UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WAS HI NGTON, DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

FLORIDA DRONE WORX , INC.

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF F EDERAL 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 a) DJI PHANTOM 3, and c) DJI INSPIRE 1 UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SEC TION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)

Submitted on NOVEMBER 18 , 2015

Florida Drone Worx , Inc.

Stefan Muehlbauer , Owner

2316 Pine Ridge Rd, #383 Naples, FL 34109 ( 239 ) 248

- 0460 stefan@floridadroneworx.com

# Table of Contents

GLOSSARY OF ABBREVIATIONS 3

SUMMARY 4

INTRODUCTION AND INTERESTS OF THE PETITIONER 4

BACKGROUND 4

BASIS FOR PETITION 5

NAME AND ADDRESS OF THE PETITIONER 6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH FLORIDA DRONE WORX
INC

. SEEKS EXEMPTION 6

THE EXTENT OF RELIEF FLORIDA DRONE WORX, INC. SEEKS AND THE
REASON FLORIDA DRONE WORX, INC. SEEKS THE RELIEF 9

THE REASONS WHY GR ANTING FLORIDA DRONE WORX, INC ’S REQUEST
WOULD BE IN THE PUBLIC INTEREST 12

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERS ELY
AFFECT SAFETY 14

CONCLUSION 24

## GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area Of Interest

ATC Air Traffic Control

ATO Air Traffic Organization
AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certifica te of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station
GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airmen
PIC Pilot in Command
Section 333 FAA Modernization and Reform Act of2012 (FMRA)

SO Safety Ob server SOP Standard Operating Procedure

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Sight

VMC Visual Meteorological Conditions
VTOL Vertic al Takeoff and Landing

## SUMMARY
Florida Drone Worx, Inc. seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91. 7(a), 91.121, 91.151(b ), 91.405(a), 91.407(a)(l ), 91.409(a)(l) & ( a)(2), and 91.417( a) & (b), to operate an
Unmanned Aircraft System pursuant to Section 333 ofthe FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Florida Drone Worx, Inc. to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photo graphy for real estate photography, wedding videography, special events, film sets and landscape over certain areas of the
United States.



## INTRODUCTION AND INTERESTS OF THE PETITIONER
Florida Drone Worx, Inc. is a subsidiary of Arma Communications Inc. a leading provider of online marketing agency. It is the mission of Florida Drone Worx, Inc. to provide our clients with expertise and knowledge in all aspects of picture, video & audio production, as well as provide them with advanced technologies & solutio ns that will increase efficiency, productivity and effectiveness. Florida Drone Worx, Inc. also provides clients with the highest quality digital content for use in their commercial, personal, and non

- profit multimedia projects. Florida Drone Worx, Inc. an d its parent company Arma Communications Inc has several years of professional experience in photography and videography and has become recognized as an expert in this field.

Florida Drone Worx , Inc. has 3 years of recreational/hobby experience in all aspe cts of aerial video and photography. The objective of Florida Drone Worx , Inc.'s aerial video and photography operations is to provide high quality imaging for a variety of commercial, public, and residential uses, specifically targeting:

• Real Estate Video graphy and Photography

• Wedding Videography and Photography

• Land survey & appraisals

• Equipment Inspections

• Roof Inspections

• Construction sites before & after

• Precision Agriculture

• Creation of commercial messages for Television and Online Media

• Search and Rescue Operations

• Motion Picture Filming

• Drone Educational Classes

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



## BACKGROUND
Unmanned Aircraft Systems: DJI Phantom 3, and DJI Inspire 1 UASs Florida Drone Worx, Inc. seeks an

exe mption to operate DJI systems for compensation or hire within the NAS. The DJI Phantom 3 has a maximum gross weight of approximately 2 pounds 13 ounces, while having a length of 16 inches by 16inches, height of 8 inches, and a maximum speed of approximate ly 31 knots. The DJI Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of approximately 42 knots. The DJI Phantom 3, and DJI Inspire 1 UAs are equipped wit h four main rotors; driven by Lithium Polymer battery powered electric motors.

The DJI Phantom 3, and DJI Inspire 1 UAs that will be operated by Florida Drone Worx , Inc. will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.P.R. Part 45, Identification and Registration Marking.



## BASIS FOR PETITION
Petitioner, Florida Drone Worx, Inc., pursuant to the provisions of the Federal Aviation Regulations ( 1 4 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 UASs in the Nation al 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 o perating area associated with the unmanned aircraft and its operation, Florida Drone Worx, Inc. operation of DJI Phantom 3, and DJI Inspire 1 UASs meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in

acco rdance with 14 C.P.R. Part 21, Subpart H.

