### Brian Brill Mountain Graphix 114 Village P lace, Suite 315 Dillon, Colorado 80435 www.mtngraphix.com
970. 389.0957

U.S. Department of Transportation Docket Management System 1200 New Jersey Avenue SE Washington DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act

To W hom it M ay C oncern:

This application is substantially based on the FAA's findings in E xemption No.
FAA

– 2015

– 2779 , granted on September 25 , 2015, and in reliance on the analysis provided therein.

SUMMARY Mountain Graphix seeks exemption from the requirements of 14 C.F.R §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(c)(2) & (3 ), 91.7(a), 91.119(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a), 91.417(a) and (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Mountain Grap hix to operate an UAS for the commercial purpose of conducting aerial video and photography of inspection sites over certain areas of the United States.

INTRODUCTION OF THE PETITIONER Mountain Graphix provides its clients with information about how an acc ident happened. The objective of Mountain Graphix is to provide the best and most effective inspection.

BACKGROUND Unmanned Aircraft Systems: DJI Phantom 3 Standard

Mountain Graphix seeks an exemption to operate DJI systems for compensation or hire withi n the NAS. The DJI
Phantom 3 Standard is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems in tandem with its own dedicated remote system. The DJI Phantom 3 S tandard has a maximum gross weight of 2 .7 pounds with a diagonal size of 23.3 inches and a maximum speed of approximately 31 knots. The DJI Phantom 3 Standard is equipped with four main rotors driven by a 6000mAh LiPo 2S powered electric motors and a Panas onic Smart FSI 1/2.3", Effective pixels 12M (Total pixels 12M) for image capture.
The DJI Phantom 3 Standard that will be operated by Mountain Graphix will be registered in accordance with 49 U.S.C. 44103, as well as 14 C.F.R. Part 47, and marked in accord ance with 14 C.F.R. Part 45.

BASIS FOR PETITION Petitioner, Mountain Graphix , pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and FAA Modernization and Reform Act of 2012 (FMRA), Section 333, hereby petitions the
Adminis trator to commercially operate the DJI Phantom 3 Standard UAS in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.23(a) & (c), 61.101(e)(4) & (5), 61.113(a), 61.315(a), 91.7(a), 91.119(a), 91.121, 91.151(a)(1 ), 91.405(a), 91.407(a)(1), 91.409(a), and 91.417(a) & (b). In consideration of the speed, weight, size, and limited operation area associated with the unmanned aircraft and its operation, Mountain Graphix ’s operation of DJI Phantom 3 Standard meets the co nditions of FAA Modernization and Reform Act of 2012 (FMRA) Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingly, Mountain Graphix requests relief from §§ 91.405(a) 91.407(a)( 1), 91.409(a)(1) & (2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate. MountainMountain Graphix, LLC, PO Box 1091, 114 Village Place, Suite 3 15, Dillon, CO 80435
Office: 970.468.0319 Cell: 970.389.0957

brian @mtngraphix.com Graphix submits that the requested relief is proper since an equivalent level of s afety will be ensured. Mountain Graphix 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., Monthl y Maintenance Log, and DJI Phantom 3 Standard Instruction Manual). Furthermore, Mountain Graphix will document and maintain all maintenance records for the DJI Phantom 3 Standard UAS. Relief from certain requirements of § 61.23(a) & (c) entitled M edical ce rtificates: Requirement and duration, is requested by Mountain Graphix to operate the DJI Phantom 3 Standard without an issued medical certificate. Mountain Graphix will require all pilots to have an annual physical to ensure the pilot is fit to command. R elief from § 61.101(e)(4) & (5), 61.113(a), and 61.315(c)(2) & (3) entitled R ecreational pilot privileges and limitations, P rivate pilot privileges and limitations: Pilot in command, and What are the privileges and limits of my sport pilot certificate? Res pectively , is requested by Mountain Graphix to the extent necessary to allow a PIC holding a recreational, private, or sport pilot certificate, as well as a state Driver’s license, and who has demonstrated, by meeting minimum flight hour and currency requi rements, that the PIC is able to safely operate the DJI Phantom 3 Standard UAS in a manner consistent with this exemption, including evasive and
emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles, and structures
where necessary. Relief from § 91.7(a), entitled Civil aircraft airworthiness, because the DJI Phantom 3 Standard UAS does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Mountain Graphix submits the they will e nsure that the DJI Phantom 3 Standard UAS is in an airworthy condition, prior to every flight, by determining that the UAS is in compliance with the operating documents (i.e. Monthly Maintenance Log, and DJI Phantom 3 Standard Instruction Manual), and that the aircraft are in a condition for safe flight. Relief from § 91.119(c), entitled Minimum safe altitudes: General , because Mountain Graphix intends to use
the DJI Phantom 3 Standard to collect aerial video and photographs of buildings and structures in volved in an investigation. Outside of structures involved in an investigation, Mountain Graphix will maintain safe distance from structures, people, vessels, and vehicles. Relief from § 91.121, entitled Altimeter Settings, as the DJI Phantom 3 Standard UA will not have a typical barometric altimeter onboard. However, altitude information of the DJI Phantom 3 Standard UA will be provided to the PIC via GPS equipment and radio communications telemetry data link, which downlinks from
the UA to the Ground Cont rol System for active monitoring of the flight path. This altitude information,
combined with Mountain Graphix ’s operation of the DJI Phantom 3 Standard within VLS at or below 500 feet AGL, will ensure a level of safety equivalent to § 91.121.
Relief from § 91.151(b), entitled F uel requirements for flight in VFR conditions. Mountain Graphix submits that safety will not be affected by operation of the DJI Phantom 3 Standard UA during daylight visual meteorological conditions (VMC) under VFR, with enough batt ery power to fly for a total duration of approximately 13 minutes to the first point of intended landing and assuming normal cruising speed, to fly after that for at least 5
minutes. In accordance with 14 C.F.R. § 11.81, Mountain Graphix provides the follo wing information in support of its petition for exemption:

