UNITED STATES OF

AMERICA

DEPARTEMNT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No.________________

**IN THE MATTER OF THE PETITION FOR EXEMPTION OF:** 



### Addison M. Dickinson **FOR AN EXEMPTION SEEKING RELIEF FROM TH**  **E REQUIREMENTS OF TITLE 14 OF THE CODE OF**  **FEDERAL REGULATIONS SECTIONS 14 CFR PART 21,**  **45.23(b),61.113 (a)&(b), 91.7 (a), 91.9 (b)(2)**

**91.103, 91.109, 91 .119, 91.121, 91.151 (a), 91.203 (a)&(b),**  **91.405 (a), 401 (a)(1), 409 (a)(2), And 417 (a)&(b) CONCERNING**  **COMMERCIAL OPERATION OF THE DJI PHANTOM 2 VISION+, DJI**  **PHANTOM 3, AND DJI INSPIR E 1**  **UNMANNED AIRCRAFT SYSTEM PURSUANT TO SECTION 333 OF**  **THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112** 

**- 95)** Submitted on July 22, 2015

Addison M. Dickinson 11288 Persimmons Blvd Royal Palm Beach, FL 33411 561 542

- 2665 addisondickinson@gmail.comJuly 22, 2015U. S. Department of Transportation

Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re: Exem ption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. 45.23(b);14 CFR Part 21;14 CFR 61.113 (a) & (b); 91.7 (a);91.9 (b) (2);91.103(b); 91.109;91.119; 91.121; 91.151(a);91.203(a) & (b);91.405 (a); 91.407(a) (1); 91.409 (a) ( 2);91.417 (a) & (b).

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Addison M. Dickinson, operator of Small Unmanned Aircraft System s (“ sUASs”) equipped to offer on

- dem and commercial UAS operations for a host of industries and applications. These include:

• Public Safety Support Operations • Solar field voltaic module inspection • Utility

- power generation system inspections and patrolling

• Pipeline inspection and patrolling, • Filmmaking, cinematography, and videography • Precision agriculture • Wildlife and forestry monitoring • Aerial surveying • Construction site inspection and monitoring * infrastructure inspection and monitoring * scientific research * search and rescue • Real

- estate marketing • Motion Picture Filming * infrastructure inspection and monitoring* scientific research

* search and rescue • Real

- estate marketing • Motion Picture Filming

Addison M. Dickinson hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its sUASs, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the F AA as required by Section 333.

As described more fully below, the requested exemption would permit the operation of

sm all, unm anned and relatively inexpensive sUAS under controlled conditions in airspace that is 1) limited 2) predetermined 3) controlled as to access and 4) would provide safety enhancements to the already safe operations using conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “...establish requirements for the safe operation of such aircraft systems in the national airspace system.” Section 333(c) of the Reform Act.The nam e and address of the petitioner is:Addison M. Dickinson

11288 Persimmons Blvd Royal Palm Beach, FL 33411 561 542

- 2665 addisondickinson@gmail.com

Regulations from which the exemption is requested:

**14 CFR Part 21 14 C.F.R. 45.23(b)**  **14 CFR 61.113 (a) & (b) 14 C.F.R. 91.7 (a)**  **14 CFR 91.9 (b) (2) 14 C.F.R. 91.103**  **14 C.F.R. 91.109 14 C.F. R. 91.119**  **14 C.F.R. 91.121 14 CFR 91.151 (a)**  **14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a)**  **14 CFR 407 (a) (1) 14 CFR 409 (a) (2)**  **14 CFR 417 (a) & (b)**

This exem

ption application is expres sly submitted to fulfill Congress’ goal in passing Section 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of UASs do not create a hazard to

users of the NAS or the public or pose a threat to n ational security in light of the following: • The UAS’s size, weight, speed, and operational capability; • Operation of the UAS in close proximity to airports and populated areas; and • Operation of the UAS within visual line of sight of the operator. Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “may operate safely in the national airspace system, the Secretary shall establishrequirements for the safe operation of such aircraft in the national airspace

system .” Id. §3 33(c) (em

phasis added) Applicant interprets this provision to place the duty on the Administrator to not only process applications for exemptions under section 333, but for the Administrator to craft conditions for the safe operation of the UAS, if it should be determined that theconditions set forth herein do not fulfill the statutory requirements for approval.