Accordingly, Florida Drone Worx, Inc. requests relief from Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to

a ircraft with an airworthiness certificate.

Florida Drone Worx, Inc. submits that the requested relief is proper since an equivalent level of safety will be ensured. Florida Drone Worx, Inc. will use experienced personnel or technicians to perform
maintenan ce, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3, and DJI Inspire 1 Instruction Manual). Furthermore, Florida Drone W orx, Inc. will document and maintain all maintenance records for the DJI Phantom 3, and DJI Inspire 1 UASs.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested by Florida Drone Worx, Inc. to the extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an airman medical certificate, and who has demonstrated, by meeting minimum flight

- hour and currency require ments, that the PIC is able to safely operate the DJI Phantom 3, and DJI Inspire 1 UASs in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structure s.

Florida Drone Worx, Inc. seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the DJI Phantom 3, and DJI Inspire 1 UASs do not require an airworthiness certificate in accordance with 14 C.P.R. Part 21, Subpart H. As such, Fl orida Drone Worx, Inc. submits that they will ensure that the DJIPhantom 3, and DJI Inspire 1 UASs are in an airworthy condition, prior to every flight, by determining that the UASs are in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3, and DJI Inspire 1 Instruction Manual), and that the aircraft are in a condition for safe flight.

Florida Drone Word, Inc. also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings, as the DJI Phan tom 3, and DJI Inspire 1 UAs will not have a typical barometric altimeter onboard. However, altitude information of the DJI Phantom 3, and DJI Inspire 1 UAs will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with Florida Drone Worx, Inc.'s operation of the DJI Phantom 3, and DJI Inspire 1 UASs within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to
Section 91.121.

Additionally, Florida Drone Worx, Inc. seeks an exemption from the requirements of Section 91.151 (b), entitled Fuel requirements for flight in VFR conditions. Florida Dron e Worx, Inc. submits that safety will not be affected by operation of the DJI Phantom 3, and DJI Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a
total dur ation of approximately 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

In accordance with 14 C.F .R. § 11.81, Florida Drone Worx, Inc. provides the following information i n 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:

Stefan Muehlbauer c/o Florida Drone Worx, Inc. 2316 Pine Ridge Rd #383 Naples, FL 34109 Tel: (239) 248

- 0460
Ema il: stefan@floridadroneworx.com


## B. The Specific Sections Of 14 C.F.R. From Which Florida Drone Worx, Inc. Seeks Exemption.
1. Florida Drone Worx, Inc. Seeks Exemption From The Requirements Of Section Part 21, Subpart H

14 C.F.R Part 21, Subpart H, establishes the procedural requirements for the issuance of airworthiness certificates as required by 14 C.F.R. §91.203(a)(l)

2. Florida Drone Worx, Inc. Seeks Exemption From The Requirements Of Section 61.113(a) And (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections (a) and (b) prescribe the following, in relevant part:(a) No person who holds a private pilot certificate may act as a pilot in 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
busine ss 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.

3. Florida Drone Worx , Inc. Seeks Exemption From The Requirements Of Section 91.7( a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following: (a) No person may operate a civil aircraft unless it is in an airworthy condition.

4. Florida Drone Worx , Inc. Seeks Exemption From The Requirements Of Section 9 1.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimete r 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

. 5. Florida Drone Worx, Inc. Seeks Exemption From The Requirements Of Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states the following:

(b )No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.

6. Florida Drone Worx, Inc. Seeks E xemption From The Requirement Of Section 91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following: Each owner or operator of an aircraft

-
(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.]

7. Florida Drone Worx, Inc. Seeks Exemption From The Requirements Of Section 91.407(a)(l)Sec tion 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration, subsection (a)(l), states the following: (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or al teration unless

— (1) It has been approved for return to service by a person authorized under§ 4 3. 7 of this chapter[.]

8. Florida Drone Worx , Inc. Seeks Exemption From The Requirements Of Sections 91.409(a)(l) 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.

9. Florida Drone Worx , Inc. Se eks Exemption From The Requiremen ts 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 own er or operator shall keep the following records for the periods specified in paragraph (b) of this
section:

(1 ) Records of the maintenance, preventive maintenance, and alteration and records of
the 100

- hour, annual, progressive, and other required or app roved 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 Admin istrator) of the

work p erformed and (ii) The date of com pletion 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 o f 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

requ ired 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 curre nt 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, the time and date when the next action is required. 9 10 (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 f ollowing 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. (2) The records specified in pa ragraph (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 rep aired and the aircraft is approved for
return to service.