A. Name and address Of the Petitioner. The name and address of the Petitioner and point of contact is:

Mountain Graphix LLC.
Brian Brill 114 Village Place, Suite 315 Dillon, Colorado, 80435

B. T he Specific §§ of 14 C.F.R. From Which Mountain Graphix Seeks Exemption.
1. Mountain Graphix Seeks Exemption from the Requirement of §61.23(a) & (c). § 61.23, entitled Medical certificates: Requirement and duration, subsections (a) and (c) prescribe the
fo llowing (a) Operations requiring a medical certificate. Except as provided in paragraphs (b) and (c) of this section, a

person

—Mountain Graphix, LLC, PO Box 1091, 114 Village Place, Suite 3 15, Dillon, CO 80435
Office: 970.468.0319 Cell: 970.389.0957

brian @mtngraphix.com (1) Must hold a first

- class medical certificate: (i) When exercising the pilot

- in

- command privileges of an airline transport pil ot certificate; (ii) When exercising the second

- in

- command privileges of an airline transport pilot certificate in a flag or supplemental operation in part 121 of this chapter that requires three or more pilots; or (iii) When serving as a required pilot fl ight crew member in an operation conducted under part 121 of this chapter if the pilot has reached his or her 60th birthday. (2) Must hold at least a second class medical certificate when exercising: (i) Second

- in

- command privileges of an airline transport pilot certificate in part 121 of this chapter (other than operations specified in paragraph (a)(1)(ii) of this section) ; or (ii) Privileges of a commercial pilot certificate; or (3) Must hold at least a third

- class medical certificate

— (i) When exercising the privileges of a private pilot certificate; (ii) When exercising the privileges of a recreational pilot certificate; (iii) When exercising the privileges of a student pilot certificate; (iv) When exercising the privileges of a flight instructor certificate and acting as the pilot in command; (v) When exercising the privileges of a flight instructor certificate and servi ng as a required pilot flight crewmember; (vi) When taking a practical test in an aircraft for a recreational pilot, private pilot, commercial pilot, or airline transport pilot certificate, or for a flight instructor certificate; or (vii) When performing t he duties as an Examiner in an aircraft when administering a practical test or proficiency check for an airman certificate, rating, or authorization. (c) Operations requiring either a medical certificate or U.S. driver's license. (1) A person must hold an d possess either a medical certificate issued under part 67 of this chapter or a U.S.
driver's license when

— (i) Exercising the privileges of a student pilot certificate while seeking sport pilot privileges in a light sport aircraft other than a glider or balloon; (ii) Exercising the privileges of a sport pilot certificate in a light sport aircraft other than a glider or balloon; (iii) Exercising the privileges of a flight instructor certificate with a sport pilot rating while acting as pilot in
command or serving as a required flight crewmember of a light sport aircraft other than a glider or balloon; or (iv) Serving as an Examiner and administering a practical test for the issuance of a sport pilot certificate in a light sport aircraft other than a glider or balloon. (2) A person using a U.S. driver's license to meet the requirements of this paragraph must

— (i) Comply with each restriction and limitation imposed by that person's U.S. driver's license and any judicial or administrative order applying to the operation of a motor vehicle ; (ii) Have been found eligible for the issuance of at least a third

- class airman medical certificate at the time of his or her most recent application (if the person has applied for a medical certificate); (iii) Not have had his or her most recently issue d medical certificate (if the person has held a medical certificate) suspended or revoked or most recent Authorization for a Special Issuance of a Medical Certificate withdrawn; and (iv) Not know or have reason to know of any medical condition that would m ake that person unable to operate

a light sport aircraft in a safe manner.

2. Mountain Graphix Seeks Exemption From The Requirement Of § 61.101(e)(4) & (5). § 61.101, entitled Recreational pilot privileges and limitations , subsection (e)(4) states the fo llowing: (e) Except as provided in paragraphs (d) and (i) of this section, a recreational pilot may not act as pilot in
command of an aircraft

— (4) For compensation or hire ; (5) In furtherance of a business;

3. Mountain Graphix Seeks Exemption From The Requirement Of § (5), 61.113(a). § 61.113, entitled P rivate pilot privileges and limitations: Pilot in command, subsection (a) states the following: (a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft.Mountain Graphix, LLC, PO Box 1091, 114 Village Place, Suite 3 15, Dillon, CO 80435
Office: 970.468.0319 Cell: 970.389.0957

brian @mtngraphix.com 4. Mountain Graphix Seeks Exemption From The Requirement Of § 61.315(c)(2) & (3). § 61.315, entitled What are the privileges and limit of my sport pilot certificate? , subsection (c)(2) & (3) states the following: (c) You may not act as pilot in command of a light sport aircraft: (2) For compensation or hire. (3) In furtherance of a business.

5. Mountain Graphix Seeks Exemption From The Requirement Of § 91.7(a). § 91.7, entitled Civil aircraft worthiness, subsection (a), s tates that: (a) No person may operate a civil aircraft unless it is in an airworthy condition.

6. Mountain Graphix Seeks Exemption From The Requirement Of § 91.119(c). § 91.119, entitled Minimum safe altitudes: General , subsection (c) states that: Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes: (c) O ver other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, th e aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.

7. Mountain Graphix Seeks Exemption From The Requirement Of §
91.121. § 91.121, entitled Altimeter Settings , subsection (a)(1) states the following, in part : (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

— (1) Below 18,000 feet MSL, to

— (i) The current reported altimeter s etting 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.

8. Mountain Graphix Seeks Exemption From The Requirement Of § 91.151(b). § 91.151, entitled F uel requirements for flight in VFR conditions, subsection (b), states the following: (b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.

9. Mountain Graphix Seeks Exemption From The Requirement Of § 91.405(a). § 91.405, entitled Maintenance required , subsection (a) states: Each owner or operator of an aircraft

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

10. Mountain Graphix Seeks Exemption From The Requirement Of § 91.407(a)(1). § 91.407, entitled O peration after maintenance, preventive maintenance, rebuilding, or alteration, subsection (a)(1), states the following: (a) No person may oper ate 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.

11. Mountain Graphix Seeks Exemption From The Req uirement Of § 91.409(a). § 91.409, entitled Inspections, subsection (a), states the following:Mountain Graphix, LLC, PO Box 1091, 114 Village Place, Suite 3 15, Dillon, CO 80435
Office: 970.468.0319 Cell: 970.389.0957

brian @mtngraphix.com (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 an nual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by §43.7 of this chapter ; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.

12. Mountain Graphix Seeks Exemption from The Requirement Of § 91.417(a) & (b). § 91.417, entitled Maintenance records, subsections (a) & ( 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, pr eventive maintenance, and alteration and records of the 100hour, 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. Th e 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 aircr aft 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, roto r, and appliance. (iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the time since the last inspection requ ired 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 nu mber and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms prescribed by §43.9(d) of this chapter for each major alteration to the airframe and currently ins talled engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or

super seded by other work or for 1 year after the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft
at the time the aircraft is sold. (3) A list of defects furnished to a register ed 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 Mountain Graphix Seeks And The Reason Mountain Graphix Seeks The Relief.
1. Exte nt Of Relief Mountain Graphix Seeks And The Reason Mountain Graphix Seeks Relief From § 61.23(a) & (c). Relief from § 61.23(a), entitled M edical certificates: Requirement and duration, is requested to the extent necessary to allow a PIC, with a current physical from an approved practitioner but no medical certificate, to pilot the DJI Phantom 3 Standard

. The limitations of § 61.23(a) sets forth the level of medical certificate one needs in order to pilot an aircraft. However, because the DJI Phantom 3 St andard does not require a physical pilot inside the vessel and because the DJI Phantom 3 Standard can be programmed to safely return, within the same limitations the PIC would be required to follow, to the GCS and land in the event of loss of range or
othe r emergencies a current physical will maintain a similar level of safety as the medical certificate would. Mountain Graphix requests that a current physical and valid driver’s license meet the safety requirements of
this section.

2. Extent Of Relief Mount ain Graphix Seeks And The Reason Mountain Graphix Seeks Relief From § 61.101(e)(4) & (5), 61.113(a), And 61.315(a). Relief from §§ 61.101(e)(4) & (5), 61.113(a), and 61.315(a), entitled R ecreational pilot privileges and limitations, P rivate pilot privil eges and limitations: Pilot in command, and hat are the privileges and limits of my sport pilot certificate? , is requested to the extent necessary to allow a PIC holding a recreational, private,Mountain Graphix, LLC, PO Box 1091, 114 Village Place, Suite 3 15, Dillon, CO 80435
Office: 970.468.0319 Cell: 970.389.0957

brian @mtngraphix.com or sport pilot certificate as well as a valid driver’s lice nse and current physical, and who has met certain flight
hour and currency requirements, to conduct the proposed UAS flight operations for compensation or hire. This relief is requested since the limitations set forth state that private, recreation, or spo rt pilots may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensati on or hire. As set forth more fully below, Mountain Graphix submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the DJI Phantom 3
Standard UAS unless that PIC has met certain flight hour and currency requ irements, demonstrating that the PIC is able to safely operate either the DJI Phantom 3 Standard in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining app ropriate distances from people, vessels, vehicles, and structures that are not part of an investigation. Further, Mountain Graphix submits that all flights of the DJI Phantom 3 Standard conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to business ; and (2) will not carry passengers or property for compensation or hire.

3. Extent Of Relief Mountain Graphix Seeks And The Reason Mountain Graphix Seeks Relief From § 91.7(a). Relief from § 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent required to allow Mountain Graphix to determine that the DJI Phantom 3 Standard UAS is in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e. Monthly Maintenance Log, and DJI
Phantom 3 Standard Instruction Manual). Mountain Graphix seeks the requested relief because the DJI Phantom 3 Standard UAS does not require an airworthiness certificate in accordance with 14 C.F.R. part 21, Subpart H. Therefore, Mountain Graphix will

ensur e that the DJI Phantom 3 Standard UAS is in airworthy condition based upon compliance with the operation documents (i.e. Monthly Maintenance Log, and DJI Phantom 3 Standard Instruction Manual) prior to every flight, and further, determine that the aircraft is in condition for safe flight, as stated in the conditions
and limitations below.

4. Extent Of Relief Mountain Graphix Seeks And The Reason Mountain Graphix Seeks Relief From § 91.119(c). Relief from § 91.119(c), entitled Minimum safe altitudes: Gen eral, will be necessary in order to conduct various investigations. The DJI Phantom 3 Standard would need to get close vessels, vehicles, and structures involved in the investigation in order to capture clear photographs of the inspection site. Specificall y, the § limits getting within 500 feet of any person, vessel, vehicle, or structure. Mountain Graphix requests relief from this limit against vessels, vehicles, and structures only when part of an active investigation with the property owner’s previous permission. Considering the hovering capabilities of the DJI Phantom 3
Standard , which is ± 0.1 m vertically (when Vision Positioning is activated) and ± 1.5 m horizontally, a safer
than 500 feet distance can be maintained. Furthermore, Mountain Graphix w ill incorporate a second remote system so that the VO or a third participant can operate the photography will the PIC can verify that the DJI
Phantom 3 Standard is maintaining a safe distance from the structure, vehicle, or vessel.

5. Extent Of Relief Mou ntain Graphix Seeks And The Reason Mountain Graphix Seeks Relief From § 91.121. Relief from § 91.121, entitled A ltimeter settings, may be required to allow flight operations of the DJI Phantom
3 Standard UAS, which utilize barometric pressure sensor, GP S equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to air traff ic control (ATC) in feet above ground level (AGL), Mountain Graphix seeks the requested relief because the DJI
Phantom 3 Standard UA’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric

pressure or field altitude, befo re each flight. Considering the limited altitude of the proposed operations, relief is sought to the extent necessary to comply with the applicable conditions and limitations stated below, As more fully set forth herein, an equivalent level of safety will be maintained since the DJI Phantom 3 Standard UA is 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 that PIC with altitud e information of the UA on the heads up display of the GCS.Mountain Graphix, LLC, PO Box 1091, 114 Village Place, Suite 3 15, Dillon, CO 80435
Office: 970.468.0319 Cell: 970.389.0957

brian @mtngraphix.com 6. Extent Of Relief Mountain Graphix Seeks And The Reason Mountain Graphix Seeks Relief From § 91.151(b). Relief from section 91.151(b), entitled F uel requirements for flight in VFR conditions

, is requested to the extent required to allow flights of the battery powered DJI Phantom Standard UA during daylight hours in visual meteorological conditions, under visual flight rules, for a total duration of 13 minutes to the first point of
intended la nding and, assuming normal cruising speed, to fly after that for at least 5 minutes. Mountain Graphix seeks the requested relief because without an exemption from this rule will severely constrain the practicality of any aerial video or still photo flight operations that Mountain Graphix proposes to conduct pursuant to this Petition. Significantly, as set forth below, the technical specifications of the DJI Phantom 3
Standard UAS the operation documents, and Mountain Graphix ’s proposed operating limitations , ensure that Mountain Graphix will safely operate the battery powered DJI Phantom 3 Standard UA during daylight hours in visual meteorological conditions, under visual flight rules, with enough battery power to fly for a total duration
of 13 minutes to th e first point of intended landing and, assuming normal cruising speed, to fly after that for at
least 5 minutes.

7. Extent Of Relief Mountain Graphix Seeks And The Reason Mountain Graphix Seeks Relief From §§ 91.405(a), 91.407(a)(1), 91.409(a)(1) & (2) , And 91.417(a) & (b). Since §§ 91.405(a), 91.407(a)(1), 91.409(a)(1) & (2), And 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, Mountain Graphix requests relief from these §§ because the DJI Phantom 3 Standard UAS does not requir e an airworthiness certificate. As set forth more fully below, the DJI Phantom 3 Standard
UAS meets the conditions of FAA Modernization and Reform Act of 2012 (FMRA) Section 333 for operation
without an airworthiness certificate. Accordingly, Mountain Grap hix 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. Monthly Maintenance Log and DJI Phantom 3 Standard
Instr uction Manual). Furthermore, Mountain Graphix will document and maintain all maintenance records for
the DJI Phantom 3 Standard UAS.

D. The Reason Why Granting Mountain Graphix Request Would Be In The Public Interest; That Is, How It Would
Benefit The Pub lic As A Whole. Granting the present Petition will further the public interest by allowing Mountain Graphix to safely, efficiently, and economically perform aerial video and photography of homes, vehicles, vessels, construction sites, and
other accident si tes over certain areas of the United States. Additionally, use of the DJI Phantom 3 Standard UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of Mountain Graphix ’s proposed op eration of the DJI Phantom 3 Standard UAS will be
realized without implicating any privacy issues.

1. The Public Will Benefit From Decreased Congestion Of The NAS.
The DJI Phantom 3 Standard UA is battery powered and serve as a safe, efficient, and econom ical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJI Phantom 3 Standard UAS would
reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground. Additionally, when Mountain Graphix must collect video and photographic evidence of ships and vessels off the c oast, using the DJI Phantom 3 Standard will result in a
reduction of congestion in the waterways and ultimately a reduction in fuel costs. Furthermore, by reducing the number of manned aircraft operations in the NAS, congestion around airports caused by ar riving and departing
aircraft will be reduced. The DJI Phantom 3 Standard UA does not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would result in
fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom Standard UAS. Conducting aerial acquisitions with the D JI Phantom 3 Standard UAS, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerialMountain Graphix, LLC, PO Box 1091, 114 Village Place, Suite 3 15, Dillon, CO 80435
Office: 970.468.0319 Cell: 970.389.0957

brian @mtngraphix.com video and still photography flight operations. By using battery powered and electric motors, the DJI Phantom 3
Standard UAS produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically utilized for aerial video an d photography, while burning approximately 2030 gallons per hour of leaded aviation fuel. The DJI Phantom 3
Standard UA, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the
UA is propelled by battery powered electric motors, rather than an internal combustion engine. By using the DJI
Phantom 3 Standard 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 Standard UA (weight approximately 2 pounds 13 ounces at its maximum gross weight with length a 23.3 inches diagonal, and with no fuel on board), has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weight approxim ately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations With The DJI Phantom 3 Standard UAS Will Benefit The Economy In addition to being safe and efficient, the DJI Phantom 3 Standard UAS is also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom 3 Standard UAS will allow United States based companies, like Mountai n Graphix , to remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (EPA) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated c ompanies must adopt new and alternative technology in order to remain competitive. Operating the battery powered DJI
Phantom 3 Standard UAS is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, b ut provides such flexibility without the high operational cost of a traditional
manned aircraft. By operating the DJI Phantom 3 Standard UAS companies, such as Mountain Graphix , can remain competitive and profitable, and therefore, provide greater job stab ility to employees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through commercial use of the DJI Phantom 3 Standard UAS, provides a stable workforce that
increases consu mer spending; improves local, state, and federal tax revenues and allows companies to invest in research and development in order to remain competitive both in the United States and abroad.

4. There Are No Privacy Issues. Similar to the manned aerial acqu isition flight operations that have been conducted for decades, Mountain Graphix ’s proposed operations of the DJI Phantom 3 Standard UAS will not implicate any privacy issues. Specifically the DJI Phantom 3 Standard UAS will be operated in compliance with operating documents (i.e. Monthly Maintenance Log, and DJI Phantom 3 Standard Instruction Manual) additionally requiring property
owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations)

E. The Reason Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety Equal To That Provided By The Rule From Which Mountain Graphix Seeks Exemption. 1. Reasons Why the DJI Phantom 3 Standard UA Meet The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333. In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, Mountain Graphix ’s operation of the DJI Phan tom 3 Standard UAS meets the conditions of FAA Modernization and Reform Act of 2012 (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 w ithout airworthiness certification and sets forth requirements for considering whether a UAS will create hazard to users of the NAS or the public, or otherwise pose a threat to national security. Specifically, FAA Modernization and Reform Act of 2012 (FMRA ) Section 333 states the following, in part:Mountain Graphix, LLC, PO Box 1091, 114 Village Place, Suite 3 15, Dillon, CO 80435
Office: 970.468.0319 Cell: 970.389.0957

brian @mtngraphix.com (a) In General.Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned air craft systems may operate safely in the national airspace system before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act. (b) Assessment of Unmanned Aircraft Systems.In making the determination under subsection (a), the Secretary shall determine, at a minimum( 1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operatio n within visual line of sight do not create a
hazard to users of the national airspace system or the public or pose a threat to national security ; and (2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1). (c) Requ irements for Safe Operation.If the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system. In seeking this exemption, Mountain Graphix submits that the DJI Phantom 3 Standard UAS can operate safely in the NAS pursuant to FAA Modernization and Reform Act of 2012 (FMRA) Section 333, as demonstrated by: (a)
the cha racteristics of the DJI Phantom 3 Standard UA; (b) the pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The DJI Phantom 3 Standard UAS Demonstrate Its Safe Characteristics.
The DJI Phantom 3 Standard UA S does not create a hazard to users of the NAS or the public, or otherwise pose a threat to the national security considering its size, weight, speed, and operational capability.

i. Technical Specifications Of The DJI Phantom 3 UAS. The technical specific ations of the DJI Phantom 3 Standard UAS are set for by the DJI Phantom 3 Standard User Manual and Safety Guide, attached hereto as Appendix A and B.

ii. The DJI Phantom 3 UAS Autonomous Flight And Navigation Mode Enable The UAS to Remain Within A
Defined Operational Area.
The DJI Phantom 3 Standard UAS may be operated in both manual and fully autonomous flight modes. A complete description of the flight and navigational modes of the DJI Phantom 3 Standard UAS is provided at page 1 0 of the DJI Phantom 3 St andard User Manual, attached hereto as Appendix A.

iii. The DJI Phantom 3 Standard UAS Is Designed For Automatic 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 Standar d UA will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 3 Standard UA do not reacquire control link data from the GCS, the
UA will assume that the Control Link is lost and the US will return to the home position (i.e. failsafe mode) via GPS, and will descend to the takeoff position and shutdown. A complete description of the Failsafe Functions
of the DJI Phantom 3 Standard are set forth at pages 13 of the DJI Phantom 3 User Manual, attached hereto as Appendix A.

iv. The DJI Phantom 3 Standard GCS And Its Operation. A complete description of the operation and specifications of the DJI Phantom 3 Standard GCS and flight control software is provided at pages 21

- 43 of the DJI Phantom 3 Standard User Manual, a ttached hereto as Appendix A.

b. Flight Operations Of DJI Phantom 3 Standard UAS Is Limited To The Line Of Sight Of A Certified Pilot in Command With A Safety Observer. Mountain Graphix will be the only company to authorize PICs for the DJI Phantom 3 Stan dard . Additionally, a safety observer and photographer will assist the PIC during flight time.

c. Flights Of DJI Phantom 3 Standard UAS Will Be Conducted Pursuant To Specific Operating Limitations.Mountain Graphix, LLC, PO Box 1091, 114 Village Place, Suite 3 15, Dillon, CO 80435
Office: 970.468.0319 Cell: 970.389.0957

brian @mtngraphix.com In seeking this exemption, Mountain Graphix proposes to c ommercially operate DJI Phantom 3 Standard UAS for the special purpose of conducting aerial video and photography over certain areas of the United States, pursuant to the following specific operating limitations: 1. Operations authorized by this grant of e xemption will be limited to the following aircraft described in the operating documents, rotorcraft UASs weight less than 55 pounds maximum gross weight: DJI Phantom 3
Standard Unmanned Aircraft System. Proposed operations of any other aircraft will requir e a new petition or a petition to amend this grant. 2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photography. 3. The UA may not be flown at an indicated airspeed exceeding 20 knots.
4. The UA must be operated at an altitude of no more than 500 feet AGL, as indicated by the procedures specified in the operating documents unless a special request is made and approved by ATC. All altitudes reported to ATC must be in feet AGL.
5. The UA must be operated within VLOS of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses , as specified on the PIC’s State issued Driver’s
License 6. The use of the first person view by the PI C or SO is not permitted. 7. All operations must utilize an SO. The SO may be used to satisfy the VLOS requirement as long as the IC always maintains VLOS capability. The SO and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the SO can perform the functions prescribed in the operatin g 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 doc uments 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 revis e its operating documents. It is the operator's responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension o r amendment to the grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its grant of exemption. The FAA’s UAS Integratio n Office (AFS80) may be contacted if questions arise regarding updates or revisions to the operating documents. 10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The GCS must be included in the preflight inspection. All m aintenance and alterations must be properly document in the aircraft records. 11. Any UAs that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.ge 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 preflight inspection must account for all potential discrepancies, e.g. inoperable components, items, or

e quipment, not already cov ered in the 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 operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, descr iption of work accomplished, and the signature of the authorized person returning the UAS to service. 15. Each UAS operated under this exemption must comply with all manufacture Safety Bulletins.Mountain Graphix, LLC, PO Box 1091, 114 Village Place, Suite 3 15, Dillon, CO 80435
Office: 970.468.0319 Cell: 970.389.0957

brian @mtngraphix.com 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 a private, sport, recreational, or higher pilot certificate, at least a current Driver’s License, and a current physical from an approved practitioner. 18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles, and structures not involved in an investigation. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b ) Flights for the purposes of training the operator’s PIC 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 IC 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 de fined in 14 C.F.R. § 1.1. All operations must be conducted under VMC. If flight at night is required, a special request will be made at the FAA office closet to proposed area of operations. Flights under SVFR are not authorized. 20. The UA may not operate within 5 nautical miles of an airport reference point as denoted on current FAA published aeronautical chart unless a letter of agreement with that airport's management is obtained, and the operation is conducted in accordance with a NOTAM as required by t he operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request. 21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in accordance with the operating documents.
23. The P IC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents. 24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to f ly at normal cruising speed to the intended point and land the UA with 25% battery power remaining. 25. The operator must obtain an ATO issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption. Thi s COA will also require the operator to request a NOTAM not more than 72 hours in advance, but not less than 48 hours prior to operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of ai rspace, altitude level and potential transponder requirements. 26. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (NNumber) markings in ac cordance with 14 C.F.R. part 45, Subpart C. Markings must be made as large as practical 27. Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the FCC or other appropriate government oversig ht agency requirements. 28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the GCS of the UAS any time the UAS in operating. These documents must be made available to the Administrator or any
law enforcement off icial upon request. 29. The UA must remain clear and yield the right of way to all manned aviation operations and activities at the
time. 30. The UAS may not be operated by the PIC from any moving device or vehicle. 31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If situation arises where nonparticipating persons leave such protection and are within 500 feet of
the U, flight o perations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles, or structures where the owner/controller of such vessels, vehicles, or structures has granted permission and the PIC has made a safety assessment of the risk of

op erating closer to those objects and determined that it does not present an undue hazard, and;Mountain Graphix, LLC, PO Box 1091, 114 Village Place, Suite 3 15, Dillon, CO 80435
Office: 970.468.0319 Cell: 970.389.0957

brian @mtngraphix.com c. Operations nearer to the PIC, So, operator trainees, or essential persons do not present an undue hazard to those persons per § 91.119(a). 32. All operations s hall 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.
3 3. 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 (AFS80) within 24 hours. Accidents must be rep orted to the NTSB per instructions contained on the NTSB
website: www.ntsb.gov

.

2. Reasons Why An Exemption From The Requirements Of § 61.23(a) Would Not Adversely Affect Safety. Mountain Graphix submits that the equivalent level of safety established by § 61.23(a) will be maintained because no PIC will be allowed to operate the DJI Phantom 3 Standard unless that PIC has a current physical
on file with Mountain Graphix and a valid Driver’s License. The FAA has previously granted relief from § 61.23(a) & ( c) specific to UAS, in circumstances similar, in all material respects to those presented herein (e.g. Exemption Nos. 11410, 11553, 11257, 11213, 11437, 11150A).

3. Reasons Why An Exemption From The Requirements Of §§ 61.101(e)(4) & (5), 61.113(a), And 61 .315(a) Would Not Adversely Affect Safety. Mountain Graphix submits that the equivalent level of safety established by §§ 61.101(e)(4) & (5), 61.113(a), and 61.315(a) will be maintained because no PIC will be allowed to operate the DJI Phantom 3 Standard

u nless that PIC has demonstrated, by meeting minimum flight hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 Standard UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maint aining appropriate distances from people, vessels, vehicles, and

structures. Considering Mountain Graphix ’s proposed area of operations, and the operating limitations set
forthabove ; the parallel nature of private, recreational, or sport pilot aeronautical knowledge requirements to those of commercial pilot requirements; and the airmanship skills necessary to safely operate the DJI Phantom
3 Standard UAS, Mountain Graphix submits tha t the additional manned airmanship skills unnecessary for Mountain Graphix ’s specific proposed flight operations. Mountain Graphix will not allow any PIC to operate the
DJI Phantom 3 Standard UAS unless that PIC has demonstrated, by meeting minimum flight hour requirements or the DJI Phantom 3 Standard UAS training and currency requirements, that the PIC is able to safely operate the the DJI Phantom 3 Standard UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and mai ntaining 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 of total time as a UAS rotorcraft pilot (with a minimum of 5 h ours of those hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency

purpose s). Accordingly, Mountain Graphix will ensure safe operations by not allowing any PIC to operate the DJI Phantom
3 Standard UAS unless that PIC has demonstrated, by meeting minimum flight hour and currency requirements, that the PIC is able to safely oper ate the DJI Phantom 3 Standard UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles, and structures. The FAA has previously granted relief from § 61.11 3(a) & (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160,
111 61). 4. Reasons Why An Exemption From The Requirements Of § 91.7(a) Would Not Adversely Affect Safety. The equivalent level of safety established by § 91.7(a) will be maintained because prior to every flight, Mountain Graphix will ensure that the DJI Phan tom 3 Standard 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.Mountain Graphix, LLC, PO Box 1091, 114 Village Place, Suite 3 15, Dillon, CO 80435
Office: 970.468.0319 Cell: 970.389.0957

brian @mtngraphix.com Additionally, the FAA has previously granted relief from § 91.7(a) specific to UAS, in circ umstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 1116, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

5. Reasons Why An Exemp tion From The Requirements Of § 91.119(c) Would Not Adversely Affect Safety. The equivalent level of safety established by § 91.119(c) will be maintained because the DJI Phantom 3
Standard will not be flown closer to any Vessel, Structure, or Vehicle witho ut prior authorization from the

owner. Additionally, the DJI Phantom 3 Standard has automated hover capabilities which allow the DJI Phantom 3
Standard to maintain position within ± 0.2m vertically and ± 1.5m horizontally. The FAA has previously granted

re lief from § 91.119(c) 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, 11111, 11112, 11136, 11188, 11208, 11213, 11437, 11508, 11671)

6. Reasons Why An Exemption From The Requirements Of § 91.121 Would Not Adversely Affect Safety. The equivalent level of safety established by § 91.121 will be maintained because the altitude information of
the DJI Phantom 3 Standard UA 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 Mountain Graphix ’s operation of the DJI Phan tom 3 Standard UA within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to § 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 § 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).

7. Reasons Why An Exemption From The Requirements Of § 91.151(b) Would Not Adversely Affect Safety. A grant of this exemption would en sure an equivalent level of safety established by § 91.151(b) as a result (1) the technical specifications of the DJI Phantom 3 Standard UAS; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Acc ordingly, Mountain Graphix will ensure that it will safely operate the battery powered DJI Phantom 3 Standard UA during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 13 minutes to the first point of intended
lan ding and, assuming normal cruising speed, to fly after that for at least 5 minutes. Here the technical specifications of the DJI Phantom 3 Standard UAS ; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safety established by § 91.151(b). Furthermore, safety will be ensured as the DJI Phantom 3 Standard UAS provide audible an d visual warnings to
the PIC at the GCS when the UA 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 power, the DJI Phantom 3 Standard UAS will descend and land automatically. Significantly, previous exemptions granted by the FAA concerning § 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations of the UA S are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in § 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from § 91.151 specific to UAS, in cir cumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 1158, 11159, 11160, 11161).

8. Reasons Why An Exemption From The Requirements Of §§ 91.405(a), 91.407(a)(1), 91.409(a), And 91.417(a) & (b) Would Not Adversely Affect Safety. In seeking this exemption, Mountain Graphix submits that the equivalent level of safety with regard to the
regu latory maintenance and alteration requirements established by §§ 91.405(a), 91.407(a)(1), 91.409(a)(1) & (2), and 91.417(a) & (b) will be met because Mountain Graphix will use trained technicians to perform maintenance, alterations, or preventive maintenan ce on the UAS using the methods, techniques, and practicesMountain Graphix, LLC, PO Box 1091, 114 Village Place, Suite 3 15, Dillon, CO 80435
Office: 970.468.0319 Cell: 970.389.0957

brian @mtngraphix.com prescribed in the operating documents (i.e. Monthly Maintenance Log and DJI Phantom 3 Standard Instruction Manual). Furthermore, Mountain Graphix will document and maintain all maintenance records for the DJI
Phantom 3 Standard UAS.
Since the DJI Phantom 3 Standard UAS will be inspected as prescribed by the operating documents, Mountain Graphix will maintain the equivalent level of safety established by §§ 91.405(a), 91.409(a)(1) & (2). A copy of
th e DJI Phantom 3 Standard User Manuals are attached hereto as Appendix A. Likewise, the exemption sought will not adversely affect safety because Mountain Graphix 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 §§ 91.407(a) and 91.407(b), because maintenance of the DJI Phantom 3 Standard 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 §§ 91.405(a), 91.407(a)(1), 91.409(a)(1) & (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 Mountain Graphix ’s proposed operating limitations, the operating documents, and the technical aspects of the DJI Phantom 3 Standard UAS, Mountain Graphix submits that safety will not be adversely affected by granting exemption from §§ 91.405(a), 91.407(a)(1), 91.409(a)(1) & (2), and 91.417(a) & (b). The FAA has previ ously granted relief specific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 1106, 11067, 11080, 11109, 11110, 11112, 1113, 11138, 11150, 11153, 11156, 11157, 11158, 111 59, 11160, 11161).

9. The FAA May Prescribe Any Other Conditions For Safe Operation. In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. §
21.16 entitled Special Conditions

, Mountain Graphix requests that t he FAA prescribe special conditions for the intended operation of the DJI Phantom 3 Standard 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. §§ 61.23(a), & (c), 61.101(e)(4) & (5), 61.113(a) & (b), 61.315(c)(2) & (3), 91.7 (a), 91.119(c), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (2), and 91.417(a) & (b). Such special conditions will permit safe operat ion of the UA for the limited purpose of conducting aerial video and photography over certain areas of the United States for compensation or hire. FAA Modernization and Reform
Act of 2012 (FMRA) Section 333 sets forth the requirements for considering wheth er a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification in accordance with any requirements
that must be established for the safe operation of the UAS in the NAS. Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of the DJI Phantom 3 Standard 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. § 21.16, entitled Special Conditions

, stated the following: If the FAA finds that the airworthiness regulations of this subchapter do n ot contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller because of novel or unusual design feature of the aircraft, aircraft engine, or propeller , he prescribes special conditions and amendments thereto for the

pr oduct. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety standards for the aircraft, aircraft engine, or propeller as the FAA finds necessary to establish a level of safety equivalent to that established i n the regulations. Therefore, in accordance with FAA Modernization and Reform Act of 2012 (FMRA) Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for Mountain Graphix 's intended operation of the DJI
Phantom 3 Standard UAS, which contains 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. §§ 61.23(a) & (c), 61.101(e)(4) & (5), 61.113(a), 61.315(c)(2) & (3), 91.7(a) , 91.119(c), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a), 91.417(a) & (b).

F. A Summary That Can Be Published In the Federal Register, stating: The Rules From Which Mountain Graphix Seeks Exemption.Mountain Graphix, LLC, PO Box 1091, 114 Village Place, Suite 3 15, Dillon, CO 80435
Office: 970.468.0319 Cell: 970.389.0957

brian @mtngraphix.com Mountain Graphix seeks exemption from the requ irements of 14 C.F.R. §§ 61.23(a) & (c), 61.101(e)(4) & (5), 61.113(a), 61.315(c)(2) & (3), 91.7(a), 91.119(c), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a), 91.417(a) & (b).

G. A Brief Description Of The Nature Of The Exemption Mountain Graphix Seeks. This exemption will permit Mountain Graphix to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States for forensic inspections.

H. Any Additional Inf ormation, Views, Or Arguments Available To Support Mountain Graphix ’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 NS. As such, Mountain Graphix ’s request for exemption may be granted pursuant to the authority of FAA Modernization and Reform Act of 2012 (FMRA) Section 333 and 14 C.F.R. Part 11, as set forth above. The FAA Modernization and
Reform Act of 2012 (FMRA) Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security ; and further, provides the authority for such UAS to operate without airworthiness certification. As discussed in detail above, Mountain Graphix will operate the DJI Phantom 3 Standard 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 set forth herein, Mountain Graphix 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 saf e operation of the DJI Phantom 3
Standard UAS commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography over certain areas of the United States. By granting this Petition, the FAA Administrator

w ill be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012 (FMRA), while also advancing the interests of the public, by allowing Mountain Graphix to safely, efficiently, and economically operate the DJI Phantom 3 Standard U AS commercially within the NAS.

WHEREFORE , in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, Mountain Graphix respectfully requests that the Administrator grant this Petition for an exempti on from the requirements of 14 C.F.R. §§ 61.23(a) & (c) , 61.101(e)(4) & (5), 61.113(a), 61.315(c)(2) & (3), 91.7(a), 91.119(c), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a), 91.417(a) & (b), and permit Mountain Graphix to operate the DJI Phantom 3 Standard UAS commercially for the purpose of conducting
aerial video and photography over certain areas of the United States for forensic inspections.

Dated: December 17, 2015 Respectfully submitted,
Brian J. Brill

____________________________ Mountain Graphix