The Federal Aviation Act expressly grants the FAA the authority to issue

exem ptions. This statutory authority by its term s includes exempting civil aircraft, as the term is defined under §40101 of the Act that includes sUASs, from the requirement that all civil aircraft m ust have a current airworthiness certificate. The Administrator may grant an exemption from a requirem ent of a regulation prescribed under subsection (a) or (b) of this section or any sections 44702

- 44716 of this title if the Adm inistrator finds the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC §44704 ; 14 CFR §91.203 (a) (1).

Addison M. Dickinson's UASs are rotorcraft, weighting 55 or fewer lbs. including payload. They operate, under normal conditions at a speed of no more than 50 knots and have the capability to hover, and move in the vertical and horizontal plane simultaneously. They will operate only in line of sight and will operate only within a sterile area. Such operations will insure that the sUAS will “not create a hazard to users of the national airspace system or the public.” Specific operational sUASs are the DJI Phantom 2 Vision+, DJI Phantom 3, and DJI Inspire 1. The DJI Phantom 2 Vision+, DJI Phantom 3, and DJI Inspire 1 are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing e lectronic tablet or smart phone systems. The DJI Phantom 2 Vision+ and Phantom 3 have a maximum gross weight of approximately 2 pounds 11 ounces, while having a length of 16 inches width of 16 inches, height of 8 inches, and maximum speed of approximate ly 29 knots. The DJI Inspire 1 has a maximum
gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of approximately 42 knots. The DJI Phantom 2Vision+,

Phantom 3, and the DJI Insp ire 1 UAs are equipped with four main rotors; driven by Lithium Polymer battery powered electric motors. The DJI Phantom 2 Vision+, Phantom 3, and DJI Inspire 1 UAs that will be operated by HYSight Technologies will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and m arked in accordance with 14 C.F.R Part 45, Identification and Registration Marking.

Reform Act Section 333 (b). Given the small size o f the sUASs involved and the restricted sterile environment within which they will operate, the applicant falls squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by

exem ption, allow comme rcial operations of UASs to commence immediately. Also due to the size of the UASs and the restricted areas in which the relevant sUASs will operate, approval of the application presents no national security issue. Given the clear direction in Section 3 33 of the Reform Act, the authority contained in the Federal Aviation Act, as

am ended; the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental i mp acts, including reduced emissions associated with allowing UASs, the grant of the requested exemptions is in the public interest.

Accordingly, the applicant respectfully requests that the FAA grant the requested

exem ption without delay.**AIRCRAFT AN D EQUIVALENT LEVEL OF SAFETY** 

The applicant proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or ev en higher level of safety to operations under the current regulatory structure because the proposed operations represent a safety enhancement to the already safe operations conducted with conventional aircraft. These limitations and conditions to which Addison M. Dickinson agrees to be bound when conducting commercial operations under an FAA issued exemption include:
1. The sUAS will weigh less than 55 lbs. 2. Flights will be operated within line of sight of a pilot and/or observer. 3. Maxim um total flight time for each operational flight will be 45 minutes. Flights will be terminated at 25% battery power reserve should that occur prior to the 45 minute limit. 4. Flights will be operated at an altitude o f no m ore than 400 feet AGL or, not

mo re than 200 feet above an elevated platform from which filming is planned. 5. Minimum crew for each operation will consist of the sUAS Pilot, the Visual Observer, and/or the Camer Operator. 6. sUAS pilot may be an F AA licensed airman with at least a private pilot’s certificate and 3rd class medical certificate. 7. sUAS Pilot will be Pilot in Command (PIC). If a pilot certificate holder other than the sUAS Pilot, who possess the necessary PIC qualifications, is also present (i.e. the Visual Observer), that person can also be designated as the PIC. 8. The UAS will only operate within a confined “Sterile Area” of the flight operations area. 9. A briefing will be conducted in regard to the planned sUAS operations pri or to each day’s activities. It will be

mandatory that all personnel who will be performing duties within the boundaries of the safety perimeter be present for this briefing. 10. The operator will obtain the consent of all persons involved and ensure th at only consenting persons will be allowed within 100 feet of the flight operation, and this radius may be reduced to30 feet based upon an equivalent

level of safety determination. 11. Pilot and observer will have been trained in operation of UAS gener ally and received up