## A. The Extent Of Relief Florida Drone Worx , Inc. Seeks And The

Reason Florida Drone Worx , Inc. Seeks The Relief.

9. Florida Drone Worx , Inc. Seeks Exemption From The Requirements Of Section Part 21, Subpart H

Given the size and limited operating area associated with the UAS to be utilized by Florida

Drone Worx , Inc., an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act.

T he Federal Aviation Act (49 U.S. C.§ 44701(§)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and pro ximity to airports and populated areas of the particular UAS.

In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will
be at l east as safe, or safer, than a conventional rotorcraft operating with an airworthiness certificate without the restrictions and conditions of the proposed UAS operations.10. Extent Of Relief Florida Drone Worx , Inc. Seeks And The Reason Florida Drone Worx , Inc. 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 holding a private pilot or higher
level certificat e, 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 n ot carry passengers or property for compensation or hire.

As set forth more fully below, Florida Drone Worx, Inc. submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the DJI Phantom 3, UAS or DJI Inspire 1 UAS unless that PIC has met certain flight

- hour and currency requirements, demonstrating that the PIC is able to safely operate either the DJI Phantom 3, or DJI Inspire 1 UAS in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures.

Further, Florida Drone Worx , Inc. submits that all flights of the DJI Phantom 3, and DJI Inspire 1 UASs, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to Florida Drone Worx, Inc.' business and (2) will not carry passengers or property for compensation or hire.

11. Extent Of Relief Florida Drone Worx , Inc. Seeks And The Reason Florid a Drone Worx , Inc. 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 Florida Drone Worx, Inc. to determine that the DJI Phantom 3, and DJI Inspire 1 UASs are i n airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., the Florida Drone Worx, Inc. Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3, and DJI Inspire 1 Instruction Manua l).

Florida Drone Worx, Inc. seeks the requested relief because the DJI Phantom 3, and DJI Inspire 1 UASs do not require an airworthiness certificate in accordance with 14 C.P.R. Part 21, Subpart H. Therefore, Florida Drone Worx, Inc. will ensure that the DJI Phantom 3, and DJI Inspire 1 UASs 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 Instruction Manual) prior to every flight, and further, determine t hat the aircraft are in condition for safe flight, as stated in the conditions and limitations below.12. Extent Of Relief Florida Drone Worx , Inc. Seeks And The Reason Florida Drone Worx , Inc.
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 UASs, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude
informatio n from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), Florida Drone Worx, Inc. seeks the reque sted relief because the DJI Phantom 3, and DJI Inspire 1 UA'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 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 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 displa y of the GCS.

13. Extent Of Relief Florida Drone Worx , Inc. Seeks And The Reason Florida Drone Worx , Inc. 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 exte nt required to allow flights of the battery powered DJI Phantom 3, and DJI Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to the first point of intended l anding and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. Florida Drone Worx, Inc. 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 will severely constrain the practicality of any aerial video or still photo flight operations that Florida Drone Worx, Inc. proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specificatio ns of the DJI Phantom 3, and DJI Inspire 1 UASs, the DJI Phantom 3, and DJI Inspire 1 operating documents, and Florida Drone Worx, Inc.'s proposed operating limitations, ensure that Florida Drone Worx, Inc. will safely operate the battery powered DJI Phant om 3, and DJI Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

14. Extent Of Relief Florida Drone Worx , Inc. Seeks And The Reason Florida Drone Worx , Inc. Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b).Since S ections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, Florida Drone Worx, Inc. requests relief from these Sections because the DJI Phantom 3, and DJI Inspire 1 UASs do not requ ire airworthiness certificates. As set forth more fully below, the DJI Phantom 3, and DJI Inspire 1 UASs meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, Florida Drone Worx, Inc. will use trained tech nicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the Florida Drone Worx, Inc. Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3, and DJI Inspire 1 Instruction Manual). Furthermore, Florida Drone Worx, Inc. will document and maintain all maintenance records for the DJI Phantom 3, and DJI Inspire 1 UASs.



## C. The Reasons Why Granting Florida Drone Worx, Inc. Request Would Be In The Public Interest; That Is, How It Would Benefit The Public As A
Whole.

Granting the present Petition will further the public interest by allowing Florida Drone Worx , Inc. to safely, efficiently, and economically perform aerial video and ph otography of, real estate, wedding films, special events, precision agriculture, land survey & appraisal, construction sites, equipment & roof inspections, film sets and landscape over certa in areas of the United States.

