain unmanned aircraft systems may operate safely in the

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

operation of such aircraft systems in the national airspace system.

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

DJI Inspire 1 UAS's can oper ate safely in the NAS pursuant to FMRA Section 333, 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,

s peed, 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 flight modes , i.e. Return To Home

.

i ii. 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 T he 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 Phanto m

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 Safety Observer.

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 f light 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 purpose of conducting aerial

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

specific operating limitations:

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

aircraft described in the op erating 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 conducting operations

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 above ground

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

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

reported to ATC must be in feet AGL.

5. The 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 to satisfy

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

The SO and PIC must be able to communicate verbally at all times. Electronic

messaging or texting is not permitted during flight operations. The PIC must be

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

duration of the fl ight. 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/obstructio ns and

is not permitted to operate the camera or other instruments.

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

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

discrepancy exists between the conditions and limitations contained in the grant

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

conditions and limitations contained in the grant of exemption take precedence

and must be followed. Otherwise, the operator must fol low the procedures as

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

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

and present updated and revised documents to the Administrator upon request.

The operator must also present updated and revised documents if it petitions for

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

that any update or revision would affect the basis upon which the FAA granted

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

exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if

questions arise regarding updates or revisions to the operating documents.

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

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

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

necessary maintenance has been performed and the UAS is found to be in a

condition for safe flight. The Ground Control Station must be included in the

preflight inspection. All maintenance and alterations must be properly

documented in the aircraft records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS

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

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

functional test flight must make an entry in the aircraft records.

12. The pre

- flight inspection must account for all potential discrepancies, e.g.

inoperable components, items, or equipment, not already covered in the

relevant sections of the operating documents.24 13. The operator must follow the UAS manufacturer’s aircraft/component,

mainte nance, overhaul, replacement, inspection, and life limit requirements.

14. The operator must carry out its maintenance, inspections, and record keeping

requirements, in accordance with the operating documents. maintenance,

inspection, 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 all manufacturer

Safety Bulletins.

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

corrective action taken against discrepancies discovered between inspections.

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

third

- class medical certificate.

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

operator’s qualification criteria and demonstrates the ability to safely operate

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

exemption, including evasive and emergency maneuvers and maintaining

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

qualification flight hours must be logged in a manner cons istent with 14 C.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 operations may

only be conducted during dedicated training sessions. During training,

proficiency, and experience

- building flights, all persons not essential for flight

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

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

91.119.

19. UAS operations may not b e 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 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 Administ rator 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

PIC.

22. If the UA loses communications or loses its GPS signal, it must return to a pre

determined location within the planned operating area and land or be recovered

in accordance with the operating documents.

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

emergencies in accordance with the o perating 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) issued Certificate

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

grant of exemption. This COA will also require the operator to request a Notice

to Airman (NOTAM) not more than 72 hours in advance, but not less than 48

hours prior to the operation. All operations shall be conducted in accordance

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

altitude level and potenti al transponder requirements.

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

serial number, registered in accordance with 14 C.F.R. part 47, and have

identification (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 time the

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 manned aviation

operations and activities at all times.

30. The UAS may not be operated by the PIC from any moving device or vehicle.

31. Flight operations mu st 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 prote ct nonparticipating

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

operator must ensure that nonparticipating persons remain under such

protection. If a situation arises where nonparticipating persons leave such

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

immediately and/or;

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

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

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

operating closer to those objects and determined that it does not present

an undue hazard, and;

c. Operations nearer to the PIC, SO, operator trainees or essential persons

do not present an undue hazard to those persons per § 91.119 (a).

32. All operations shall be conducted over private or controlled

- access property

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

Permission from land owner/controller or authorized representative will be

obtained for each flight to be conducted.

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

vertical boundaries of the operational area as defined by the applicable COA

must be reported to the FAA's UAS Integration Office (AFS

- 80) within 24

hou rs. Accidents must be reported to the National Transportation Safety Board

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

.

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

And (b) Would Not Adversely Affect Safety.

MEDIAPOST, LLC submits that the equivalent level of safety established by

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

the DJI Phantom 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, incl uding

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

skills necessary 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).

MEDI APOST, 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, ve hicles and

structures.

