October 30, 2015

Attn: U. S. Department of Transportation Docket Operations West Building Ground Floor, Room w12

-140 1200 New Jersey Ave, SEWashington, DC 20590 RE: REMSBERG INC. REQUEST AN EXEMPTION FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OFFEDERAL REGULATIONS SECTIONS 61.315(b) & (c), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF DJI Phantom 3 UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

-95) Edwin Remsberg Remsberg inc. 2507 Pleasantville Rd Fallston MD 21047 410

-598

-8516 edwin@remsberg.com

**GLOSSA RY OF** **ABBREVIA TIONS**  AGL Above Ground Level AOI Area of Interest ATC Air Traffic Control ATO Air Traffic Organization AV Aerial Vehicle CFR Code of Federal Regulations COA Certificate of Authorization FAA Federal Aviation Administration FAR Federal Aviation Regulation GCS Ground Control Station GPS Global Positioning System LOL Loss of Link NAS National Airspace System NOTAM Notice to Airman PIC Pilot In Command Section 333 FAA Modernization and Reform Act of 2012 (FMRA) SO Safety Observer SOP Standard Operating Procedures UA Unmanned Aircraft UAS Unmanned Aircraft System VFR Visual Flight Rules VLOS Visual Line of Site VMC Visual Meteorological Conditions VTOL Vertical Takeoff and Landing**SUMMA RY** 

REMSBERG INC seeks exemption from the requirements of 14 C.F.R §§ 61.315(b) & (c), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System (DJI Phantom 3) pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit REMSBERG INC to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting

aerial video and photography of agricultural sites, residential and commercial real estate, civil landscapes and events over certain areas of the United States.

**INTRODUCTION AND INTERESTS OF THE PETITIONER**  REMSBERG INC has for over twenty

-five years provided their clients (which include private sector businesses and non

-profits, along with local state and federal agencies) with expertise and knowledge in photography, video and multimedia using advanced technologies and solutions. REMSBERG INC has worked on thousands of productions over the past 25 years in all types of locations with a perfect client and employee safety record. In the past we have supplied our clients aerial video and photography using commercial aircraft. The objective of REMSBERG INC and our Unmanned Aircraft System (DJI Phantom 3) aerial operations is to provide a more affordable, high

-quality production system for a variety of governmental, commercial, public, and residential uses, specifically targeting

• Agricultural landscapes and practices

• Real

-estate marketing

• Economic development

• Civic landmarks

• Specialevent coverage

• Private and University educational training Remsberg Inc principal Edwin Remsberg has safely flown small RC electric quadcopters recreationally for approximately 1.5 years without incident. Edwin Remsberg is also a certificatedsport pilot with more than 120 hours of fixed wing airtime. Much of it near and in the heavily regulated and controlled airspaces of theWashington DC SFRA

**BA CKGROUND** 

Unmanned Aircraft Systems: DJI Phantom 3, UAS REMSBERG INC seeks an exemption to operate DJI Phantom 3 system for compensation or hire within the NAS. The DJI Phantom 3 is vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The DJI Phantom 3 has a maximum gross weight of approximately 2.8 lb. while having a diagonaldimensionof 23.2”, a maximum speed of approximately 16.4’fps and a maximum

flying height of 400'. The DJI Phantom 3 is equipped with four main rotors; driven by Lithium Polymer battery powered electric motors. The DJI Phantom 3 that will be operated by REMSBERG INC will be registered in accordancewith49 U.S.C.44103, Registration of Aircraft, aswell as 14 C.F.R Part 47,Aircraft Registration

, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking

. **BA SIS FOR PETITION**  Petitioner, REMSBERG INC, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems

, hereby petitions the Administrator to commercially operate the DJI Phantom 3, UAS in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.315(b) & (c), 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 considerationofthe speed,weight,size,and limited operatingareaassociated with the unmanned aircraft and its operation, REMSBERG INC operation of DJI Phantom 3 UAS meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingly, REMSBERG INC requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate. REMSBERG INC submits that the requested relief is proper since an equivalent level of safety will be ensured. REMSBERG INC will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e.

, Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual). Furthermore, REMSBERG INC will document and maintain all maintenance records for the DJI Phantom 3 UAS. Relief from certain requirements of Section 61.315 (b) and (c), entitled Sportpilot privileges andlimitations: Pilotin command

, is requested by REMSBERG INCto the extent necessary to allow a Pilot in Command (PIC) holding a sport pilot or higher level certificate and who has demonstrated, by meeting minimum flight

hour and currency requirements, that the PIC is able to safely operate the DJI Phantom UAS in a manner consistentwiththis exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. REMSBERG INC seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness

, because the DJI Phantom 3 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, REMSBERG INC submitsthattheywill ensure thatthe DJI Phantom 3 UAS is in

an airworthy condition, prior to every flight, by determining that the UAS are in compliance with the operating documents (i.e., Monthly Maintenance Log, andDJI Phantom 3 Instruction Manual), and that the aircraft are in a condition for

safe flight. REMSBERG INC also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings

, as the DJI Phantom 3 UAS will not have a typical barometric altimeter onboard. However, altitude information of the DJI Phantom 3 UASwill be providedto the PICvia 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 REMSBERG INC’s operation of the DJI Phantom 3 UAS within visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121. Additionally, REMSBERG INC seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions

. REMSBERG INC submits that safety will not be affected by operation ofthe DJI Phantom 3 UAS during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for atotal duration of approximately 23 minutes. Battery power indicators are also able to show exactly how much battery power is left, as well as how much time is needed to return safely back to point of take off. In accordance with 14 C.F.R

. § 11.81, REMSBERG INC provides the following information in support of its petition for exemption:

**A. Name A** **nd Ad** **dress Of The Petitioner.** The name and address of the Petitioner and point of contact is: Edwin Remsberg Owner Remsberg Inc. 2507 Pleasantville Rd Fallston Maryland 21047 410

-598

-8516 edwin@remsberg.com FAA Sport pilot certificate #3606836

**B. The**  **Specific Sections**  **Of 14**  **C.F.R. From**  **Which REMSBERG**  **INC Seeks**  **Exemption. 1.**  **REMSBERG INC**  **Seeks Ex** **emption From**  **The Requirements**  **Of Section**  **61.315 (b) and (c).** Section 61.315, entitled , What are the privileges and limits of my sport pilot certificate? , subsections (b) and (c) prescribe the following, in relevant part: (b) You may share the operating expenses of a flight with a passenger, provided the expenses involve only fuel, oil, airport expenses, or aircraft rental fees. You must pay at least half the operating expenses of the flight. (c) You may not act as pilot in command of a light

-sport aircraf t: (2) For compensation or hire. (3) In furtherance of a business.

**2. REMSBERG**  **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 mayoperate a civil aircraft unless it is in an airworthy condition. **3. REMSBERG**  **INC Seeks**  **Exemption From**  **The Requirements**  **Of Section**  **91.121.** Section 91.121, entitledAltimetersettings, subsection (a), statesthefollowing, in part: (a) Each person operating an aircraft shall maintain the cruising altitude orflight level ofthat aircraft, as the case may be, by referenceto an altimeterthat is set, when operating

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

-- (i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station;

or (iii) In the case of an aircraft not equipped with a radio, the

elevation of the departure airport or an appropriate altimeter setting available before departure. **4. REMSBERG**  **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 weatherconditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes. **5. REMSBERG**  **INC Seeks**  **Exemption 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 43of this chapter[.] **6. REMSBERG**  **INC Seeks**  **Exemption From**  **The Requirements**  **Of Section**  **91.407(a)(1)** Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration

, subsection (a)(1), states the following: (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

-- (1) It has been approved for return to service by a person authorized under § 43.7 of this chapter[.] **7. REMSBERG**  **INC Seeks**  **Exemption From**  **The Requirements**  **Of Sections**  **91.409(a)(1) A nd 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 inaccordancewith part43 ofthis chapterand has been approved for return to service by a person authorized by § 43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. **8. REMSBERG**  **INC Seeks**  **Exemption From**  **The Requirements**  **Of Sections**  **91.417(a) A nd 91.417(b).**  Section 91.417, entitled Maintenance records

, subsections (a) and (b), state the following: (a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preventive maintenance, and alteration and

records of the 100

-hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include

--

(i) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the aircraft for return to service. (2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor. (ii) The current status of life

-limited parts of each airframe, engine, propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraftwhichare requiredto beoverhauledonaspecified time basis. (iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required.