Additionally, use of the DJI Phant om 3, and DJI Inspire I UASs will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of Florida Drone

Worx , Inc.'s proposed operation of the DJI Phantom 3, and DJI Inspire 1 UASs will be realized without implicating any p ri vacy Issues.

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

The DJI Phantom 3, and DJI Inspire 1 UAs are battery powered and serve as a safe, efficient, and
economical alternative to the manned aircraf t traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJI Phantom 3, or DJI Inspire 1 UAS would reduce the amount of manned aircraft in the NAS , reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing ai rcraft will be reduced. The DJI Phantom 3, and DJI Inspire 1 UAs 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. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 3, and DJI Inspire 1
UASs.

Conducting aerial acquisitions with the D JI Phantom 3, and DJI Inspire 1 U AS'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 ba ttery power and electric motors, the DJI Phantom 3, and DJI Inspire 1 UASs produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically utiliz ed 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, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the U As are propelled by battery powered electric motors, rather than an internal combustion engine.

By using the DJI Phantom 3, and DJI Inspire 1 U AS's to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, wh ich is usually associated with traditional manned aircraft flight operations, will be substantially 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 (weighin g approximately 2 pounds 11 ounces, 2 pounds 13 ounces, and 6 pounds 7.5 ounces respectively, at the ir maximum gross weights with lengths of 16 inches, 16 inches, and 17.3 inches respectively, widths of 16 inches, 16 inches, and 17.7 inches respectively, a nd 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 with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations With The DJI Phantom 3, and DJI Inspire 1 UASs Will Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 3, and DJI Inspire 1 UASs 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 UASs will allow United States based companies, like Florida Drone Worx, Inc., to remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency ("EPA") regulatory actions phasing out leaded aviation fuels, U.S. owned and o perated companies must adopt new and alternative technology in order to remain competitive. Operating the battery powered DJI Phantom 3, and DJI Inspire 1 UASs is one such technology that not only allows companies greater operational flexibility compared t o 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 UASs, companies such as Florida Drone Worx, Inc., 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 UA Ss, 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 acquisition flight operations that have been conducted for decades, Florida Drone Worx, Inc.'s proposed operation of the DJI Phantom 3, and DJI Inspire 1 UASs will not implicate any privacy issues. Specifical ly, the DJI Phantom 3, and DJI Inspire 1 UASs will be operated only in compliance with operating documents (i.e., the Florida Drone Worx, Inc. Aerial Operations Manual, Monthly Maintenance Log, and DJI DJI Phantom 3, and DJI Inspire 1 Instruction Manual) w hich 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.



## D. 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 Florida Drone Worx, Inc. Seeks Exemption.

1. Reasons Why The DJI Phantom 3, and DJI Inspire 1 UAs Meet The Condi tions Of The FAA Modernization and Reform Act of2012 (FMRA) Section 333.

In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, Florida Drone Worx, Inc.'s operation of the DJI Phanto m 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 certificatio n and sets forth requirements for considering whether a UAS will create a hazard to users ofthe NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part:

(a) In General

-- Notwithstandin g 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

co mpletion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act.

(b) Assessment of Unmanned Aircraft Systems.

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

—
(1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the n ational 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

oper ation of unmanned 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, Florida Drone Worx, Inc. submits that the DJI Phantom 3, and DJI Inspire 1 UASs can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI Phantom 3, and DJI Inspire 1 UASs; (b) the pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The DJI Phantom 3, and DJI Inspire 1 UASs Demonstrate Its Safe
Characteristics.

The DJI Phantom 3, and DJI Inspire 1 UASs do not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capabilit y.

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

The technical specifications of the DJI Phantom 3, and DJI Inspire 1 UASs are set forth by the DJI Phantom 3, and DJI Inspire 1 Specifications and Data She et, attached hereto as Exhibit A and B.

ii. The DJI Phantom 3, and DJI Inspire 1 UASs Autonomous Flight And Navigation Modes Enable The UASs To Remain Within A Defined Operational Area.

The DJI Phantom 3, and DJI Inspire 1 UASs may be operated in both manual and fully autonomous flight modes. A complete description of the flight and navigational modes of the DJI Phantom 3, and DJI Inspire 1 UASs are provided at pages 23

- 29 of the, DJI Phantom 3; and pages 12

- 18 and 45

- 52 of the DJI

I nspire 1 User Manuals, attached hereto as Exhibit C and D

.

iii. The DJI Phantom 3, and DJI Inspire 1 UASs Are Designed For Automatic Return To Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation.