- to

- date information on the particular UAS to be operated. 12. Observer and pilot will at all times are able to communicate by voice and/or
text. 13. Written and/or oral permission from the relevant property holders will be obtained. 14. All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies. 15. If the sUAS loses communications or loses its GPS signal, the UAS will have capability to return to a pre

- determined location within the Security Perimeter and land. 16. The sUAS will have the capability to abort a flight in case of unpredicted obst acles or emergencies.**14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203**

**(a) (1)** Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an

e quivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, u pon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of these criteria dem onstrates that the UAS operated without an airworthiness certificat e, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed.

The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither

a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured area as set out in the Manual. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator, pursuant to the Manual’s requirements, and under the requirements and in

com pliance with local public safety requirements, to provide security for the area of operation as is now done with conventional filming. The FAA will have advance notice of all operations. These safety enhancements, which already apply to civil aircraft operatedin connection with motion picture and television production, provide a greater

degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no credible threat to national security posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inabi lity to carry a substantial external load. The FAA has issued the following exemptions to this regulations Exemptions Nos. 11251.

**14 C.F.R. § 45.23 (b). Marking of the Aircraft** The regulation requires: When m arks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pi lot station, in letters not less than 2 inches nor

mo re than 6 inches high, the words "limited," "restricted," "light

- sport," "experimental,"

or "provisional," as applicable. Even though the UAS will have no airworthiness certificate,

an exem ption m ay

b e needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the sUAV, two

- inch lettering will be impossible. The word “Experimental” will be placed on the fuselage in comp liance with §45.29 (f). The equivalent level of safety will be provided by having the sUAV marked on itsfuselage as required by §45.29 (f) where the pilot, observer and others working

with the sUAV will see the identification of the UAS as “ Experim ental.” The FAA has issued the following exemptions to this regulation to Exemptions, but not limited to, Nos. 10700, 8738, 10167 and 10167A, 11256, 11251.

**14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Comman**  **d.** Sections 61.113 (a) & (b) limit private pilots to non

- commercial operations

**.** Because the sUAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring the PIC operatin g the aircraft to have a private pilot’s license rather than a commercial pilot’s license to operate this

sm all UAS. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is rem otely controlled with no living thing on board. The area of operation is controlled and restricted, and all flights are planned and coordinated in advance. The level of safety provided by the requirements included in the Manual exceeds that provided by a single individual holding a commercial pilot’s ce rtificate operating a conventional aircraft. The risks associated with the operation of the sUAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations of the sUAS as requested with a private pilot as the PIC exceeds the present level of safety achieved by 14 C.F.R. §61.113 (a) & (b).

**14 C.F.R. §91.7(a): Civil aircraft airworthiness.** The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft,should this

exem ption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft and the requirements contained in the Manual for maintenance and use of safety check lists prior to each flight, as set forth in Sections J, L and Q, an equivalent level of safety will be provided.

**14 C.F. R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.**  Section 91.9 (b) (2) provides: No person may operate a U.S.

- registered civil aircraft ... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unl ess there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any

com bination thereof. The sUAS, given its size and configuration has no ability or place to carry such a flight m anual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the pilot flying the sUAS will have immediate access to it. The FAA has issued the following exemptions to this regulation, but not limited to: Exem ption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, 10 700, 11251, and 11256.**14 C.F.R. § 91.103: Preflight action**

This regulation requires each pilot in command to take certain actions before flight
to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the ai rcraft an exemption will be needed. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft perform ance data before initiation of flight.

**14 C.F.R. §91.109: Flight instruction** : Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. **s** UASs and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos.5778K & 9862A. The equivalent level of safety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the si ze and speed of the aircraft.

**14 C.F.R. §91.119: Minimum safe altitudes** Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a sUAS that is a helicopter and the

exem ption requests authority to operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption may be needed to allow such operations. As set forth herein, except for the limited conditions stated in the Manual, the UAS will never operate at higher than 400 AGL. It willho wever

be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations without their pre

- obtained consent. The equivalent level of safety will be achieved given the size, weight, and speed of the UAS as well as the location where it is operated. No flight will be taken without the required
permission of the property owner or local officials. Because of the advance notice to the property owner and participants in the aerial activity, all affected individuals will be aware of the planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein and the lack of f lammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL other industries. In addition, the low

- altitude operations of the sUAS will ensure separation be tween these

sm all

- UAS operations and the operations of conventional aircraft that must comply with Section 91.119.

**14 C.F.R. §91.121 Altimeter Settings** This regulation requires each person operating an aircraft to maintain cruising altitude by refer ence to an altimeter that is set “...to the elevation of the departure airport or anappropriate altimeter setting available before departure.” As the sUAS may not

have a barom etric altim eter, but instead a GPS altitude read out, an exemption may be needed

. An equivalent level of safety will be achieved by the operator, pursuant to the Manual and Safety Check list, confirming the altitude of the launch site shown on the GPS altitude indicator before flight.

**14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions**  Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landin g, and, assuming normal cruising speed

– (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.” The battery powering the sUAS provides approximately 30

- 50 minutes of powered flight. To meet the 30

- mi nute reserve requirement in 14 CFR §91.151, sUAS flights would be limited to approximately 20 minutes in length. Given the limitations on the UAS’s
pr oposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or night VFR conditions is reasonable. Applicant believes that an exemption from 14 CFR §91.151(a) falls within the

sco pe of prior exem

ptions. See Exem

ption 10673 (allowing Lockheed Martin Corporation
to operate without compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the sizeand speed of the small UAS. Additionally, limiting sUAS flights to 2 0 minutes

would greatly reduce the utility for which the exemption will be granted. Applicant believes that an equivalent level of safety can be achieved by limiting flights to 45 minutes or 25% of battery power whichever happens first. This restriction would be

mo re than adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area. Similar exemptions have been granted to other operations, including Exem ptions 2689F, 5745, 10673, 10808, and 11251.

**14 C.F.R. §9 1.203 (a) and (b): Carrying Civil Aircraft Certification and**  **Registration** The regulation provides in pertinent part: (a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate an d current airworthiness certificate. . . . (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. The UAS fully loaded weighs no more than 55 lbs and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registratio n docum ents or to display them on the sUAS. An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the sUAS will have immediate access to them, to the extent they are applicable to t he sUAS. The FAA has issued numerous exemptions
tothis regulation. A representative sample of other exceptions includes Exemption

Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, 10700, 11251, and 11256.

**14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2 ); 417(a) & (b): Maintenance**  **Inspections** These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in

com pliance with Part 43.

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. The operator pursuant to the flight m anual and operating handbook will accomplish maintenance. An equivalent level of safety will be achieved because these small UASs are very limited in size and will carry a small payload and operate only in restricted areas for limited periods of tim e. If mechanical issues arise the UAS can land immediately and will be operating from

no higher than 400 feet AGL. As provided in the Manual, the operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the ai rcraft in an airworthy condition to provide the equivalent level of safety. *********

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed: Applic ant seeks an exemption from the following rules: 14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) & (b);91.7(a); 91.9

(b) (2);91.103(b);91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55lbs or less).

Approval of exemptions allowing commercial operations of sUASs, will enhance safety by reducing risk. Conventional operations, using jet or piston po wer aircraft, operate at extrem ely low altitudes just feet from the subjects being filmed and in extreme proximity to people and structures and present the risks associated with vehicles that weigh in the neighborhood of 4,000lbs, carrying large amounts of jet A or other fuel. Such aircraft

mu st fly to and from the operational location. In contrast, a sUAS weighing fewer than 55 lbs. and powered by batteries eliminates virtually all of that risk given the reduced

mass and lack of combustible fuel carried on board. The sUAS is carried to the operation site and not flown. The sUAS will carry no passengers or crew and, therefore, will not
expose them to the risks associated with manned aircraft flights.The operation of small UASs, weighting less than 55 lbs., conducted in the strict

conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including exempting the applicant from the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a sterile environment and, as a result, are far safer than conventional operations conducted with turbine helicopte rs operating in close proximity to the ground and people.

