Monday, November 30, 2015

Attn:

U. S. Department of Transportation Docket Operations

West Building Ground Floor, Room w12

- 140

1200 New Jersey Ave, SE Washington, DC 20590

RE: Austin Brown dba. GLOBAL AIR MEDIA, LLC

R EQUEST AN EXEMPTION FROM THE REQU I REMENTS OF T I TLE 14 OF THE CODE

OF FEDERAL REGULATIONS SECT I ONS 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

COMMERC IAL OPERATION OF D J I Phanto m 3 UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF The FAA Modernization and Reform Act of 2012 (Public

Law 112

- 95)

Austin Brown

CEO , Global Air Media, LLC

33 S. Highland Ave., Baltimore, MD 21224

410

- 504

- 2369

info@globalairmedia.comG LOSSARY OF ABBREVIATIONS

AG L Above Ground Level

AO I Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

A V Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FA A Federal Aviation Administration

FA R Federal Av iation Regulation

GCS Ground Control Station

GPS Global Positioning S y stem

LOL Loss of Link

NA S National Airspace S y stem

NOTAM Notice to Airman

P I C Pilot I n Command

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

S O Safety Observer

SOP Standard Operating Procedur e s

U A Unmanned Aircraft

UA S Unmanned Aircraft S y stem

VF R Visual Flight Rules

VLOS Visual L ine of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and LandingSUMMARY

Austin Brown dba. GLOBAL AIR MEDIA, LLC hereafter refe rred to as The GLOBAL AIR

MEDIA, 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 S y stem (D J I Phantom 3 Pro) pursuant to Section 333 of

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

GLOBAL AIR MEDIA, LLC t o operat e a n Unmanne d Aircraf t S y ste m (UAS ) fo r th e

commercia l purpos e of conducting aerial vi deo and photograp h y o f construction sites, residential

and commercial real estate, civil landscap e s and events over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

The staff at GLOBAL AIR MEDIA, LLC has over 10 years of e xperience in providing private,

commercial, and government clients with expertise and knowledge in project management

, multi medi a marketin g

, general contracting and training using advanced technologies and

solutions. GLOBAL AIR MEDIA’s experienced staff ha s worked on hundreds of various

projects over the past 10 years in all t y p e s o f industries with a perfect client and emplo y ee safe t y

record. GLOBAL AIR MEDIA, LLC will offer professional and innovative aerial photography,

mapping, surveying, and inspection services by use of Unmanned Aerial Systems (UAS). As we

intend to serve a wide range of clients from governmental, commercial, public, and residential,

our mission is to improve safety and efficiency for each client while providing the highest quality

end product. Areas we will be specifically targeting include:

• Construction

• Aerial Mapping and Surveys

• Real

- estate marketing

• Economic development

• Photography and Film

• Agriculture

• Private and governmental train ing

The staff has safel y flown the DJI Phantom Pro 3 electric quadcopters recreationally for

approximately 2 years without incident

.

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 3 Pro, UAS

The GLOBAL AIR MEDIA, LLC seeks an exemption to operate D J I Phantom 3 Pro s y stem for

compensation or hire wit hin the NAS. The DJI Phantom 3 Pro i s vertical takeoff and landing

(VTOL) Unmanned Aircraft (UA ) with a Ground Control Station (GCS ) utilizing electronic

tablet or smart phone s y stems. The DJ I P hantom 3 Pro has a maximum gros s w eight o f

approximately 2.8 lb. while having a diagonal dimension of 23.2 ”

, a maximu m speed of

approximately 16.4’fps and a maximu m fl y in g height o f 400 '

. The D J I Phantom 3Pro i s equipped

with four main rotors; driven by L ithiu m Pol y me r batter y powered electric motors.The D J I Phantom 3 Pro that will be operated b y The GLOBAL AIR MEDIA, LLC will be

registered in accordance with 49 U.S.C. 44103, Registration o f 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

Registra t ion Marking

.

BASIS FOR PETITION

Petitioner, The GLOBAL AIR MEDIA, LLC pursuant to the provisions o f the Federal Aviation

Regulations (14 C.F.R. § 11.61) and th e FAA Modernizat ion and Reform Act of 2012 (FMRA),

Section 333, Special Rules for Certain Unmanned Aircraft Systems

, here b y petitions the

Administrator to commercially operate the D J I Phantom 3 Pro, UA S in the National Airspace

S y stem (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).

I n consideration of th e speed, weight, size, and limited operating area associated with the

unmanned aircraft and it s operation, The GLOBAL AIR MEDIA, LLC operation of D J I

Phantom 3Pro UA S meets the conditi on s o f FMR A Sectio n 33 3 and therefore

, wil l no t requir e

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

According l y

, The GLOBAL AIR MEDIA, LLC requests relief from Sections 91.405(a),

91.407(a)(1), 91.409(a)(1 ) & (a)(2)

, an d 91. 4 17(a ) & (b)

, a s thes e section s se t fort h requirements

for maintenance that only app l y to aircraft with an airworthiness certificate.

The GLOBAL AIR MEDIA, LLC submits that the requested relief is proper since an

equivalent level of safe t y will be ensured. The GLOBAL AIR MEDIA, LLC will use

experienced personnel or technicians to perform maintenance, alterations, or preventive

maintenance on the UAS us ing the methods, techniques, and practices prescribed in the operating

documents (i.e., Monthly Maintenance L o g

, a nd DJ I P hantom 3 Pro I nstruction Manual).

Furthermore, The GLOBAL AIR MEDIA, LLC will document and maintain all maintenance

records for the DJ I Phantom 3 Pro UAS.

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

and limitations: Pilot in command

, is requested b y The GLOBAL AIR MEDIA, LLC to the

extent necessary t o allo w a Pilo t i n Comman d (P I C) ho lding a private pilot or higher level

certificate, as well as an airman medical certificate, and who ha s demonstrated, b y m eeting

minimum flight

- hour and currenc y r equirements

, tha t th e P I C i s abl e t o safel y operat e th e DJI

Phantom 3 Pro UAS i n a manner consistent with this exemption, including evasive and

emergenc y maneuvers and maintaining appropriate distances from people, vessels, veh i cles and

structures.