When the Cont rol Link is lost, the DJI Phantom 3, and DJI Inspire 1 UAs will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 3, and DJI Inspire 1 UAs do not reacquire control link data from the GCS, the UAs will assume that the Control Link is lost and the UAs will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown. A complete description of the Failsafe Functions for the DJI Phantom 3 UAS are set forth at page 12 of the DJI Phantom 3 User Manual; and for the DJI Inspire 1 at pages 13 through 15 of the DJI Inspire 1 User Manual, attached hereto as Exhibit C and D.

iv. The DJI Phantom 3, and DJI Inspire 1 GCS And Its Operation.

A complete description of the operation a nd specifications of the DJI Phantom 3, and DJI Inspire 1 GCS and flight control software is provided at pages 11 through 46 of the DJI Phantom 3 User Manual;; and pages 24 through 34 of the DJI Inspire 1 User Manual. DJI Phantom 3 and DJI Inspire 1 User M anuals are
attached hereto as Exhibits C and D.

b. Flight Operations Of DJI Phantom 3, and DJI Inspire 1 UASs Are Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer.Florida Drone Worx, Inc. will only utilize certificated pilots who possess a current and valid airman medical certificate to act as a pilot in command (PIC) of the DJI Phantom 3, and DJI Inspire 1 UASs. Additionally, a safety observer will assist all pilots during flight time.

c. Fligh ts Of DJI Phantom 3, and DJI Inspire 1 UASs Will Be Conducted Pursuant To Specific Operating
Limitations.

In seeking this exemption, Florida Drone Worx , Inc. proposes to commercially operate DJI Phantom 3, and DJI Inspire 1 UASs 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 operatin g documents, rotorcraft UASs 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 UAs may not be flown at an indicated airspeed exceeding 20 knots.

4. The UA must be operated at an altitu de of no more than 500 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved by ATC. All altitudes reported to ATC must be in feet AGL.

5. The UAs must be operated within visual line of sight (VLOS) of the PIC at 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.

6. The use of first perso n 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 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 o perate 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 con tained 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 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 Administratorupon 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 VAS 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 c ondition 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 flig ht. 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 fl ight 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 po tential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents.

13. The operator must follow the UAS manufacturer's aircraft/component, maintenance, overhaul, replacement, in spection, 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 comp onent parts must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature of the authorized person returning the UAS
to service.

15. Each UASs operated under this exemption must comply with all manufacturer Safety Bulletins.

16. The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections.

17. The PIC must possess at least a private pilot certificate and at least a current thirdclass 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
wi ll 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 consistent with 14 C.P.R.§ 61.51(b ). Flights for the purposes of training the operator's PICs are permitted under the terms ofthe 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

19. U AS operations may not be conducted during nigh t, as defined in 14 C .F .R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a specialrequest will be made at the FAA office closest to proposed area of operations. Flights under specia l visual flight rules (S VFR) 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
obtai ned, and the operation is conducted in accordance with a NOT AM as required by the operator's COA. The letter of agreement with the airport management must be made available to the Administrator upon request.

21. The UA may not be operated less than 500 f eet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating a rea 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 flig ht unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 25% battery power remaining.

25. The operator must obtain an Air Traffic Organization (AT O) issued Certificate of 20 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 (NOT AM) not more than 72 hours in advance, but
not less than 4 8 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requirements.

26. All aircraft operated in accordance wi th the exemption must be identified by serial number, registered in accordance with 14 C.P.R. part 47, and have identification (N

- Number) markings in accordance with 14 C.P.R. part 45, Subpart C. Markings must be as large as practicable.

27. Before condu cting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.

28. The documents required fewer than 14 C. P.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

29. The UA must remain clea r and yield the right of way to all manned aviation operations and activities
at all times.

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

31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UAand/or debris in the event of a n accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures where 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 determi ned 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 controll ed

- 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 oper ation 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 hours. Accidents must be reported to the National Transportation Saf ety 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.

Florida Drone Worx, Inc. s ubmits 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 UASs 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, or 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 Florida Drone Worx, Inc.'s proposed area of operations, and the operating limitations set
forth

- above; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exe mption No. 11 062); and the airmanship skills necessary to safely operate the DJI Phantom 3, or DJI Inspire 1 UAS, Florida Drone Worx, Inc. submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for Florida Drone Worx, Inc.'s specific proposed flight operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those present ed herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

Florida Drone Worx, Inc. will not allow any PIC to operate the DJI Phantom 3, or DJI Inspi re 1 UAS unless that PIC has demonstrated, by meeting minimum flight

- hour requirements or the DJI Phantom 3, or DJI Inspire 1 UAS training and currency requirements, that the PIC is able to safely operate the DJI Phantom 3, or DJI In spire 1 UAS 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 manner cons istent with 14 C.P.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as aUAS pilot operating the same make and model of UAS to be used for operations under the exemption). In addition to the hour req uirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes).