(vi) Copies ofthe forms prescribed by § 43.9(d) ofthis chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed: (1)The recordsspecified in paragraph (a)(1) ofthissectionshall be retained until the work is repeated or superseded by other work orfor 1 year after the work is performed.(2)The records specified in paragraph (a)(2)ofthis section shall be retainedand

transferred with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service. **C. The**  **Extent Of**  **Relief REMSBERG**  **INC Seeks**  **An d**  **The Reason**  **REMSBERG INC Seeks The Relief.**  **1. Extent**  **Of Relief**  **REMSBERG INC**  **Seeks An** **d The**  **Reason REMSBERG**  **INC Seeks Relief From Section 61.315(b) A** **nd (c).** Relief from Section 61.315(b) and (c) entitled What are the privileges and limits of my sport pilot certificate?

, is requested to the extent necessary to allow a PIC holding a sport pilot or higher level certificate and who has met certain flight

-hour and currency requirements, to conduct the proposed UAS flight operations for compensation or hire

. As set forth more fully below, REMSBERG INC submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the DJI Phantom 3 UAS unless that PIC has met certain flight

-hour and currency requirements, demonstrating that the PIC is able to safely operate eitherthe DJI Phantom 3 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, REMSBERG INC submits that all flights of the DJI Phantom 3 UAS, conducted by the PIC pursuant to the grant ofthis Petition: (1) will be incidental to REMSBERG INC’s business; and (2)will not carry passengers or property for compensation or hire. **2. Extent**  **Of Relief**  **REMSBERG INC**  **Seeks An** **d The**  **Reason REMS** **BERG 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 REMSBERG INC to determine that the DJI Phantom 3 UAS are in airworthy condition priorto everyflight by ensuring thatthe UAS is in compliance with the operating documents (i.e., REMSBERG INC Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual). REMSBERG INCseeksthe requested relief because the DJI Phantom 3 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.Therefore, REMSBERG INCwill ensurethatthe DJI Phantom 3 UAS

are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3) prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated in the conditions and limitations below. **3. Extent**  **Of Relief**  **REMSBERG INC**  **Seeks An** **d The**  **Reason REMSBERG**  **INC Seeks Reli ef From Section 91.121.**  Relieffrom Section 91.121, entitled Altimeter settings, may be required to allow flight operations ofthe DJI Phantom 3 UAS, which utilize a barometric pressuresensor, GPS equipment, and a radio communications telemetry data link to

downlink altitude informationfromthe UAto the PIC atthe 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), REMSBERG INC seeks the requested relief because the DJI Phantom 3 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 issoughtto theextent necessaryto complywiththeapplicable conditions and limitations stated below.As morefully setforth herein, an equivalent level of safety will be maintained since the DJI Phantom 3 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 display of the GCS. **4. Ex** **tent Of**  **Relief REMSBERG**  **INC Seeks**  **An d**  **The Reason**  **REMSBERG 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 extent required to allow flights of the battery powered DJI Phantom 3 UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 23 minutes. REMSBERG INC seeks the requested relief because without an exemptionfrom Section 91.151(b),theflighttimedurationofthe battery powered DJI Phantom 3 UAS will severely constrain the practicality of any aerial video or still photo flight operations that REMSBERG INC proposes to conduct pursuant to this Petition. Significantly, as set forth below, the technical specifications of the DJI Phantom 3 UAS, the DJI Phantom 3 operating documents, and REMSBERG INC’s proposed operating limitations, ensurethat REMSBERG INCwill safely operatethe battery powered DJI Phantom 3 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 23 minutes. **5. Extent**  **Of Relief**  **REMSBERG INC**  **Seeks An** **d The**  **Reason REMSBERG**  **INC Seeks Relief From Sections 91.405(a), 91.407(a)(1),**  **91.409(a)(1) &**  **(a)(2), An** **d 91.417(a) & (b).** Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, REMSBERG INC requests relief from these Sections because the DJI Phantom 3 UAS do not require airworthiness certificates.As setforth morefully below, the DJI Phantom 3 UAS meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, REMSBERG INC will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the REMSBERG INC Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual). Furthermore,REMSBERG INC willdocument and maintain all maintenance records for the DJI

Phantom 3 UAS. **D. The**  **Reasons Why**  **Granting REMSBERG**  **INC Request**  **Would Be**  **In The**  **Public Interest; That Is, How It Would Benefit The Public A s A**  **Whole.** Granting the present Petition will further the public interest by allowing REMSBERG INCto safely,efficiently,and economically perform aerialvideoand photography of agricultural sites, real estate, events and civic landscape over certain areas of the United States. Additionally, use of the DJI Phantom 3 UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of REMSBERG INC’s proposed operation of the DJI Phantom 3 UAS will be realized without implicating any privacy issues. **1. The Public Will Benefit From Decreased Congestion Of The NA S.**  The DJI Phantom 3 UAS are battery powered and serve as a safe, efficient, and economical alternative tothe manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJI Phantom 3 UAS would reducethe amount ofmanned aircraft inthe NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground. Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The DJI Phantom 3 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**  **A nd**  **Efficiency Of**  **The DJI**  **Phantom 3 UA S.**  Conducting aerial acquisitions with the DJI Phantom 3 UAS, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, the DJI Phantom 3 UAS produce no air pollution, and is the most viable environmentally conscious alternativetothe cabin class, six cylinder internal combustion engine aircraftthat

are typically utilized for aerial video and photography, while burning approximately 20

-30 gallons per hourofleadedaviationfuel.The DJI Phantom 3 UAS, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAS are propelled by battery powered electric motors, rather than an internal combustion engine. By using the DJI Phantom 3 UAS to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground,which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI Phantom 3 UAS (weighing approximately 2.8 pounds at their maximum gross weight with diagonal dimension of 23.2 inches, and with no fuel on board), has less physical potential for collateral damage tolife 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 awingspan ofapproximately42 feet, a length of 34 feet, and afuel capacity of 180 gallons). **3. P erforming A** **erial Video and Photography Operations With The DJI**  **Phantom 3 UA S Will Benefit The Economy.**  In addition to being safe and efficient, the DJI Phantom 3 UAS are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom 3 UAS will allow United States based companies, like REMSBERG INC, to remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviationfuelandthe Environmental ProtectionAgency (“EPA”) regulatoryactions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery powered DJI Phantom 3 UAS is one such technology that not only allows companies greater operationalflexibility comparedto manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft. Byoperatingthe DJI Phantom 3 UAS, companiessuch as REMSBERG INC, can remain competitive and profitable, and therefore, provide greaterjob stability to employees and contractors, which will ultimately contribute to growth ofthe U.S. economy. Improved financial performance of U.S. companies, through commercial use of the DJI Phantom 3 UAS, 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 andabroad. **E. The**  **Reasons Why**  **Granting The**  **Exemption Would**  **Not Ad** **versely A**  **ffect Safety** 
**, Or**  **How T** **he Exemption**  **Would Provide**  **A Lev** **el Of**  **Safety A**  **t Least**  **Equal To**  **That Provided**  **By T** **he Rule**  **From Which**  **REMSBERG INC**  **Seeks Exemption.**  **1. Reasons** **Why**

**T he**  **DJI Phantom**  **3 UA** **S Meet**  **The Conditions**  **Of The**  **FAA Modernization and Reform A** **ct of 2012 (FMRA ) Section 333.**  In considerationofthe size,weight,speed, and limited operatingareaassociated withthe unmanned aircraft and its operation, REMSBERG INC’s operation ofthe DJI Phantom 3 UAS meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users 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.

--Notwithstanding any other r equirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shalldetermine ifcertain unmannedaircraftsystems mayoperate safely in the national airspace system before completion of t he plan andrulemaking 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 andpopulated areas, and operation within visual line ofsight do not create a hazard to users ofthe national airspace system or the public or pose a threat to national security; and (2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 oftitle 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1). (c) Requirements for Safe Operation.

--If the Secretary determines under this section that certain unmanned aircraft systemsmay operate safely in the national airspace system, the Secretary shall establ ish requirements for the safe operation of such aircraft systems in the national airspace system. In seeking this exemption, REMSBERG INC submits that the DJI Phantom 3 UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics ofthe DJI Phantom 3 UAS; (b) the pilot certification requirement; and (c) the specific operating limitations. **a. The Specifications Of The DJI Phantom 3 UA S Demonstrate Its Safe**  **Characteristics.** The DJI Phantom 3 UAS does not create a hazard to users of the NAS or the public, or otherwise poseathreatto national security considering itssize,weight, speed, and operational capability. **i. Technical Specifications Of The DJI Phantom 3 UA S.**  The technical specifications of the DJI Phantom 3 UAS are set forth by the DJI Phantom 3 User Manual, attached hereto as Appendix A. **ii. The DJI Phantom 3 UA S Global Positioning Modes Enable The UA** **S To Remain Within A** 

**Defined Operational A rea.**  The DJI Phantom 3 UAS may be operated in both manual and global positioning flight modes. A complete description of the flight and navigational modes of the DJI Phantom 3 UAS is provided at pages 11 ofthe DJI Phantom 3 User Manual attached hereto as Appendix A. **iii. The DJI Phantom 3 UA S A** **re Designed For Au** **tomatic Return To Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation.**  When the Control Link is lost, the DJI Phantom 3 UAS will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 3 UAS does

not reacquire control link data from the GCS, the UAS will assume that the Control Link is lost and the will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown. A complete description ofthe Failsafe Functions ofthe DJI Phantom 3 UAS are set forth at pages 12 through 14 of the DJI Phantom 3 User Manual, attached hereto as Appendix A. **iv. The DJI Phantom 3 GCS A nd Its Operation.**  A complete description ofthe operation and specifications ofthe DJI Phantom 3 GCS and flight control software is provided at pages 23 through 29 of the DJIPhantom 3 User Manual. DJI Phantom 3 User Manual is attached hereto as

Appendix A. **b. Flight Operations Of DJI Phantom 3 UAS Is Limited To The Line Of Sight Of A**  **Cer tificated Pilot in Command With A**  **Safety Observer.**  REMSBERG INC staff will be the only persons to act as a pilot in command (PIC) of the DJI Phantom 3 UAS. Additionally, a safety observer will assist him at all times during flight time. **c. Flights Of DJI P hantom 3 UA** **S Will Be Conducted Pursuant To Specific Operating Limitations.**  In seeking this exemption, REMSBERG INC proposes to commercially operate DJI Phantom 3 UAS 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 operating documents, rotorcraft UAS weighing less than 55 pounds maximum gross weight: DJI Phantom 3 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 purposeof 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 altitude of no more than 200 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unlessa Certificate of WaiverorAuthorization (COA) request is made and approved and at no time above 400 feet AGL. 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 otherthan corrective lenses, as specified onthe PIC’s FAA

-issued airman medical certificate. 6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted. 7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration oftheflight.The PIC must ensurethatthe SO can performthe functions prescribed in the operating documents. 8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is not permitted to operate the camera or other instruments.9. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations contained in 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 itsoperating documents. It isthe operator’s responsibilityto track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if it petitionsforextension or amendmenttothe grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS

-80) may be contacted if questions arise regarding updates or revisions to the operating documents. 10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. Ifthe inspection reveals a condition that affects the safe operation ofthe UAS,the aircraft is prohibitedfrom operating untilthe necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included 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 orflight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraft records. 12. The pre

-flight inspection must account for all potential discrepancies, e.g. inoperable components, items, orequipment, not already covered inthe relevant sections of the operating documents. 13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. 14. The operatormust carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature of the authorized person returning the UAS to service. 15. Each UAS operated underthis exemption must complywith 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 sport pilot certificate18. The operator may not permit any PIC to operate unless the PIC meets the