The GLOBAL AIR MEDIA, LLC seeks relief from Section 91.7(a), entitled Civil aircraft

airworthine ss

, becaus e the DJI Phantom 3 Pro UAS do not require an airworthiness certificate in

accordance with 14 C.F.R. Part 21, Subpart H. As such, The GLOBAL AIR MEDIA, LLC

submits that the y will ensure tha t the DJI Phantom 3 Pro UAS is in an airwort h y condition

, prior

to every flight, b y determining tha t the UA S are in compliance with the operating documents(i.e., Monthl y Maintenanc e Log

, and D J I Phantom 3 Pro Instruction Manual)

, an d tha t th e

aircraft are in a condition for safe flight. The GLOBAL AIR MEDIA, LLC also seeks an

exemption from the requirements of Section 91.121, entitled Altimeter Settings

, as the D J I

Phantom 3 Pro UA S will not hav e a t y pical barometric altimeter onboard. However, altitude

information of the DJI Phantom 3 Pro UAS wi ll be provided to the P I C via Global Positioning

S y stem (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 The GLOBAL AIR M EDIA‘s co operation of the DJI Phantom 3 Pro UAS within visual

line of sight, at o r below 400 fee t AGL, will ensure a level of safe t y equivalent to Section

91.121.

Additionall y , The GLOBAL AIR MEDIA, LLC seeks an exemption from the requirements of

Section 91.151(b), entitled Fuel requirements for flight i n VFR conditions . The GLOBAL AIR

MEDIA, LLC submits that safety w il l not be affected b y operation o f the DJI Phantom 3 Pro

UAS during da y light hou r s in visual meteorological conditions (VMC) under visual f light rules

(VFR), with enoug h batter y power t o fl y f o r a total duration of approximately 23 minute s.

B atter y power indicators are also able t o show exactl y h o w much batter y p owe r is left, as

well as ho w much time is needed to return safe l y back to point of takeoff.

I n accordance with 14 C.F.R. § 11.81, The GLOBAL AIR MEDIA, 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:

Austin Brown

CEO, Global Air Media , LLC

33 S. Highland Ave., Baltimore, MD 21224

410

- 504

- 2369

info@globalairmedia.com

B. The Specific Sections of 14 C.F.R. From Which The GLOBAL AIR MEDIA, LLC

Seeks Exemp tion.

1. The GLOBAL AIR MEDIA, 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 hold s a private pilot certificate ma y a ct as a pilot in command

(P I C) o f an aircraft that is carr y ing passengers o r proper t y for compensation or hire;

nor may that person, for compensation or hire, act as P I C of an aircraft.(b) A p rivate pilot ma y

, for compensation o r hire, act as P I C of a n aircraft in

connection with a n y business or empl o y m ent i f

—

(1) The flight is only incidental to that business or emplo y ment; and

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

2. The GLOBAL AIR MEDIA, LLC 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.

3. The GLOBAL AIR MEDIA, 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 maintai n the cruising altitude or flight level

of that aircraft, as the case ma y be, b y r eference to an altimeter that i s set, when

operatin g

--

(1) Below 18,000 fee t MS L , to

--

(i) The current reported altimeter setting of a station alon g the route and

within 10 0 nautical miles of the aircraft;

(ii) I f there is n o station within the area prescribed in paragraph (a)(1)(i) of

this section, the current reported altimeter setting o f a n appropriate available

station; or

(iii) I n the case of an aircraft not equipped with a radio, the elevation of the

departure airport or a n appropriate altimeter setting available before

departure.

4. The GLOBAL AIR MEDIA, LLC Seeks Exemption from the Requirements of Section

91.151(b).

Section 91.151, entitled Fuel req uirements for flight in VFR conditions , subsection

(b), states the following:

( b ) No person may begi n 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 o f intended landing and, assuming norma l cruising speed, to fl y after that

for at least 20 minutes.

5. The GLOBAL AIR MEDIA, LLC Seek s Exemption from the Requirement of Se c tion

91.405(a).Section 91.405, entitled Maintenance required

, subsection (a)

, sta tes th e 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 inspect ions, except as provided in paragraph (c) of thi s section,

have discrepancies repair ed as prescribed in part 43 of this chapter[.]

6. The GLOBAL AIR MEDIA, LLC Seeks Exemption from the Requirements of Section

91.407(a)(1)

Section 91.407, entitled Operation afte r maintenance, preventive maintenance,

rebuilding, or alteration

, subsection (a)(1), states the following:

(a ) No person ma y operate a n y aircraft that has undergone maintenance, preventive

maintenance, rebuilding, or alteration unles s

--

(1) I t has b e en approved for return to service b y a person authorized unde r § 43.7

of this cha pter [.]

7. The GLOBAL AIR MEDIA, LLC Seeks Exemption from the Requirements of Sections

91.409(a)(1) and 91.409(a)(2).

Section 91.409, entitled Inspections , subsection (a), stat e s the following:

(a ) Except as provided in paragraph (c ) of this section, n o person ma y 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 ha s been

approved for return to service by a person authorized by § 43.7 of this chapte r; or

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

with part 21 of this chapter.8. The GLOBAL AIR MEDIA, LLC Seeks Exemption from the Requiremen t s of Sections

91.417(a) and 91.417(b).

Section 91.417, entitled Maintenance record s

, subsections (a) and (b), state the

following:

(a ) Excep t for work performed in accordance with §§ 91.411 and 91.413, each

registered owner or operator shall keep the following records for the periods specified

in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alter ation and

records of th e 100

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

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

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

--

(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 aircraf t

for return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, eac h engine

, each propeller, and

each rotor.

(ii) The current status of lif e

- limited parts of each airframe, engine, propeller,

rotor, and applian c e.

(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 inspecti on required b y t h e inspection program under which th e aircraft

and its appliances are maintained.

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

directives including, fo r each, the method o f compliance, the A D or safety

dir ective number and re vision date. I f the A D or safe t y directive involves

recurring action, the time and date when the next action is required.

(vi) Copies of the forms prescribed b y § 4 3.9(d ) of this chapter for each

major alteration to th e airframe and cu rrent l y installed engines, rotors,

propellers, and appliances.(b) The owner o r operator s hall retain the following records for the periods

prescribed:

(1) The records specified in paragraph (a)(1) o f thi s section shall be retained until

the work is repeated o r superseded b y other wor k or for 1 y e a r after the work is

performed.

(2) The records specified in paragraph (a)(2) o f thi s 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 re tained until the defects ar e repaired and the aircraft is

approved for return to service.

C. The Extent of Relief the GLOBAL AIR MEDIA, LLC Seeks and the Reason the

GLOBAL AIR MEDIA, LLC Seeks the Relief.

1. Extent O f Relief Th e GLOBAL AIR MEDIA, LLC See k s And The Reason The

GLOBAL AIR MEDIA, LLC Seeks Relief From Section 61.113(a) And (b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges a n d limitations: Pilot in

command

, is requested to the extent necessary to allow a P I C holding a private pilot or higher

level certificate, a s well as a current and valid airman medical certificate, and who ha s met

certain flight

- hour and currency requiremen ts

, t o conduc t th e propose d UA S fligh t operation s 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 ma y

, for compensation or hire, act as P I C o f an aircraft i n conne c tion with a n y

business or emplo y ment if: (1) The flight is on l y incidental to that business or emplo y ment; and

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

As set forth more ful l y below, The GLOBAL AIR MEDIA, LLC submits t hat an equivalent level

of safe t y will be maintained becaus e no P I C will b e allowed to op erate the DJI Phantom 3 Pro

UAS unless that P I C ha s me t certain flight

- hour and currency r equirements, demonstrating

tha t the P I C is able to safe l y operate either the DJI Phantom 3 Pro UAS in a manner consistent

with the operations specifications as desc ribed in this exemption, including evasive and

emergency maneuvers, as well as maintaining appropriate distances from people, vessels,

vehicles and structures.

Further, The GLOBAL AIR MEDIA, LLC submit s that all flights o f th e DJI Phantom 3 Pro

UAS, condu cted b y the P I C pursuant to the grant of this Petition: (1) will be incidental to The

GLOBAL AIR MEDIA’s business; and (2) will not carry p assengers o r proper t y for

compensation or hire.2. GLOBAL AIR MEDIA, LLC Seeks Relief From Section 1.7(a).

Reli ef from Section 91.7(a ) entitled Civil aircraft airworthiness

, i s requested to the e x tent

required to allow The GLOBAL AIR MEDIA, LLC to determine that the DJI Phantom 3 Pro

UAS are in airwort h y condition prior to ever y f light b y e nsuring that the UAS is i n compliance

with the operating documents (i.e., the GLOBAL AIR MEDIA, LLC Aerial Operations Manual,

Monthly Maintenance L o g, and DJI Phantom 3 Pro Instruction Manual).

The GLOBAL AIR MEDIA, LLC seeks the requested relief because the DJI Phantom 3 Pro UAS

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

Therefore, The GLOBAL AIR MEDIA, LLC will ensure tha t the DJ I P hantom 3 Pro UA S

ar e in airwort h y condition based upon it s compliance with the operating d ocuments (i.e.,

Monthl y Maintenance L o g

, and D J I Phantom 3 Pro) prior to ever y flight, and further, determine

tha t the aircraft are in condition for safe flight, as stated in the conditions and limitations below.

3. Extent Of Relief Th e GLOBAL AIR MEDIA, LLC Seeks And The Reason The GLOBAL

AIR MEDIA, LLC Seeks Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, ma y be required to allow flight

operations o f the DJI Phantom 3 Pro UAS

, which utilize a barometric pressure sensor, GPS

equipment, and a radio communications telemetry data link to downlink altitude information

from the U A to the P I C at the groun d control s tatio n (GCS). Since the FA A requires that a n y

altitude information concerning UAS operations be re ported t o air traffic control (ATC) in feet

above groun d level (AGL), The GLOBAL AIR MEDIA, LLC seeks the requested relief because

the DJI Phantom 3 Pro UAS altimeter ma y b e set on the groun d to zer o feet AGL, rather than the

local barometric pressure or f ield altitude, before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought

t o th e exten t necessar y t o comp l y wit h th e applicabl e condition s an d limitation s state d below

. As

more full y set forth here in, an equivalent level of safe t y will be maintained since the DJI

Phantom 3 Pro UAS are equipped with a barometric pressure sensor and GP S equipment, which

automatical l y ensures tha t a ground level pressure setting will be established prior to each flight

, and provides the PIC with altitude information of the UA on the head s

- u p displa y of the GCS.

4. Extent Of Relief Th e GLOBAL AIR MEDIA, LLC Seeks And The Reason The GLOBAL

AIR MEDIA, LLC Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is

requested to the extent required t o allow flights of the batter y powered DJI Phantom 3 Pro UAS

during da y light hours i n visual meteorological conditions (VMC), under visual flight rul es

(VFR), for a total duration of 23 minutes.The GLOBAL AIR MEDIA, LLC seeks the requested relief because without an exemption

from Section 91.151(b), the flight time duration of the batter y p ow e red DJI Phantom 3 Pro

UAS will severel y constrain the practicality o f a n y aerial video or still photo flight operations

that The GLOBAL AIR MEDIA, LLC proposes to conduct pursuant to this Petition.

Significant l y

, as set fort h below, the technical specifications of the DJI Phantom 3 Pro UAS, the

D J I Phan tom 3 Pro operating documents, and The GLOBAL AIR MEDIA, LLC proposed

operating limitations, ensure that The GLOBAL AIR MEDIA, LLC will safely operate the

batter y powered DJI Phantom 3 Pro UAS during da y light hours in visual meteorological

conditions (VMC) , under visual flight rules (VFR), with enough battery power to f l y for a total

duration of 23 minutes.

5. Extent Of Relief Th e GLOBAL AIR MEDIA, LLC Seeks And The Reason The GLOBAL

AIR MEDIA, LLC Seek s Relief Fro m Sections 91.405(a), 91.407(a) (1), 91.40 9(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) on l y apply to

aircraft with an airworthiness certificate, The GLOBAL AIR MEDIA, LLC requests relief

from these Sections because the DJI Phantom 3 Pro UAS do not require airworthiness

certificates. As set forth more ful l y below, th e DJI Phantom 3 Pro UAS meet the conditions of

FMRA Section 333 for operation without an airworthiness certificat e

. According l y , The

GLOBAL AIR MEDIA, LLC w ill use trained technicians to perform maintenance, alterations, or

preventive maintenance on the UA S using the methods, techniques, and practices prescribed in

the UA S operating documents (i.e., the GLOBAL AIR MEDIA, LLC Aerial Operations Manual,

Monthl y M aintenance L o g, and DJ I P hantom 3 Pro I n struction Manual). Furthermore, The

GLOBAL AIR MEDIA, LLC will document and maintain all maintenance records for the DJI

Phantom 3 Pro UAS.

D. The Reasons Why Granting the GLOBAL AIR MEDIA, LLC Request Would Be I n

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

Granting th e present Petition will further the public interest b y a llowing The GLOBAL AIR

MEDIA, LLC to safel y

, efficientl y

, and economicall y p erform aerial video and photograp h y of

construction sites, real estate, events and civic landscape over certain areas of the United States.

Additionall y

, us e o f th e DJI Phantom 3 Pro UAS will decrease congestion of th e NAS, reduce

pollution, and provide sign i ficant benefits to the econo m y . No tab l y

, th e benefits o f The

GLOBAL AIR MEDIA, LLC proposed operation of th e DJI Phantom 3 Pro UAS will be

realized without implicating a n y privacy issues.

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

The DJI Phantom 3 Pro UAS are batte r y powered and serve as a safe, efficient, and economical

alternative to th e manned aircraft traditionally u tilize d to obtain aerial imager y

. B y r educing theamount of manned aircraft needed to perform aerial acquisitions, an exemption allowing th e use

of a DJI Phantom 3 Pro UAS would reduc e th e amount of manned aircraft in th e NAS, reduce

noise and air pollution, as well as increase the safe t y of life and proper t y in the air and on the

ground.

Furthermore, b y r educing the number of manne d aircraft op erating in the NAS, congestion

around airports caused b y a rriving and departing aircraft will be reduced. The D J I Phantom 3

Pro UA S do not require an airport to takeoff or land. L ikewise, a reduction of manned aircraft

conducting aerial video and photograp h y missions would result in fewer aircraft that must be

handle d b y a ir 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 Pro

UAS.

Conducting aerial acquisitions with the DJI Phantom 3 Pro UAS, instead of manned aircraft,

will great l y benefit the public b y drastically r educing the levels of air and nois e pollution

generated during traditional aerial video and still photograp h y flight operations. B y using

batter y p ower and electric motors, the DJI Phantom 3 Pro UAS produce no air pollution, and

is the most viable environmentally c onscious alternative to the cabin class, si x c y linder int erna l

combustion engine aircraft that ar e t y pically utilized for aerial video and photograp h y

, while

burning approximately 20

- 30 gallons pe r hour of leaded aviation fuel. The DJI Phantom 3 Pro

UAS

, while reducin g the carbon footprint o f aerial acquisitions, a lso eliminates noise pollution,

a s th e UA S are propelled b y batter y powered electric motors, rather than an internal combustion

engine.

B y using the DJI Phantom 3 Pro UAS to perform aerial acquisitions, the substantial risk to life

and proper t y in the air and on the ground, which is usually associated with traditional manned

aircraft flight operations, will b e substantially r educed o r complete l y eliminated. Aside from the

lack of flight crew members located onboard the aircraft, the DJI Phantom 3 Pro UAS (weighing

approximately 2.8 pounds a t their maximu m gross weight with diagonal dimension of 23.2

inches, and with no fuel on board), ha s less physical potential for collateral damage to life and

proper t y on the ground, and in the air, compared to the manned aircraft tha t t y picall y c onduct

si milar operations (weighing approximately 6 ,00 0 pounds with a wingspan of approximately 42

feet, a length of 34 feet, and a fuel capaci t y of 180 gallons).

3. Performing Aerial Video and Photography Operations With The DJI Phantom 3 Pro

UAS Will Benefit The Economy.

I n a ddition to being saf e and efficient, th e DJ I P hantom 3 Pro UA S are also an

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

operation of the DJI Phantom 3 Pro UAS will allo w United States based companies, like The

GLOBAL AIR MEDIA , LLC t o remai n competitiv e an d contribut e t o growt h o f th e U.S

.

econom y . Specifical l y, with the rising cost of aviation fuel and the Environmental Protection

Agenc y (“EPA”) regulatory actions phasing out le ad e d aviation fuels, U.S. owned and operatedcompanies must adopt new and alternative technology in order to remain competitive.

Operating th e batter y powered DJI Phantom 3 Pro UAS is on e such technology t ha t not onl y

a llows companies greater operat ional flexibil it y c ompared to manned aircraft, bu t provides

such flexibilit y without the high operational cost of a traditional manned aircraft.

B y operating the DJI Phantom 3 Pro UAS, companies such as The GLOBAL AIR MEDIA , LLC

can remain comp etitive and profitable, and the r efore, provide greate r job stabilit y to emplo y ees

and contractors, which will ultimatel y c ontribute to growth of the U.S. economy. Improved

financial performance of U.S. companies, through commercial use of th e DJI Phantom 3 Pro

UAS

, provides a stable workfor c e 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. Th ere Are No Privacy Issues.

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

The GLOBAL AIR MEDIA ’s proposed operation of the DJI Phantom 3 Pro UA S will not

implicate an y p rivac y issues. Specificall y

, the DJI Phantom 3 Pro UAS will be operated onl y in

compliance with operating documents (i.e., th e GLOBAL AIR MEDIA, LLC Aerial Operations

Manual, Monthl y Maintenance L o g

, and D J I Phantom 3 Pro I nstruction Manual) which requires

proper t y owner involvement as well as local law enforcement notification, and in accordance

with the Federal Aviation Regulations, including th e minimum altitude requirements o f 14

C.F.R. § 91.119.

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

Ho w The Exemption Would Provide A Level Of Safety A t Least Equal To That Provided

By The Rule From Which The GLOBAL AIR MEDIA, LLC Seeks Exemption.

1. Reasons Why Th e DJI Phanto m 3 Pro UAS Mee t The Conditions Of Th e

FAA Modernization and R eform Act of 2012 (FMRA) Section 333.

I n consideration of th e size, weight, speed, and limited operating area associated with the

unmanned aircraft and its operation, The GLOBAL AIR MEDIA ’s operation o f the DJI Phantom

3 Pro UAS meet the conditions of FM RA Section 333, and will not require an airworthiness

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

Section 333 provides authorit y f or a UAS to operate without airworthiness certification and sets

forth requirements for considering whether a UAS will create a hazard to users of the NAS or the

public

, o r o therwise pos e a threa t t o nationa l securit y . Specifical l y

, FMRA Sectio n 33 3 state s the

following, in part:

( a ) In General.

-- Notwithstanding any other requirement of this subtitle, an d not l ater

than 180 days afte r the date of enactment of this Act, the Secretary of Transportation

shall determine i f certain unmanned aircraft systems may operate safely in thenational 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.

( b ) Assessment of Unmanned Aircraft Systems.

- - In making the determination under

subsection (a), the Secretary shall determine, at a minimu m

--

( 1 ) which types of unmanned airc raft systems, i f 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 o r po se 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 Sta tes

Code, is required for th e operation of unmanned aircraft system s identified

under paragraph (1).

(c ) Requirements for Safe Operation.

- - If the Secretary determines under thi s section

that certain unmanned aircraft systems may operate safely in th e natio na l airspace

system, the Secretary shall establish requirements fo r the safe operation of such

aircraft systems in the national airspace system.

I n seeking this exemption, The GLOBAL AIR MEDIA, LLC submits that the DJI Phantom 3 Pro

UAS can operate safel y in th e NAS pursuant to FMRA Section 333, as demonstrated b y : (a) the

characteristics o f th e DJI Phantom 3 Pro UAS; (b) th e pilot certification requirement; and (c) the

specific operating limitations.

a. The Specifications Of The DJI Phantom 3 Pro UAS Demonstrate Its Safe

Characteristics.

The DJI Phantom 3 Pro UAS does not create a hazard to users of the NAS or the public, or

otherwise pose a threat to national securi t y considering its size, weight, speed, and operational

capability.

i. Technical Specifications of the DJI Phantom 3 UAS.

The technical specifications o f the DJI Phantom 3 Pro UAS are set forth b y the D J I Phantom 3

Us e r Manual, attached hereto as Appendix A

.

ii. The DJI Phantom 3 Pro UAS Global Positioning Modes Enable the UAS to remain

within a defined operational area.The DJI Phantom 3 Pro UAS ma y be operated in both manual and global positioning flight

modes. A complete description of the flight and navigational modes of the DJI Phantom 3 Pro

UAS is provided at pages 11 of the D J I Phantom 3 User Manual attached hereto as Appendix A.

iii. The D JI Phantom 3 Pro UAS Are Designed For Automatic Return to Home Point

Or Hover In The Event Of Loss Of The Control Link Or Navigation.

When the Control L ink is lost, the DJI Phantom 3 Pro UAS will remain stationar y

, in flight, for

3 seconds or more. If, af ter 3 seconds, the DJI Phantom 3 Pro UAS do e s not reacquire control

link data from the GCS, the UA S will assume that the Control L ink is lost and the will return to

the home position (i.e., failsafe mode) via GPS, and will descend to the tak e off position a nd

shutdown. A complete description of the Failsa f e Functions of the DJI Phantom 3 Pro UAS

are se t forth at pages 12 through 14 of the D J I Phantom 3 Pro User Manual, attached hereto as

Appendix A

.

iv. The DJI Phantom 3 GCS and Its Operation.

A complete d escription of the operation and specifications of the DJ I P hantom 3 GCS and flight

control software i s provided at page s 23 through 29 o f the D J I Phantom 3 User Manual. D J I

Phantom 3 User Manual i s attached hereto as Appendix A

.

b. Flight O p erations Of DJI Phantom 3 Pro UAS Is Limited To The Line Of Sight

Of A Certificated Pilot in Command With A Safety Observer.

The GLOBAL AIR MEDIA, LLC video production staff will be the on l y perso ns to act as a pilot

in command (P I C) o f the DJ I P hantom 3 UA S

. Add iti onall y

, a safet y observer will assist him at

all times during flight time.

c. Flights Of DJI Phantom 3 Pro UAS Will Be Conducted Pursuant To Specific

Operating Limitations.

In seeking this exemption, The GLOBAL AIR MEDIA, LLC proposes to commercial l y ope rat e

DJI Phantom 3 Pro UAS for the special purpose of conducting aerial video and photograp h y

over certain areas of United States, pursuant to the following specific operating limitation s

.

1. Operations authorized b y this grant o f exemption will be limite d to th e f ollowing aircraft

described in the operating documents, rotorcraft UA S weighing les s than 55 pounds maximum

gros s weight: D J I Phantom 3 Pro Unmanned Aircraft Systems . Proposed operations o f

an y other aircraft will require a new petition o r a pet ition to amend this grant.

2. UAS operations unde r this exemption will be limite d to conducting operations for the

purpose of aerial video and photograp h y.

3. The U A S ma y 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 b y t he procedures specified in the operating documents unless a special request is made

and approved b y A TC. All altitudes reported to ATC must be in feet AGL.

5. The UA S must be operated within visual line of sight ( V LOS ) of th e P I C at all times.

This requires the P I C to be able to use huma n vision unaided b y a n y d evice other than

corrective lenses, as specified on the P I C’s FAA

- issued airman medical certificate.

6. T he use of first perso n view ( FPV) b y the P I C or safe t y observer (SO) is not permitted.

7. All operations must utilize a safety observer (SO). The SO ma y b e used to satisfy the VLOS

requirement a s long as th e P I C a lwa y s maintain s VLOS capabilit y

. T h e SO and P I C must b e able

to communi cat e verbal l y a t all times. Electronic messaging or texting is not permitted during

flight operations. The P I C must be designated before the flight and cannot transfer his o r her

designation for th e duration o f th e flight. The P I C must ensure that th e SO c an perform the

functions prescribed in the operating documents.

8

. Th e S O mus t no t perfor m an y othe r dutie s beyon d assistin g th e P I C wit h seein g and avoiding

other air traffic and other ground base d obstacles/obstructions and i s 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 t o the Administrator upon request

. I f a

discrepancy e xist s between the condition s and limitations contained in th e grant of exemption and

the procedures outlined i n the operating documents, the conditions and limitations contained in th e

grant of exemption take precedence and mus t b e followed. Otherwise, th e operator must follow

the p rocedures as outlined in it s operating documents. The operator ma y update or revise its

operating documents. I t is the operator’s responsibility to track such revisions and present updated

and revised documents to the Administrator upon request. The operat or must also present updated

and revised documents if i t petitions for e x tension or amendment to th e grant of exemption. I f the

operator determines that a n y update or revision would affect the basis upon which the FAA

granted the exemption, then the operat or must petition for amendment to its grant of exemption.

The FAA’s UAS Integration Office (AF S

- 80) ma y be contacted if questions arise regarding

updates or revisions to th e operating documents.

10. Prior to each flight the PIC must inspect the UAS to ens ure that it is in a condition for safe

flight. I f the inspection reveals a condition that affects th e safe operation of the UAS, the aircraft

is prohibited from operating until the necessary maintenance has been performed and the UAS i s

foun d t o b e i n a co nditio n fo r saf e flight

. The Ground Control Station must b e included in the

preflight inspection. All maintenance and alterations must be properly documented in the aircraft

records.

11. An y UAS that has undergone maintenance or alterations that affect th e UAS operation or

flight ch a racteristics, e.g. replacement of a flight critical component, must underg o a

functional test flight. The P I C wh o conducts the functional test flight must make an entry in the

aircraft records.12. The pr e

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

components, items, or equipment, no t alrea d y covered in the relevant sections of the operating

documents.

13. The operator mus t follow the UAS manufacturer’s aircraft/component, maintenance, o verhaul;

replacement, inspection, and life limit requirements.

14. The operator must car r y out its maintenance, inspections, and record keeping requirements, in

accordance with the operating documents. Maintenance, inspection, alterations, and status of

re placement/overhaul component p a rts must be note d in the aircraft records, including total time

i n service, description o f work accomplished, and the signature of the authorized person

returning the UAS to service.

15. Eac h UA S operated under this exemptio n must compl y with all manufact urers Safety

Bulletins.

16. The authorized person must make an entr y in the aircraft record o f the corrective action taken

against discrepancies discovered between inspections.

17

. Th e P I C must possess at least a private pi lot certificate and at least a c urrent third

- class

medical certificate.

18. The operator ma y not permit a n y P I C to operate unless the PI C meets the operator’s

qualification criteria and demonstrates the abilit y to safe l y operate the UA S i n a manne r

consi sten t wit h ho w th e UA S wil l b e operated under the exemption, including evasive and

emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and

structures. PI C qualification flight hours must be logged in a manner consisten t with 1 4 C.F.R. §

61.51(b). Flights for the purposes of training the operator’s P I Cs are permitted under th e

terms o f th e exemption. However, training operations ma y on l y b e conducted during dedicated

training sessions. During training, profici enc y

, an d experienc e

- building flights, all persons not

essential for flight operations ar e considered nonparticipants, and th e P I C must operate the

U A with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119.

19. UAS operations may not be conducted during night, as def ine d i n 1 4 C.F.R

. § 1.1. All

operations must be conducte d under visual meteorological conditions (VMC). If flight at night is

required, a special request will be made at the FA A office closest to proposed area of operations.

Flights under special visual fli gh t rules (SVFR) ar e not authorized.

20. The U A ma y not operate within 5 nautical miles of a n airport reference point as denoted on a

current FAA

- published aeronautical chart unless a letter of agreemen t with that airport’s

management is obtained, and the operation is conducted in accordance with a NOTAM as required

b y t he operator’s COA

. The letter of agreement with the airport management must be made

available to the Administrator upon request.

21. Th e U A ma y not b e operated less than 500 fee t below o r less than 2,000 feet horizontally

from a cloud or when visibility is less than 3 statute miles from the P I C.22. I f th e U A loses communications or loses its GPS signal, i t must return to a pr e

- dete rmined

location withi n the planned operating area and land o r b e 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 P I C is prohibited from beginning a flight unless (co nsidering wind and forecast weather

conditions) there is enoug h power to fl y a t normal cruising speed to the intended landing point

and land the UA with 25% battery power remaining.

25. The operator must obtain an Air Traffic Organization (ATO ) issued Certificate of Waiver or

Authorizatio n (COA ) prio r t o conductin g an y operation s unde r th e gran t of exemption. This COA

will also require the operator to request a Notice to Airman (NOTAM) not more than 7 2 hours in

advance, bu t not less than 48 hours prior to the operation. All operations shall be conducted in

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

altitude level and potential transponder 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

o f th e U A must compl y with th e 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 b e available to the P I C

at th e Groun d Control Station of the UA S a n y time th e UAS is operating. These documents

must be made available t o the Administrator or an y law enforcement o fficial upon

request.

29. The U A must remain clear and y i el d the right o f wa y to all manned aviation operations and

activities at all times.

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

31. Flight operations must be cond ucted a t least 500 fee t from all nonparticipating persons

(persons other than the P I C, SO, operator trainees or essential persons), vessels, vehicles, and

structures unless:

a. Barriers or structures ar e present that sufficiently protect nonparticipating

persons from the U A and/or debris in the event of an accident. The operator

must ensure that nonparticipating persons remain under such protection. I f 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 nea r vessels, vehicles or structures where the

owner/controller o f such vessels, vehicles o r structures ha s granted permission and

the P I C has made a safety a ssessment of t he risk of operating closer to those

objects and determined that it does not present an undue hazard, and;

c. Operations nearer to the P I C, SO, operator trainees or essential person s do not

present an undue hazard to those persons per § 91.119(a).

32. Al l operations shall be conducted over private or controlled

- access property w ith permission

from the land owner/controller or authorized representative. Permission from land

owner/controller or authorized representative will be obtained for each flight to b e conducted.

33. An y incident, accident, or flight operation tha t transgresses the lateral or vertical boundaries of

the operational area as defined by th e applicabl e CO A mus t b e reported to the FAA's UAS

Integration Office (AF S

- 80 ) within 24 hours. Accid ents must be reported to the National

Transportation Safet y B oard (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.

The GLOBAL AIR MEDIA, LLC submits that the equivalent level of safe t y established b y

Section

61.113(a) and (b) wil l b e maintaine d becaus e n o PI C wil l b e allowe d t o operat e th e D J I Phantom

3 UA S unless that P I C has demons trated, b y meeting minimum flight

- hour and currency

req uirements, that th e PIC is able to safe l y operate th e D J I Phantom 3 UAS in a manner

consistent with the exemption, including evasive and emergency maneuvers and maintaining

appropriate distances from people, vessels, vehicles and structures.

Considering T h e GLOBAL AIR MEDIA, LLC proposed area of operations, and the operating

limitations set forth

- above; the parallel nature of private pilot aeronautical knowledge

requirements to those of commercial pil ot requirements ( See Exemption No. 11062); and the

airmanship skills necessary to safe l y operate th e D J I Phantom 3 Pro UAS

, The GLOBAL AIR

MEDIA, LLC submits that the additional manned airmanship experience of a

commercially certificated pilot wo uld no t correlate to th e airmanship skills necessary f or The

GLOBAL AIR MEDIA, LLC 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 respect s, t o those presented herein (e.g. Exemption Nos.

11062

, 11063

, 11064

, 11065

, 1 1066

, 11067

, 11080

, 11109

, 11110

, 11112

, 11136

, 11138

, 11150,

11153, 11156, 11158, 11159, 11160, 11161).

The GLOBAL AIR MEDIA, LLC will not allow an y P I C to operate th e DJI Pha ntom 3 Pro UAS

unless that P I C has demonstrated, b y meeting minimum flight

- hour requir e ment s or the D J I

Phantom 3 Pro UAS training and currency requirements, that the P I C is able to safely operate theD J I Phantom 3 UAS in a manner consistent with this e x emption, including evasive and

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

structures.

Specifical l y, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. §

61.51(b), 25 hours o f total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those

hours as a UAS pilot operating the same make and model of UAS to be used for operations under

the exemption). I n a ddition to the hour requirements, the P I C must accomplish 3 takeoff s and

landings in the preceding 90 da y s (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 safe t y

during The GLOBAL AIR MEDIA, LLC proposed operations. The Administrator has held that

prior documented f l i g ht experience tha t was obtained in compliance with applicable regulations

would ensure safe operations, stating as follows:

I n Exemption No. 11062, the FA A required tha t prior to conducting operations for the

purpose of motion picture filming (or similar operations), the P I C must have accumulated

and logged, i n a manner consistent with 14 CF R 61.51(b), 2 5 hours o f tota l time a s a

UAS rotorcraft pilot includi ng a t least 10 hours logged as a UAS pilot wit h a multi

- rotor

UAS. Prior to operations under Exemption No. 11062, the P I C mus t also have

accumulated and logged a minimum of 5 hours a s a UA S pilot operating the same make

and model o f UAS t o b e used for oper ations under th e exemption. For clarification, the

FAA considers these minimum hour requirements to be inclusive rather than additive; i.e.

5 hour s mak e an d mode l tim e ma y b e include d i n th e 1 0 hour s o f mult i

- rotor time and t he

10 hours ma y b e included in the total 25 hours of UAS rotorcraft time. I n addition to the

hour requirements, the P I C must accomplish 3 takeoffs and landings in th e preceding 90

da y s (for currenc y purposes). The FAA finds that at a minimum, the flight

- ho ur

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

the skills necessary to safely c onduct the petitioner’s proposed operations. The FA A also

finds that prior documented flight experience tha t was obtained in compli anc e with

applicable regulations would satisf y this requirement. Training, proficienc y

, and

experienc e

- building flights ca n also be conducted under the grant of exemption to

accomplish the required flight time. During training, proficienc y , and experienc e

- building

flights the P I C is requ ired to operate the U A with appropriate distances in accordance

with 14 C.F.R 91.119.

Exemption No. 11138 at page 15.

According l y

, Th e GLOBAL AIR MEDIA, LLC wil l ensur e saf e operation s b y no t allowin g a n y

P I C to operate the DJI Phantom 3 Pro UAS unless that P I C ha s demonstrated, b y meeting

minimum flight

- hour and currency requirements, that th e PIC is able to safel y operate the D J I

Phantom 3 Pro UAS in a manner consistent with the exemption, including evasive andemergency m aneuvers 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 level o f safe t y established b y S e ctio n 91.7(a) will b e maintained b ecause prior to

ever y f light, The GLOBAL AIR MEDIA, LLC wil l ensure that the DJI Phantom 3 Pro UAS is

in an airwort h y condition based upon the UAS’s compli anc e with its operating documents

and as stated in the conditions and limitations herein.

Additional l y

, the FA A ha s previous l y granted relief from Section 91.7(a) specific to UAS, in

circumstances similar, in all material respects, t o 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 A f fect Safety.

The equivalent level of safe t y established b y S ection 91.121 will be maintained because the

altitude information of th e DJI Phantom 3 Pro UAS will be provided to th e PIC vi a GPS

equipment and a radio communications telemetry d ata link

, which downlinks from th e U A to th e

GCS for active monitoring of th e flight path and altitude. This altitude information, combined

with The GLOBAL AIR MEDIA, LLC operation of the DJI Phantom 3 Pro UAS within visual

line of sight, at or below 500 fee t AGL, will ensure a lev e l o f safet y e quivalent to Section

91.121. The altitude information will be generated b y G P S equipment installed onboard th e

aircraft. Prior to each flight, a zero altitude initiation point is automatically established b y th e

UA S at ground level.

The FA A 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 Requirem ents of Section 91.151(b) Would Not

Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safe t y established b y 14 C.F.R.

Section 91.151(b) as a result of (1) the technical specifications of the DJI Phantom 3 Pro UA S ;

(2) the limitations on the proposed flight operations; and (3) the location of the proposed flight

operations. Accordingl y

, The GLOBAL AIR MEDIA, LLC wil l ensur e tha t i t wil l saf e l y operat e

the batter y powered DJI Phantom 3 Pro UAS during da y li g ht hours in VFR conditions, with

enough batter y power to fly for a total duration of 23 minutes.Here

, as in Exemption No. 11109, the technical specifications of the DJ I Phantom 3 Pro UA S ;

the lim itations o n the proposed flight operations; and the location of the p roposed operations, will

ensure an equivalent leve l of safe t y established b y 14 C.F.R. Section 91.151(b). Furthermore,

safe t y will be ensured as the DJI Phantom 3 Pro UAS provide audible and visual warnings to th e

P I C at the GCS when the UA S experiences l ow batter y voltage, the first warning occurring at

approximately 3 3 % remaining batter y power, and again at approximately 10 % remaining battery

power. At the critically low batter y level, the DJI Phantom 3 Pro UAS wil l descend and land

automaticall y

.

Signi ficant l y

, previous exemptions grante d b y t h e FAA concerning Section 91.151 establish that

safe t y is not adverse l y affected when the technical characteristics and operating limitations of the

UAS ar e considered. Relief has been granted for manned airc r aft t o operate at less than the

minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650.

Moreover, the FAA ha s previously granted relief from Section 91.151 specific to UAS, in

circumstances similar, in all material respects, t o th ose 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 Requirem e nts 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.

I n seeking this exemption, The GLOBAL AIR MEDIA, LLC submits that th e equivalent level

of safe t y with rega r d to the regulatory maintenance a nd alteration requirements established by

Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a ) & (b ) wil l b e me t because

The GLOBAL AIR MEDIA, LLC will use trained technicians to perform maintenance,

alte rations, or preventive maintenance on the UA S using th e methods, techniques, and practices

prescribed in the operating documents (i.e., the GLOBAL AIR MEDIA, LLC Aerial Operations

Manual, Monthl y Maintenance Log

, and D J I Phantom 3 Pro Instruction Manual). Furthermore,

The GLOBAL AIR MEDIA, LLC will docume nt and maintain all maintenance records for the

DJ I P hantom 3 Pro UAS.

Since the DJI Phantom 3 Pro UAS will be inspected as prescribed b y the operating documents,

The GLOBAL AIR MEDIA, LLC will maintain th e equivalent level of safe t y established b y

S ections 91.405(a )

, 91.409(a)(1), and 91.409(a)(2). A cop y of th e D J I Phantom 3 Pro User

Manuals are attached hereto as Appendix A and B ; a co p y o f the DJI Phantom 3 Pro UAS

Maintenance LOG is attached hereto as Appendix C.