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 Florida Drone Worx, Inc.' proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51 (b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi

- rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the s ame make and model of UAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi

- ro tor time and the 10 hours may be included in the total25 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 obtain ed in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience

- building flights can also be conducted under the grant of exemption to accomplish the required flight time. 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, Florida Drone Worx , Inc. will ensure safe operations by not allowing any PIC to operate the Dll Phantom 3, or Dll 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, or DJI Inspire 1 UAS
in a manner consistent with the exem ption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety.

The equivalent lev el of safety established by Section 91.7(a) will be maintained because prior to every flight, Florida Drone Worx, Inc. will ensure that the DJI Phantom 3, or 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) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 1 1062, 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 equivalen t 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 will be provided to the PIC via GPS equipment and a radio communications telemetry data link, which downlinks fr om the UA to the GCS for active monitoring of the flight path and altitude. This altitude information, combined with Florida Drone Worx, Inc.' operation of the DJI Phantom 3, and DJI Inspire 1 UAs within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically established by the UASs at ground le vel.

The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

5. Reasons Why An Exemption From The Requirements Of Section 91.15l(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 UASs; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, Florida Drone Wo rx , Inc. will ensure that it will safely operate the battery powered DJI Phantom 3, and DJI Inspire 1 UAs during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 3, and DJI Inspire 1 UASs; the limitations on the proposed flight oper ations; and the location of the proposed operations, will ensure an equivalent level of safety established by 14 C.P.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Phantom 3, and DJI Inspire 1 UASs provide audible and visual warnings to the PIC at the GCS when the UAs experiences low battery voltage, the first warning occurring at approximately 33% 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 UASs will descend and land automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations of the UA S are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160 , 11161).6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety.

In seeking this exemption, Florida Drone Worx, Inc. 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)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) will be met because Florida Drone Worx, Inc. will use trained technicians to p erform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., the Florida Drone Worx, Inc. Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3, and DJI Inspire 1 Instruction Manual). Furthermore, Florida Drone Worx, Inc. will document and maintain all maintenance records for the DJI Phantom 3, and DJI Inspire 1 UASs.

Since the DJI Phantom 3, and DJI Inspire 1 UASs will be inspected as prescri bed by the operating documents, Florida Drone Worx, Inc. 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 User Manuals
are attached hereto as Exhi bit C, and D; a copy of the DJI Phantom 3, and DJI Inspire 1 UAS Maintenance
LOG is attached hereto as Exhibit E.

Likewise, the exemption sought will not adversely affect safety because Florida Drone Worx, Inc. will use trained technicians to perform main tenance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed by the operating documents. Furthermore, the exemption sought would maintain an equivalent level of safety established by Sections 91.407,
91. 417(a) and 91.417(b), because all maintenance of the DJI Phantom 3, and DJI Inspire 1 UASs will be performed by trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log.

Significantly, previous exemptions gr anted by the FAA concerning Sections 91.405(a), 91.407(a)(l), 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 U AS are considered.

In considerat ion of Florid Drone Worx, Inc.'s proposed operating limitations, the operating documents, and the technical aspects of the DJI Phantom 3, and DJI Inspire 1 UAS's, Florida Drone Worx, Inc. submits that safety will not be adversely affected by granting exemp tion from 14 C.F.R. Sections 91.405(a), 91.407(a)(l) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted relief specific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos.

1 1062, 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 ofthe FAA Modernization and Reform Act of2012 (FMRA) and 14 C.F .R. § 21.16 entitled Special Conditions, Florida Drone Worx , Inc. requests that the FAA prescribe special conditions for the intended operation of the DJI Phantom 3, and DJI Inspire 1 UASs, which contain such safety sta ndards that the 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 9 1.417(a) & (b). Such special conditions will permit safe operation of the UAs for the limited purpose of conducting aerial video and photography overcertain 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 re quirements 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 UASs, since the airworthine ss 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. Section 21.16, entitled Special Conditions, states the following: If the FAA finds that the
airworthin ess 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, he prescribes special cond itions 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 as the FAA finds necessary to establish a level of safety equivalent to that established in the regulations.