**Privacy** All flights will occur over private or controlled access property with the property owner’s prior consent and knowledge. Filming will be of people who have also consented
to being fil me d or otherwise have agreed to be in the area where filming will take place. The grant of this exemption request will provide improved safety in both day and night operations. Satisfaction of the criteria provided in Section 333 of the Reform Act of 201 2

-

- size, weight, speed, operating capabilities, proximity to airports and populated

areas and operation within visual line of sight and national security

– provide more than adequate justification for the grant of the requested exemptions allowing

comm ercial operation of applicant’s UAS. It is of note that certain public safety operations may involve advanced monitoring technology such as Infrared Red, Night Vision, etc. These specific operations will be governed pursuant to all applicable Local, State, and Federal laws regarding search and seizure including court approval of said operations via search warrant.

**Conclusion** As set forth herein, Addison M. Dickinson 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 2 Vision+, DJI Phantom 3, and DJI Inspire 1 UASs commercially, without an airworthiness certificate, for the limited purpose of conducting theaforem entioned on

- dem and commercial sUAS operations that include:

• Public Safety Support Operations • Solar field voltaic module inspection • Utility

- power generation system inspections and patrolling, • Pipeline inspection and patrolling, • Filmmak ing, cinematography, and videography, • Precision agriculture, • Wildlife and forestry monitoring, • Aerial surveying, and • Construction site inspection and monitoring * infrastructure inspection and monitoring * scientific research * search and res cue • Real

- estate marketing • Motion Picture FilmingBy granting this Petition, the FAA Administrator will be fulfilling the

Congressionalmandate of the FAA Modernization and Reform Act of 2012, while also

advancingthe interests of the public, by al lowing Addison M. Dickinson to safely,

efficiently,and economically operate sUASs commercially within the NAS.WHEREFORE **,** in accordance with the Federal Aviation Regulations and the

FAA Modernization and Reform Act of 2012, section 333, Addison M. Di ckinson respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 45.23(b); Part 21; 61.113(a) & (b), 91.7(a); 91.9(b); 91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a); 91.405(a), 91.407(a)(1); 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Addison M. Dickinson to operate the DJI Phantom 2 Vision+, DJI Phantom 3, and the DJI Inspire 1 commercially in the United Stat es.

Respectfully Submitted,

Addison M. Dickinson 11288 Persimmons Blvd Royal Palm Beach, FL 33411 561 542

- 2665 addisondickinson@gmail.com

**Appendices** : A

– DJI Phantom 2 Vision+/Phantom 3

– Specifications Data Sheet B

– DJI Inspire 1 Specifications Data Sheet C

– Link to DJI Phantom 2 Vision+ Manufacturer’s User Manual D

– Link to DJI Inspire 1 Manufacturer’s User Manual**APPENDIX**

**– A** 

DJI PHANTOM 2 VISION+/PHANTOM 3 TECHNICAL SPECIFICATIONS Addison M. Dickinson only utilizes safe and reliable sUASs. DJI is an industry leader in sm all UAS production. DJI UASs are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Par am eters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJI software provides real

- tim e altitude and location information to the PIC via the linked monitor (smart phone/tablet devices) 1.1 DJI Phantom 2 Vision+/Phantom 3

. 1.1.1 Aircraft 1.1.1.1 Supported Battery

– DJI 5200mAH LiPo Battery 1.1.1.2 Weight (Battery & Propellers Included)

– 2lbs 11.810oz (1242g) 1.1.1.3 Hover Accuracy (Ready to Fly)

– Vertical: .8m ; Horizontal: 2.5m 1.1.1.4 Max Yaw Angular Velocity

- 2000/s 1.1.1.5 Max Tilt Angel

- 350 1.1.1.6 Max Ascent Speed

– 6m /s 1.1.1.7 Max Descent Speed

– 2m /s 1.1.1.8 Max Flight Speed

– 15m /s (NOT RECOMMENDED)

. 1.1.2 Gimbal 1.1.2.1 Working Current

– Static: 750mA; Dynamic: 900mA 1.1.2.2 Control Accuracy

- ±0.030 1.1.2.3 Controllable Range

– Pitch:

- 900

- 00 1.1.2.4 Maximum Angular Speed

– Pitch: 900/s .1.1.3 Camera 1.1.3.1 Operating Temperature Range

- 320F

- 1040F (00C

- 400C) 1.1.3.2 Sensor Size

– 1/2.3” 1.1.3.3 Effective Pixels

– 14M 1.1.3.4 Resolution

– 4384x3288 4.1.3.5 HD Video Recording

– 1080p30 & 720p 4.1.3.6 Recording Field of View

- 1100/850 .1.1.4 Transmitter 1.1.4.1 Operating Frequency

– 5.728GHz

– 5.85GHz 1.1.4.2 Communication Distance (unobstructed)

– FCC Compliance: 800m 1.1.4.3 Receiver Sensitivity (1%PER)

- - 93dBm1.1.4.4 Transmitter Power

– FCC Compliance: 100mW

1.1.4.5 Working Voltage

– 120m A@3.7V 1.1.5 Range Extender 1.1.5.1 Operating Frequency

– 2412

- 2462MHz 1.1.5.2 Communication Distance (unobstructed)

– 500

- 700m 1.1.5.3 Transmitter Power

– 20dBm1.1.5.4 Power Consumption

– 2W

**APPENDIX**

**– B** 

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS Addison M. Dickinson only utilizes safe and reliable UASs. DJI is an industry leader in sm all UAS production. DJI UASs are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Param eters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJI software provides real

- tim e altitude and location information to the PIC via the linked

mo nitor (sm art phone/tablet devices) AC 2.2 DJI Inspir e 1

. 2.2.1 Aircraft 2.2.1.1 Model

– T600 2.2.1.2 Weight (Battery Included)

– 6lbs 7.5291oz (2935g) 2.2.1.3 Hovering Accuracy (GPS Mode)

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

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

- 350 2.2.1.6 Max Ascent Speed

– 5m /s 2.2.1.7 Max Descent Speed

– 4m /s 2.2.1.8 Max Speed

– 22m /s (ATTI m ode, no wind

– NOT RECOMMENDED) 2.2.1.9 Max Flight Altitude

– 4500m 2.2.1.10 Max Wind Resistance

– 10m /s 2.2.1.11 Max Flight Time

– Approxim ately 20 minutes 2.2.1.12 Motor Model

– DJI 3510 2.2.1.13 Propeller Model

– DJI 1345 2.2.1.14 Operating Temperature Range

– 140F to 1040F (

- 100C to 400C) 2.2.1.15 Dim ensions

– 17 1

⁄ 4” x 17 3 ⁄ 4” x 12” 2.2.2 Gimbal 2.2.2.1 Model

– ZENMU SE X3 2.2.2.2 Output Power (with camera)

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

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

- ±0.030 2.2.2.5 Mounting

– Detachable2.2.2.6 Controllable Range

– Pitch:

- 900 to +300; Pan: ±3200

2.2.2.7 Mechanical Range

– Pitch:

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

– Pitch: 1200/s; Pan: 1800/s 2.2.3 Camera 2.2.3.1 Name

– X32.2.3.2 Model

– FC350

2.2.3.3 Total Pixels

– 12.76M 2.2.3.4 Effective Pixels

– 12.4M 2.2.3.5 Im age Max Size

– 4000x3000 2.2.3.6 ISO Range

– 100

- 3200 2.2.3.7 Field of View

- 940 2.2.3.8 CMOS

– Sony EXMOR 1/2.3” 2.2.3.9 HD Video Recording

– UHD(4K): 4096x2160p24/25, 3840x2160p24/25/30; FHD: 1920x1080p24/25/30/48/50/60; HD: 1280x720p24/25 /30/48/50/60 2.2.3.10 Operating Temperature Range

- 320F

- 1040F (00C

- 400C)

. 2.2.4 Transmitter 2.2.4.1 Name

– C1 2.2.4.2 Operating Frequency

– 5.728

- 5.850GHz; 2.400

- 2.483GHz 2.2.4.3 Communicating Distance (unobstructed)

– 2000m 2.2.4.4 Output Pow er

– 9W 2.2.4.5 Operating Temperature Range

- 140F to 1040F (

- 100C to 400C) 2.2.4.6 Battery

– 600mAh LiPo 2S

**APPENDIX**

**– C**  DJI Phantom 2 Vision+ Manufacturer’s User Manual http://download.dji

innovations.com/downloads/phantom_2_vision_plus/en/Phantom _2_ Vision_Plus_User_M anual_v1.8_en.pdf

**APPENDIX**

**– D**  DJI Inspire 1 Manufacturer’s User Manual http://download.dji

innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.0_en.pdf