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

-building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119. 19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized. 20. The UA may not operate within

- 5 nautical miles (NM) from an airport having an operational control tower; or 3 NM from an airport with a published instrument flight procedure, but not an operational tower; or 2 NM from an airport without a published instrument flight procedure or an operational tower; or 2 NM from a heliport with a published instrument flight procedure

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

- determined location within the planned operating area and land or be recovered in accordance with the operating documents. 22. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents. 23. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 25% battery power remaining. 24. The operator must obtain anAirTraffic Organization (ATO) issued Certificate of Waiver orAuthorization (COA) priorto conducting any operations above 200ft AGL under the grant of exemption. This COA will also require the operator to requesta Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requirements. 25. 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. 26. Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal CommunicationsCommission (FCC) or other appropriate government oversight agency

requirements. 27. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station ofthe UAS any time the UAS is operating. These documents must be made available to the Administrator or any law enforcement official upon request. 28. The UA must remain clear and yield the right of way to all manned aviation operations and activities at all times. 30. The UAS may not be operated by the PIC from any moving device or vehicle. 31. All operations shall be conducted over private or controlled

-access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted. 32. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS

-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSBWeb site: www.ntsb.gov. **2. Reasons**  **Why**

**A n**  **Exemption From**  **The Requirements**  **Of Section**  **61.315(a) A nd (b) Would Not A** **dversely A**  **ffect Safety**

**.** REMSBERG INC submits that the equivalent level of safety established by Section 61.315(b) and (c) will be maintained because no PIC will be allowed to operate the DJI Phantom 3 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 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering REMSBERG INC’s proposed area of operations, and the operating limitations set forth

-above; the parallel nature of sport pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062); andthe airmanship skills necessaryto safely operatethe DJI Phantom 3 UAS, REMSBERG INC submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for REMSBERG INC’s specific proposed flight operations. REMSBERG INC will not allow any PIC to operate the DJI Phantom 3 UAS unlessthat PIC has demonstrated, by meeting minimumflight

-hour requirements

or the DJI Phantom 3 UAS training and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 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 consistent with 14 C.F.R. § 61.51(b), 25 hours oftotal time as a UAS rotorcraft pilot (with a minimumof5 hours ofthose hours as a UAS pilot operatingthe same make and model of UAS to be used for operations under the exemption). In addition to thehour requirements, 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 REMSBERG INC’s 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 requiredthat priorto conducting operationsfor the purpose of photography (or similar operations), the PIC must have accumulatedand 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 same make and model of UAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included inthe 10 hours ofmulti

-rotortime andthe 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight

-hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the petitioner’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience

-building flights can also be 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, REMSBERG INC will ensure safe operations by not allowing any PIC to operate the DJI Phantom 3 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 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. **3. Reasons**  **Why An** **E xemption**  **From The**  **Requirements Of**  **Section 91.7(a)**  **Would Not Ad** **versely A ffect Safety** 

**.** The equivalent level of safety established by Section 91.7(a) will be maintained because prior to every flight, REMSBERG INC will ensure that the DJI Phantom 3 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. 11062, 11063, 11064, 11065, 11066, 11067, 11080,11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158,

11159, 11160, 11161). **4. Reasons**  **Why**

**A n**  **Exemption From**  **The Requirements**  **Of Section**  **91.121 Would Not A** **dv ersely A**  **ffect Safety**

**.** The equivalent level of safety established by Section 91.121 will be maintained because the altitude information of the DJI Phantom 3 UAS will be provided to the PIC via GPS equipment and a radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path and altitude. This altitude information, combined with REMSBERG INC’s operation of the DJI Phantom 3 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 UAS at ground level. The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). **5. Reasons**  **Why**

**A n**  **Exemption From**  **The Requirements**  **Of Section**  **91.151(b) Would Not A dv** **ersely A**  **ffect Safety**

**.** A grant ofthis 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 UAS; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, REMSBERG INC will ensure that it will safely operate the battery powered DJI Phantom 3 UAS during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 23 minutes. Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 3 UAS; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured

asthe DJI Phantom 3 UAS provideaudible andvisualwarningstothe PIC atthe 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 UAS will descend and land automatically. Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relieffrom Section 91.151 specific to UAS, in circumstances similar, in all material respects,tothose 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**