See 14 C.P.R. § 21.16. Therefore, in accordance with FMRA Section 333 and 14 C.P.R.§ 21.16, the FAA may prescribe special conditions for Florida Drone Worx 's intended operation of the DJI Phantom 3 , and DJI Inspire 1 UASs, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.P.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.1 5l(b), 91.405(a), 91.407(a)(1), 91.409(a)(l) & (a)(2), and 91.417(a) & (b).

E. A Summary That Can Be Published In The Federal Register, Stating: The Rules From Which Florida

Drone Worx , Inc. Seeks Exemption:

Florida Drone Worx, Inc. seeks exemption from the requi rements 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 Florida Drone Worx, Inc. Seeks:

This exemption will permit Fl orida Drone Worx, Inc. to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the
United States.

Any Additional Information, Views, Or Arguments Available To Support Flori da Drone Worx, Inc.'s Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. As such, Florida Dron e Worx, Inc.'s request for exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.P.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, Florida Drone Worx, Inc. will operate the DJI Phantom 3, and DJI Inspire 1 UASs safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.

## Conclusion
As set forth herein, Florida Drone Worx, Inc. seeks an exemption pursuant to 14 C.P.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 ph otography over certain areas of United States, By granting this petition the FAA administrator will be fulfilling the congressional mandate of the FAA Modernization and reform 27 act of2012, while also advancing the interests of the public, by allowing
Flo rida Drone Worx, Inc. to safely efficiently and economically operate the DJI Phantom 3,and DJI Inspire 1 UASs commercially whithin the NAS.

Wherefore, in accordance with the Federal Aviation Regulations and the FAA Modernization and reform act of2012, Sec tion 333 Florida Drone Worx, Inc. respectfully requests that the administrator grant this petition for an example from the requirements of 14 C.P.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 Florida Drone Worx, Inc. to operate the DJI Phantom 3, and DJI Inspire 1 UASs commercially for the purpose of conducting aerial video and photography over certain areas of the United States.

November 18, 2015

Respectfully Submitt ed

Florida Drone Worx, Inc.

Stefan Muehlbauer, Owner

2316 Pine Ridge Rd #383 Naples, FL 34109 Telephone: (239) 248

- 0460

Appendices

A. DJI Phantom 3 Specifications Data Sheet

B. DJI Inspire 1 Specifications Data Sheet

C. DJI Phantom 3 Manufacturer's User M anual

D. DJI Inspire 1 Manufacturer's User Manual

E. Monthly Maintenance LogAppendix

– A

DJI PHANTOM 3 TECHNICAL SPECIFICATIONS

Florida Drone Worx, Inc. only utilizes safe and reliable UASs. DJI is an industry leader in small UAS production. DJI UASs are l oaded 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 predete rmined and set distance. In addition, DJI software provides real

- time altitude and location information to the PIC via the linked monitor (smart phone/tablet devices)

1.2 DJI Phantom 3

1.2.1 Aircraft

1.2.1.1 Supported Battery

- DJI 4480mAH LiPo Battery

1 .2.1.2 Weight (Battery & Propellers Included)

- 2lbs 13.15oz (1280g) 1.2.1.3 Hover Accuracy (Ready to Fly)

- Vertical: +/

- 0.1 m (when Vision Positioning is active) or+/

- 0.5 m; Horizontal: 1.5m 1.2.1.4 Max Yaw Angular Velocity

- 200°/s
1.2.1.5 Max Tilt An gle

- 35° 1.2.1.6 Max Ascent Speed

- 5m/s 1.2.1. 7 Max Descent Speed

- 3m/s 1.2.1. 8 Max Flight Speed

- 15m/s (NOT RECOMMENDED)

1.2.2 Gimbal

1.2.2.1 Control Accuracy

- ±0.03° 1.2.2.2 Controllable Range

- Pitch:

- 90° + 30° 1.2.2.3 Maximum Angular Speed

- P itch: 90°/s 1.2.3 Camera 1.2.3.1 Operating Temperature Range

- 32°F

- 104°F (0°C

- 40°C)
1.2.3.2 Sensor Size

- 1/2.3"
1.2.3.3 Effective Pixels

- 12.4M
1.2.3 .4 Resolution

- 4000x3000 1.2.3.5 UltraHD Video Recording

- 4096x2160p 24/25, 3840x2160p 24/25/30

1.2 .3.6 Recording Field ofView

- 94°@20mm

1.2.4 Transmitter

1.2.4.1 Operating Frequency

- 2.400GHz

- 2.483GHz 1.2.4.2 Communication Distance (unobstructed)