Likewise, th e exemption sought will not adversel y a ffect safe t y because The GLOBAL AIR

MEDIA, LLC will use trained technicians to perform maintenance, alterations or preventive

maintenance on the UAS using the methods, techniques, and practices prescribed b y t he

operating documents.

Furthermore, the exemption sought would maintain an equivalent level of safe t y established by

Sections 91.407, 91.417(a ) and 91.417(b), because all maintenance of the DJI Phantom 3 ProUAS will be p erformed b y trained technicians. Maintenance will be document e d and maintained

utilizing the monthly maintenance log. Significant l y

, previous exemptions granted

b y the FAA concerning Sections 91.405 (a), 91.407(a)(1), 91.409(a)(1) & (a)(2),

and 91.417(a) & (b) establish that safe t y is not adverse l y affected when the technical

characteristics and operating limitations of the UAS are considered.

In consideration of Th e GLOBAL AIR MEDIA, LLC proposed operating limitations, the

operating documents, and th e tech nical aspects of th e D J I Phantom 3 Pro UA S

, The GLOBAL

AIR MEDIA, LLC submits that safety wil l no t b e adversel y a ffecte d b y g ranting exemption from

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

, 91.409(a)(2), and 91.417(a) and (b). The

FA A ha s prev ious l y granted relief specific t o UAS in circumstances similar, in all material

respects, to those presented herein (e.g. Exemptio n Nos. 11062, 11063, 11064, 11065,

11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 1 1156, 11157,

11158, 11159, 11160,

11161).

7. The FAA May Prescribe Any Other Conditions For Safe Operation.

I n accordance with Section 333 of the FA A Modernization and Reform Act of 2012 (FMRA)

and 14 C.F.R. § 21.16 entitled Special Conditions, The G LOBAL AIR MEDIA, LLC requests

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

UA S , which contain such safety standards that the Administrator finds necessary to establish a

level of safe t y equivalent to that es tablished b y 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). Suc h special conditions will permit safe operation o f th e UA S for the limited purp ose of

conducting aerial video and photograp h y over certain areas of the United States for

compensation o r hire. FMRA Section 333 set s forth the requirements for considering whether a

UA S wil l creat e a hazar d t o user s o f th e NA S o r th e public

, o r otherwis e pos e a threa t t o national

securi t y ; a nd further, provides the authori t y f o r such UAS t o operate without airworthiness

certification in accordance with an y r equirements that must be established for the saf e operation

of the UAS in the NAS.

Lik ewise, the Administrator ma y prescribe special conditions pursuant to 14 C.F.R.

§ 21.16, for operation o f the D J I Phantom 3 Pro UAS

, since the airworthiness regulations

of 14 C.F.R. Part 21 d oes no t contain adequate or appropriate safe t y standards, due to the

novel or unusual design features of the aircraft. Section 21.16, entitled Special C onditions, states

the following:

I f the FA A finds that th e airworthiness regulations of this subchapter do not contain

adequate or appropriate safe t y standards for a n aircraft, aircraft engine, or propeller

becaus e of a novel or unusual design feature of the aircraft, aircraft engine or propeller,

he prescribes special conditions and amendments thereto for th e product. The special

conditions ar e issue d in accordance with Part 11 of this chapter and contain such safe t y

standards for th e aircraft, aircraft e n gin e or propeller as the FA A finds necessary to

establish a level of safe t y equivalent to that established in the regulations.See 14 C.F.R. § 2 1.16.

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

, the FAA may

prescribe special condi tion s for Leadin g Edge’s intended operation of the DJ I P hantom 3Pro

UA S , which contain such safety standards that the Administrator fi nds necessary to establish a

level of safe t y equivalent t o that established b y 14 C.F.R

. Part 21, Subpart H, and 14 C.F.R

Se c tions 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 Summary That Ca n Be Published I n The Federal Register, stating: The

Rules from Which the GLOBAL AIR MEDIA, LLC Seeks Exemption:

The GLOBAL AIR MEDIA, 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 Th e Nature O f Th e Exemption The GLOBAL AIR MEDIA,

LLC Seeks:

This exemption wil l permit The GLOBAL AIR MEDIA, LLC to commercially operate an

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

photography over certain areas of the United States.

• Any Additional Information, V i ews, Or Arguments Available To Support

The GLOBAL AIR MEDIA, LLC R equest.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA)

Section 333, which directs th e Secretary o f Transportation to determine if certain UAS

ma y operate safel y in th e NAS. As such, The GLOBAL AIR MEDIA, LLC request for

exemption ma y be granted pursuant to the a uthority of FMRA Section 333 and 1 4 C.F.R. P art

11, as set forth above.

FMRA Section 333 set s forth the requirements for considering whether a UAS will create a

hazard to users o f the NA S or the public, or otherwise pose a threat to national securi t y ; a nd

further, provides the authority for such U A S to operate without airworthiness certification.

As discussed in detail above, The GLOBAL AIR MEDIA, LLC will operate the DJ I P hantom

3 UA S safe l y in th e NAS

, without creating a hazard to users of th e NAS

, or t he public,

or otherwise pose a threat to nation a l securi t y.CONCLUSION

As set forth herein, The GLOBAL AIR MEDIA, LLC seeks an exemption pursuant to 14

C.F.R. §11.61 and Section 333 of the FA A Modernization and Reform Act of 201 2 (FMRA),

which wil l permit saf e operation o f the DJI Phantom 3 Pro UAS commercial l y

, without an

airworthiness certificate, for the limited purpose of conducting aerial video and photography over

certain areas of the United States. B y granting this Petition, the FA A Administ rator will be

fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012,

while also advancing the interests of the public, b y a llowing The GLOBAL AIR MEDIA, LLC

to safe l y, efficient l y, and economically operate the DJI Phantom 3 Pro UAS commercially within

the NAS.27 WHEREFOR E

, in accordance with th e Federal Aviation Regulations and the FAA

Modernization and Reform Act of 2012, Section 333, The GLOBAL AIR MEDIA, LLC

respectful l y requests that th e Administrator gran t t his Petition for a n exemption from the

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

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Leading

Edge to operate the D J I Phantom 3 Pro UA S commercial l y for the purpose o f

conducting aerial video and photograp h y over certain areas of the United States.

Dated:

Monday, November 30, 2015

Respectfully

submitted,

Austin Brown

CEO, Global Air Media

3 3 S. Highland Ave., Baltimore, MD 21224

410

- 504

- 2369

info@globalairmedia.com

Appendices

A

– L ink to D J I Phantom 3 Pro Manual: Click on link below

http://download.dj i

innovations.com/down loads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.2

_en.pdf