**A n Exemption F** **rom The Requirements Of Sections 91.405(a),**  **91.407(a)(1), 91.409(a)(1)**  **& (a)(2),**  **An d**  **91.417(a) &**  **(b) Would**  **Not Ad** **versely**

**A ffect Safety** 

**.** In seeking this exemption, REMSBERG 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)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because REMSBERG INC will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., REMSBERG INC Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual). Furthermore, REMSBERG INC willdocument and maintain all maintenance records for the DJI Phantom 3 UAS. Since the DJI Phantom 3 UAS will be inspected as prescribed by the operating documents, REMSBERG 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 ofthe DJI Phantom 3 User Manuals are attached hereto as Appendix A and B; a copy of the DJI Phantom 3 UAS Maintenance LOG is attached hereto as Appendix C. Likewise, the exemption sought will not adversely affect safety because REMSBERG INC will use trained technicians to perform maintenance, 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 UAS will be performed by trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log. Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered. In consideration of REMSBERG INC’s proposed operating limitations, the operating documents, and the technical aspects of the DJI Phantom 3 UAS, REMSBERG INC submits that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted relief specific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). **7. The FAA**

**Ma y**  **Prescribe A ny** 

**Other Conditions For Safe Operation.** In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, REMSBERG INC requests that the FAA prescribe special conditions for the intended operationof the DJI Phantom 3 UAS, which contain such safety standards 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 §§ 61.315(b) & (c), 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). Suchspecial conditionswill permit safe operationofthe UASfor the limited purpose of conducting aerial video and photography over certain areas of the United States for compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operatewithout airworthiness certification in accordance with any requirements that must be established for the safe operation of the UAS in the NAS. Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of the DJI Phantom 3 UAS, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special Conditions, states the following: If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine,

or propeller because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordancewith Part 11 ofthis 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.F.R. § 21.16. Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for Leading Edge’s intended operation of the DJI Phantom 3 UAS, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part21, Subpart H, and 14 C.F.R Sections 61.315(b) & (c), 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**  **Can Be**  **Published In**  **The Federal**  **Register, stating: The Rules From Which REMSBERG INC Seeks Exemption:**  REMSBERG INC seeks exemption from the requirements of 14 C.F.R Sections 61.315(b)&(c), 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 REMSBERG**  **INC Seeks:**  This exemption will permit REMSBERG INC to commercially operate an UnmannedAircraft System (UAS) forthepurpose ofconducting aerial video and photography over certain areas of the United States.

**• An** **y Ad** **ditional Information,** **Views, Or** **Ar guments**  **Available To**  **Support REMSBERG INC’s Request.**This Petition is made pursuant to the FAA Modernization and Reform Act of 2012

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. As such, REMSBERG INC’s request forexemption may begranted pursuant totheauthorityof FMRA Section 333 and 14 C.F.R. Part 11, as set forth above. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazardto users ofthe NAS orthe public, or otherwise pose athreat to national security; and further, provides the authority for such UAS to operate

without airworthiness certification. As discussed in detail above, REMSBERG INC will operate the DJI Phantom 3 UAS 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 setforth herein, REMSBERG INC seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI Phantom 3 UAS commercially, without an airworthiness certificate, for the limited purpose of conducting aerialvideo and photography overcertain areas ofthe United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing REMSBERG INC to safely, efficiently, and economically operate the DJI Phantom 3 UAS commercially within the NAS. **WHEREFORE**, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, REMSBERG INC respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.315(b) & (c), 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 DJI Phantom 3 UAS commercially for the purpose of conducting aerial video and photography over certain areas of the United States. Dated: June 10, 2015 Respectfully submitted, Edwin Remsberg Owner Remsberg Inc 2507 Pleasantville Rd Fallston MD 21047 410

-598

-8516 edwin@remsberg.com

Appendices: A

– Link to DJI Phantom 3 Manual: Click on link below http://download.dji

innovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Man ual_v1.2_en.pdf