Specifically, the PIC must have accumulated and logged, in a manner consistent

with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a

minimum of 5 hours of those hours as a UAS pilot operating the same ma ke and model of

UAS to be used for operations under the exemption). In addition to the hour requirements,

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

purposes).28 As in Exemption Nos. 11062, 11138, and 11153, prior documented flight

experience that was obtained in compliance with applicable regulations will ensure an

equivalent level of safety during 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 as follows:

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

the purpose of motion picture filming (or similar oper ations), 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 N o. 11062, the

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

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

exemption. For clarification, the FAA considers these minimum hour requirements

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

included in the 10 hours of multi

- rotor time and the 10 hours may be included in

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

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

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

- hour requirements

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

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

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

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

and experience

- building flights can also be cond ucted under the grant of exemption

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

experience

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

distances in accordance with 14 C.F.R 91.119.

Exemption No. 11138 at page 15.

Accordingly, MEDIAPOST, LLC will ensure safe operations by not allowing 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 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.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 be maintained

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 the UAS’s compliance with its

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

the FAA has previously granted relief from Section 91.7(a) speci fic 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 path and altitude.

This altitude information, combined with MEDIAPOST, LLC’S operati on 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. Prior to

each flight, a zero altitude initiation point is automatically established by the UAS's 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 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 of intended

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

Here, as in Exemption No. 11109, the tech nical 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 established by 14

C.F.R. Section 91.151(b). Furth ermore, 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 3 0 %

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

esta blish 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

Exe mption 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, 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 equivalent level of

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

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

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

alterations, or preventive maintenance on the UAS's using the methods, techn iques, 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 maintenance records fo r

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

Exhibit E.

Likewise, the exemption sought will not adversely affect safety because

MEDIAPOST, LLC will use trained technicians to perform maintenance, alterations or

preventive m aintenance on the UAS using the methods, techniques, and practices32 prescribed by the operating documents.

Further more, the exemption sought would maintain an equivalent level of safety

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

Phantom 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 concerning Sections

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

not adversely affected when the technical characteristics and operating limitations of the

UAS are considered.

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 UAS in circum stances

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, 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 the33 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 ov er certain areas of the United States for

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

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

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

without airworthiness certification in accordance with any requirements that must be

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

Likewise, the Administrator may prescribe special conditions pursu ant 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 aircr aft. Section 21.16,

entitled Special Conditions, states the following:

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

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

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

propeller, 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 safet y standards for the aircraft, aircraft engine or propeller as the

FAA finds necessary to establish a level of safety equivalent to that established in

the regulations.

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA

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

Phantom 3 and DJI Inspire 1 UAS's

, which contain such safety standards that the34 administrator finds necessary to establish a level of safety equi valent 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 operate an

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

photography over certain areas of the United States.

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

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 UAS will

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

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

certification.

As discussed in detail above, 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 national security.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 of 2012

(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 United States.

By granting this Petition, the FAA Administrator will be fulfilling the Congressional

mandate of the FAA Modernization an d 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 the FAA

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 United States.

Dated: July 24

, 2015

R espectfully submitted,

Christopher Gerard Lognion

MEDIAPOST, LLC36 APPENDICES:

A

– DJI Phantom 3 Specifications

B

– DJI Inspire 1 Specifications

C

– DJI Phantom 3 User Manual

D

– DJI Inspire1 User Manual

E

- Monthly Maintenance Log40 APPENDIX

– A

DJI PHANTOM 3 TECHNICAL S PECIFICATIONS

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

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. Parameters can

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 provides real

- time

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

Control Transmitter

.

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/spec41 APPENDIX

– B

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

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

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.

Parameters can 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 provides real

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

RC Tra nsmitter.

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/spec42 APPENDIX

– C

DJI Phantom 3

– Manufacturer's User Manual



## http://download.dji

innovations.com/downloads/phantom_3/en/Phantom_3_Professiona

l_User_Manual_v1.2_en.pdf43 APPENDIX

– D

DJI INSPIRE 1 Manufacturer’s User Manual



## http://download.dji

innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.2_en.

pdf APPENDIX

- E44 MEDIAPOST, LLC

Monthly Maintance and Repair Log

Aircraft:

Hours:

Date:

Date Issue

Discovered Date Issue

Resolved Issue Decription/Maintance Conducted Repair/Maintanc

e Performed By

Airframe

Motors

Propellers

Flight Control

Update

Gimbal

Misc