- FCC Compliance: 2000m 1.2.4.3 Receiver Sensitivity (2%PER)

- - 101dBm
1.2.4.4 Transmitter Power

- FCC C ompliance: 20dbm 1.2.4.5 Working Voltage

- 1.2 A @7.4 VAppendix

– B

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

Florida Drone Worx, Inc. only utilizes safe and reliable UASs. DJI is an industry leader in small UAS production. DJI UASs are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. 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 dis tance. In addition, DJI software provides real

- time altitude and location information to the PIC via the linked monitor (smart phone/tablet devices)

2.2 DJI Inspire

2. 2.1 Aircraft

2.2.1.1 Model

- T600 2.2.1.2 Weight (Battery Included)

- 6lbs 7.5291oz (29 35g) 2.2.1.3 Hovering Accuracy (GPS Mode)

- Vertical: 0.5m; Horizontal: 2.5m 2.2.1.4 Max Angular Velocity

- Pitch: 3000/s; Yaw: 1500/s 2.2.1.5 Max Tilt Angle

- 350 2.2.1.6 Max Ascent Speed

- 5m/s 2.2.1.7 Max Descent Speed

- 4m/s 2.2.1.8 Max Speed

- 22rn/s (ATTI mode, no wind

- NOT RECOMMENDED) 2.2.1.9 Max Flight Altitude

- 4500m
2.2.1.10 Max Wind Resistance

- 10m/s 2.2.1.11 Max Flight Time

- Approximately 18 minutes
2.2.1.12 Motor Model

- DJI 3510 2.2.1.13 Propeller Model

- DJI 1345 2.2.1.14 Operating Temp erature Range

- 140F to 1040F (

- 100C to 400C)
2.2.1.15 Dimensions

- 17 V4" x 17 314" x 12"

2.2.2 Gimbal

2.2.2.1 Model

- ZENMUSE X3 2.2.2.2 Output Power (with camera)

- Static: 9W; In Motion: 11 W 2.2.2.3 Operating Current

- Static: 750mA; In Motion: 900mA 2.2.2.4 Angular Vibration Range

- ±0.030 2.2.2.5 Mounting

- Detachable 2.2.2.6 Controllable Range

- Pitch:

- 900 to +300; Pan: ±3200 2.2.2.7 Mechanical Range

- Pitch:

- 1250 to 450; Pan: ±3300 2.2.2.8 Max Controllable Speed

- Pitch: 1200/s; Pan: 1800/s

2.2.3 Camera

2.2.3.1 Name

- X3
2.2.3.2 Model

- FC350
2.2.3.3 Total Pixels

- 12.76M
2.2.3.4 Effective Pixels

- 12.4M2.2.3.5 Image Max Size

- 4000x3000 2.2.3.6 ISO Range

- 100

- 3200 2.2.3.7 Field of View

- 940 2.2.3.8 CMOS

- Sony EXMOR 112.3"
2.2.3.9 HD Video Recor ding

- UHD(4K): 32 4096x2160p24/25, 3840x2160p24/25/30; FHD: 1920xl080p24/25/30/48/50/60; HD: 1280x720p24/25/30/48/50/60 2.2.3.10 Operating Temperature Range

- 320F

- 1040F (OOC

- 400C)

2.2.4 Transmitter

2.2.4.1 Name

- Cl 2.2.4.2 Operating Frequency

- 5.728

- 5 .850GHz; 2.400

- 2.483GHz 2.2.4.3 Communicating Distance (unobstructed)

- 2000m 2.2.4.4 Output Power

- 9W 2.2.4.5 Operating Temperature Range

- 140F to 1040F (

- lOOC to 400C) 2.2.4.6 Battery

- 600mAh LiPo 2S

APPENDIX

- C

DJI PHANTOM 3 Manufacturer's User Manu al

User manual can be found at:

http://www.dji.com/product/phantom

- 3/download

APPENDIX

- D

DJI Inspire 1 Manufacturer's User Manual

User manual can be found at:

http://www.dji.com/product/ins pire

- 1/downloadAppendix

– E

Monthly Maintenance Log

Monthly Maintenance Log

UAS: Month: Year:

Maintenance Performed by:

Date Issue Discovered Date Issue Addressed Issue Description & Maintenance Conducted Print Name Signature Software Updates
Airframe Engines Propellers
Camera Gimbal Landing Gear Vibration Dampening
Other: