UNITED STATES OF AM ERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. 2015

-

____

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

WILLIAM P THRASHER FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMEN TS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL
OPERATION OF DJI Inspire 1, Phantom 2 & 3 and 3D Robotics (3DR) SOL O

UNMANNED AIRCRAFT SYSTEMS

.

PURSUANT TO SECTION 333 OF
THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112

- 95)

Submitted on

WILLIAM P THRASHER 31859 N. Finley Point Rd Polson, Montana 59860 (406) 887

- 2266 jaxgrammy777@gmail.comTABLE OF CONTENTS

Page

GLOSSARY OF
ABBREVIATIONS...............

......................................... ................................. . ..........3

SUMMARY.....................

. . . . . . . . . . . ................................ ................................... ............4

INTRODUCTION AND INTERESTS OF
PETITIONER.............

... ..... ......................... ........... .... ........................ .......................4

BACKGROUND........

.... ....................................... .................................. ..................4

BASIS FOR
PETITION.

............................................................... ................................. ................5

NAME AND ADDRESS OF
PETITIONER

... .. ............................................... .......................................... .............7

T HE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH WILLIAM P THRASHER
SEEKS E XE MPTION..

..... ............ ...................................................................... ......8

THE EXTENT OF RELIEF WILLIAM P TH RASHER SEEKS AND THE REASON
WILLIAM P THRASHER SEEKS THE R ELI EF

... ... ... ... ... ... ... .................. ... ....11

THE REASONS WHY GRANTING WILLIAM P THRASHER REQUEST WOULD
BE IN THE PUBLIC INTEREST...

... .. ... . ......... ... ... ... ... ................................15

THE REASONS WHY GRANT ING THE EXEMPTION WOULD NOT ADVERSELY
AFFECT SAFETY............

.. ...... ...... ................. ................................... ....................19

SUMMARY THAT CAN BE PUBL ISHED IN THE FEDERAL REGISTER

.... .. .... ...32

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO
SUPPORT WILLIAMPTHRASHER REQUEST......

................................. .............. 32

CONCLUSION

......... ........................ ........................ ................ ..............................33

Attachments explanation................................. ........................................34GLOSSARY OF ABBREVIATIONS

3DR 3D Robotics AGL Above Ground Level
AOI Area of Interest
ATC Air Traffic Control
ATO Air Traffic Organization
AV Aerial Vehicle CFR Code of Federal Regulations
COA Certificate of Authorization
FAA Federal Aviation Administration
FAR F ederal Aviation Regulation GCS Ground Control Station
GPS Global Positioning System
LOL Loss of Link
NAS National Airspace System
NOTAM Notice to Airman PIC Pilot In Command
Section 333 FAA Mod and Re form Act of 2012 (FMRA) Section 333 SO Safety Observer
SOP Standard Operat ing Procedures
UA V Unmanned Aircraft Vehicle UAS Unmanned Aircraft System
VFR Visual Flight R ules VLOS Visual Line of Site
VMC Visual Meteorological Conditions
V TOL Vertic al Takeoff and Landing

SUMMARY

WILLIAM P THRASHER seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft Syste m pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit WILLIAM P THRASHER to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography of constructi on sites, real estate, and landscape over certain areas of
the United States.INTRODUCTION AND INTERESTS OF THE PETITIONER

WILLIAM P THRASHER provides his clients with expertise and knowledge in advanced technologies and solutions to increase efficiency, productivity and
effectiveness. WILLIAM P THRASHER currently holds a private pilot’s license
certificate number 1878535 with over 100 hours of flight time

. The objective of
WILLIAM P THRASHER and his aerial operations is to provide high quality imaging for a variety of commercial, public, and residential uses, specifically targeting:

• Real

- estate marketing

• Construction sites before and after

• Appraisals

• Aerial acquisitions for inspections of public and private

structures.

• Building Inspection operations

BACKGROUND

Unmanned Aircraft Systems:

DJI Inspire 1

, Phantom 2 & 3

3D Robotics SOLO

WILLIAM P THRASHER seeks an exemption to operate DJI systems for compensation or hire within the NAS. The DJI Inspire 1

, Phantom 2 & 3 and 3D Robotics SOLO a re vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems.

The DJI Inspire 1 has a maximum gross wei ght of approximately 7 pounds

, with a length of 17 inches and a width of 18 inches and a height of 10 inches and a maximum speed of approximately 30 knots.

DJI Phantom 2 ha s a maximum gross weight of approximately 3 pounds , while having a length of 16 inches width of 16 inches, height of 8 inches, and a maximum spee d o f approximately 29 knots.DJI Phantom 3 has a maximum gro ss weight of 3 pounds , a length of 17.3 inches,

width of 17.7 inches, height of 11.8 inches, and a maximum speed of approximately 30 knots.

The 3D Robotics SOLO has a maximum gro ss weight of 3.5 pounds , a length of
18 inches, widt h of 13 inches, height of 10 inches, and a maximum speed of approximately 50 knot s.

The DJI Inspire 1

, Phantom 2 & 3 and 3DR SOLO are equipp ed with four main rotors; driven by Lithium Polymer battery powered electric motors.

The DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS will be operated by WILLIAM P THRASHER and will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft , as well as 14 C.F.R Part 47, Aircraft Registration

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

.

BASIS FOR PETITION

Petitioner, WILLIAM P THRASHER , pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA) , Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereby petitions the Administrator to commercially operate the DJI Inspire 1 and DJI Phantom 2 & 3

, UASs in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operatio n, WILLIAM P THRASHER operation
DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UASs meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, WILLIAM P T HRASHER requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness
certificate.

WILLIAM P THRASHER submits that the requested relief is proper since an equivalent level of safety will be ensured. WILLIAM P THRASHER will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniqu es, andpractices prescribed in the operating documents (i.e., Monthly Maintenance Log,

and DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UASs Instruction Manual s ). Furthermore, WILLIAM P THRASHER will document and maintain all maintenance
records for The DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UASs

. Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command , is requested by WILLIAM P
THRASHER to the extent necessary to allow a Pilot in Command (PIC) with significant experience in the field of UAV’s holding FAA ground school certificate, as well as an airman medical certificate, and who has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to sa fely operate The DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UASs in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

WILLIAM P THRASHER s eeks relief from Section 91.7(a), entitled Civil aircraft
airworthiness

, because The DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, WILLIAM P THRASHER sub mits that he will ensure The DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UASs are in an airworthy condition, prior to every flight, by determining that the UASs are in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UASs Instruction Manual), and that the aircraft are in a condition for safe flight.

WILLIAM P THRASHER also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , as the DJI Inspire 1, DJI Insp ire 1,
Phantom 2 & 3 and 3DR SOLO UAS will not have a typical barometric altimeter onboard. However, altitude information of The DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UASs will be provided to the PIC via Global Positioning System (GPS) equipment and ra dio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information,
combined with WILLIAM P THASHER operation of The DJI Inspire 1, Phantom 2 &
3 and 3DR SOLO UASs within vis ua l line of sight, at or below 4 00 feet AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, WILLIAM P THRASHER seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions

. WILLIAM P THRASHER submits that safety will not be affected by operation of The DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UASs during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fl y for a total duration of approximately 15 minutes to thefirst 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, WILLIAM P THRASHER provides the following inform ation in support of its petition for exemption:

A. Name and Address o f The Petitioner.

The name and address of the Petitioner and point of contact is:

William P Thrasher 31859 N. Finley Point Rd Polson, Montana 59860 jaxgrammy777@gmail.com (406)887

- 2266

B. The Specific Sections o f 14 C.F.R. From Which WILLIAM P THRASHER Seeks Exemption.

1. WILLIAM P THRASHER Seeks Exemption f rom The Requirements Of Section 61.113(a) And (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in

c ommand

, subsections (a) and (b) prescribe the following, in relevant part:

(a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may tha t person, for compensation or hire, act
as PIC of an aircraft.

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any 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 compensation or hire.

2. WILLIAM P THRASHER Seeks Exemption From The Requirements Of Section 91.7(a).

Section 91.7, entitled Civil Aircraft A irworthiness , subsection (a), states the
follow ing:(a) No person may operate a civil aircraft unless it is in an airworthy condition.

3. WILLIAM P THRASHER Seeks Exemption From The Requirements Of Section 91.121.

Section 91.121, entitled Altimeter settings , subsection (a), states the following, i n 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 setting of a station along the route and within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure.

4. WILLIAM P THRASHER Seeks Exemption From The Requirements Of Section 91.151( b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions

, subsection

(b), states the following:

(b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.5. WILLIAM P THRASHER Seeks Exemption From The Requirement Of Section 91.405(a).

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

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

6. WILLIAM P THRASHER Seeks Exemption From The Requirements Of Section 91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, o r alteration

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

(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

--
(1) It has been approved for return to service by a person authorized under § 43.7 of this chapter[.]

7. WILLIAM P THRASHER Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2).

Section 91.409, entitled Inspections , subsection (a), states the following:

(a) Except as provided in paragraph (c) o f this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it
has had

--
(1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by § 43 .7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.

8. WILLIAM P THRASHER Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b).Section 91.417, entitl ed Maintenance records , subsections (a) and (b), state the following:

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of t his section:

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

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

--
(i) A description (or reference to data acceptable to the Administrator) of the work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature and certificate number of the person approving
the aircraft for return to service.

(2) Records containing the following information:

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

(ii) The current status of life

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

(iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time
basis.

(iv) T he current inspection status of the ai rcraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety directives including, for eac h, the method of compliance, the AD or safety dir ective number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required.(vi) Copies of the forms prescribed by § 43.9(d) of this chapt er for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of th is section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be
retained and transferred with the aircraft at the time th e aircraft is
sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.

C. The Extent Of Relief WILLIAM P THR ASHER Seeks And The Reason
WILLIAM P THRASHER Seeks The Relief.

1. Extent Of Relief WILLIAM P THRASHER Seeks And The Reason
WILLIAM P THRASHER Seeks Relief From Section 61.113(a) And (b).

Relief from Section 61.113(a) and (b) entitled Private pilot privi leges and
limitations: Pilot in command , is requested to the extent necessary to allow a PIC holding a private pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met certain flight

- hour and currency

re quirements, to conduct the proposed UAS flight operations for compensation or
hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft i n 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 compensation or hire.

As set forth more fully below, WILLIAM P THRASHER submi ts that an equivalent level of safety will be maintained because no PIC will be allowed to operate DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s unless that PIC has met certain flight

- hour and currency requirements, demonstrating that the PIC is able to safely operate either the DJI Inspire 1, DJI Phantom 2 , DJI Phantom 3 3DR SOLOUAS ’s in a manner consistent with the operations specifications as described in

this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate di stances from people, vessels, vehicles and structures.

Further, WILLIAM P THRASHER submits that all flights of DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UASs , conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to WILLIAM P THRASHER business; and (2) will not carry passengers or property for compensation or hire.

2. Extent Of Relief WILLIAM P THRASHER Seeks And The Reason
WILLIAM P THRASHER Seeks Relief From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircr aft airworthiness , is requested to the extent required to allow WILLIAM P THRASHER to determine that the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UASs are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the oper ating documents (i.e.,
the WILLIAM P THRASHER Aerial Operations Manual, Monthly Maintenance Log,
and DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UASs Instruction Manual).

WILLIAM P THRASHER seeks the requested relief because the DJI Inspire 1,
Phantom 2 & 3 and 3DR SOLO UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, WILLIAM P THRASHER will ensure that the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO
UASs are in airworthy condition based upon its comp liance with the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UASs Instruction Manual) prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated in the co nditions and
limitations below.

3. Extent Of Relief WILLIAM P THRASHER Seeks And The Reason
WILLIAM P THRASHER Seeks Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings , may be required to allow flight operations of the DJ I Inspire 1, Phantom 2 & 3 and 3DR SOLO UASs , which utilize a barometric pressure sensor, GPS 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 F AA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), WILLIAM P THRASHER seeks the requested relief becausethe DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UASs altimete r may be set on

the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to compl y 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 Inspire 1, Phantom 2 & 3 and 3DR SOLO
UASs are equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the PIC with altitude information of the UA on the
heads

- up display of the GCS.

4. Extent Of Relief WILLIAM P THRASHER Seeks And The Reason
WILLIAM P THRASHER Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR
conditions , is requested to the extent required to allow flights of the battery powered DJI Inspire 1, Phan tom 2 & 3 and 3DR SOLO UASs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a
total duration of 15 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that f or at least 5 minutes. WILLIAM P THRASHER seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered DJI Inspire 1,
Phantom 2 & 3 and 3DR SOLO UASs will severely constrain the practicalit y of any aerial video or still photo flight operations that WILLIAM P THRASHER proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s operating documents, and WILLIAM P THRASHER proposed operating limitations, ensure that WILLIAM P THRASHER will safely operate the battery powered DJI Inspire 1, Phantom 2 & 3 and 3DR
SOLO UAS’s during daylight hours in visual meteorological conditions (VMC),
unde r visual flight rules (VFR), with enough battery power to fly for a total duration
of 15 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 5 minutes.

5. Extent Of Relief WILLIAM P THRASHER Se eks And The Reason WILLIAM P THRASHER Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b).Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b)

only apply to aircraft with an airwor thiness certificate, WILLIAM P THRASHER requests relief from these Sections because the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s do not require airworthiness certificates. As set forth more fully below, DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS s meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly,
WILLLIAM P THRASHER will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods,
techni ques, and practices prescribed in the UAS operating documents (i.e., the
WILLIAM P THRASHER Aerial Operations Manual, Monthly Maintenance Log,
and DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UASs Instruction Manual). Furthermore, WILLIAM P THRASHER will docu ment and maintain all maintenance
records for the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UASs

. D. The Reasons Why Granting WILLIAM P THRASHER Request Would Be In The Public Interest; That Is, How It Would Benefit The Public As A
Whole.

Granting the p resent Petition will further the public interest by allowing WILLIAM P THRASHER to o safely, efficiently, and economically perform aerial video and photography of construction sites, real estate, and landscape over certain areas of
the United States.

Addit ionally, use of the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of WILLIAM P THRASHER proposed operation of the DJI Inspire 1 , Phantom 2 & 3 and 3DR SOLO UASs will be realized without implicating any privacy issues.

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

DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UASs are battery powered and serve as a safe, efficient, and economical 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 Inspire 1, Phantom 2 & 3 and 3DR SOL O UASs would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground.Furthermore, by reducing the number of manned aircraft operating in the NAS,

co ngestion around airports caused by arriving and departing aircraft will be
reduced. The DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UASs do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photog raphy 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 Inspire 1, Phantom 2 & 3 and 3DR SOLO , and 3DRsolo UASs

Conducting aerial acquisitions with the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UASs , instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise polluti on generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO
UAS ’s 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 and photography, while burning approximately
20

- 30 gallons per hour of leaded aviation fuel. The DJI Inspire 1, DJI Phantom 2 ,
D JI Phantom 3 UAS , while reducing the carbon footprint of aerial acquisitions,
also eliminat es noise pollution, as the UAS are propelled by battery powered electric motors, rather than an internal combustion engine.

By using the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO 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 eliminat ed. Aside from the lack of flight crew members located onboard the aircraft, the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS ’s (weighing appr oximately 7 .7 po unds , 3 .5 pounds, 3.9 pounds and 3.3 pounds respectively, at their maximum gross weights with le ngths of 17 i nches

, 16 i nches and 8 inches respectively, widths of 18 inches , 16 inches and 8 inches respectively, 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 t o the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations With The DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO , and 3DRsolo UAS w ill Benefit The Economy.In addition to being safe and efficient, the DJI Inspire 1, Phantom 2 & 3 and 3DR

SOLO UASs are also an economical alternative to using manned aircraft to
cond uct similar aerial operations. As such, operation of the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS will allow United States based companies, like
WILLIAM P THRASHER , 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 companies must adopt new and alternative technology in order to remain competitive. Operating th e battery powered DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS ’s is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of
a tradit ional manned aircraft.

By operating the DJI Inspire, 1

, DJI Phantom 2 & 3 and 3DR SOLO UASs, companies such as WILLIAM P THRASHER can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through commercial use of the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s , provides a stable workforce that increases consumer spending; improves loc al, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the United States and abroad.

4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operation s that have been conducted for decades, WILLIAM P THRASHER proposed operation of the DJI Inspire 1,
Phantom 2 & 3 and 3DR SOLO UASs will not implicate any privacy issues. Specifically, the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS ’s will be operated on ly in compliance with operating documents (i.e., the WILLIAM P THRASHER Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1, DJI Phantom 2 &3 and 3DR SOLO UAS’s ( Instruction Manual) which requires property owner involvement as well as loca l law enforcement notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption W ould Provide A Level Of Safety At LeastEqual To That Provided By The Rule From Which WILLIAM P THRASHER

Seeks Exemption.

1. Reasons Why The DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO
UAS ’ s 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, WILLIAM P THRASHER operation of
the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whe ther a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part:

(a) In General.

-- Notwithstanding any other requirement of this subtitle,
and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the plan and rulemaking required b y 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 aircr aft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pos e a threat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, UnitedStates Code, is required for the operation of unmanned aircraft systems identif

ied under paragraph (1).

(c) Requirements for Safe Operation.

-- If the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the sa fe operation of such aircraft systems in the national airspace system.

In seeking this exemption, WILLIAM P THRASHER submits that the DJI Inspire 1,
Phantom 2 & 3 and 3DR SOLO UAS ’s can operate safely in the NAS pursuant to FMRA Section 333, as demonstra ted by: (a) the characteristics of the DJI Inspire 1, DJI Phantom 2 &3 and 3DR SOLO UASs; (b) the pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS ’s Dem onstrate Its Safe Characteristics.

The DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS ’s do not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capabilit y.

i. Technical Specifications o f DJI Inspire 1, Phantom 2 & 3 and
3DR SOLO UAS ’s

.

The technical specifications of the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO
UAS ’s are set forth by the DJI Inspire 1, DJI Phantom 2 & 3 User Manuals,

att ached hereto as links

.

ii. The DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s Autonomous Flight And Navigation Modes Enable The UASs To Remain Within A Defined Operational Area.

The DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s may be operated in both
manual and fully autonomous flight modes. A complete description of the flight andnavigational modes of the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s

provided in the User Manuals, att ached hereto as links

.

iii. The DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UA S’s

a re 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 Inspire 1, Phantom 2 & 3 and 3DR SOLO
UAS’s will remain stationary, in flight, for 3 seconds or mo re. If, after 3 seconds,
the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s do not reacquire control link data from the GCS, the UAS will assume that the Control Link is lost and the
UAS will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown.

A complete description of the Failsafe Functions of the DJI Inspire 1 are set forth on pages 13 through 15, DJ I Phantom 2 UAS pages 2 0 through 21 and for the DJI Phantom 3 at pages 13 through 14 of the D JI Inspire 1, DJI Phantom 2 and DJI Phantom 3 User Manuals, att ached hereto as links

.

iv. DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s GCS Operation.

A complete description of the operation and specifications of the DJI Inspire 1 are located on page s 45

- 51 and 57 respectively. DJI Phantom 2 located on pages 10

- 21 and 57 respectively. DJI Phantom 3 located on pages 40

- 46 and 53 respectively. 3D Robotics SOL page 62. DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s User Manuals are attached hereto as links and attachments.

b. Flight Opera tions o f DJI Inspire 1, Phantom 2 & 3 and 3DR
SOLO UAS’s a re Limited t o The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer.

WILLIAM P THRASHER will be the only person to act as a pilot in command (PIC)
of DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s

. Additionally, a safety observer will assist him during flight time.

c. F lights o f DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’ s

w ill Be Conducted Pursuant To Specific Operating Limitations.In seeking this exemption, WILLIAM P THRASHER proposes to commercially

operate DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s for the special purpose of conducting aerial video and photography over certain areas of United States, pursuant to the following specific operating limitations:

1 . Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s . Proposed operations of any other aircraft will require a new petition or a petition to amend this grant.

2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photography.

3. The UAs may not be flown at an indicated airspeed exceeding 45 knots.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved
b y ATC. All altitudes reported to ATC must be in feet AGL.

5. The UAs must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s
FAA

- issued airman medical certificate.

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted.

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requi rement as long as the PIC always maintains VLOS capability. The SO and PIC must be able tocommunicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the SO can perform the functions prescribed in the operating documents.

8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoidin g other air traffic and other ground based obstacles/obstructions and is not permitted to operate the camera or
other instruments.

9. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the
Ad ministrator 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 pre cedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present upda ted and revised documents to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. If the operator determines that any update or revision
would aff ect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operating d ocuments.

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 nec essary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records.11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraft
records.

12. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents.

13. The operat or must follow the UAS manufacturer’s aircraft/component, maintenance, over haul, replacement, inspection, and life limit requirements.

14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the o perating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature of the authorized perso n returning the UAS to service.

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

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

17. The PIC must possess at least a private pilot certificate and at least
a current third

- class medical certificate.18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification cri teria 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 s tructures. 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 PICs are permitted under the terms of the exemption. However, training operations may only be con ducted during dedicated training sessions. During training, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonpart icipants in accordance with 14 C.F.R. § 91.119.

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not
authorized.

20. The UA V may not operate within 5 nautical miles of an airport reference point as denoted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request.

21. The UA V 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 V loses communica tions or loses its GPS signal, it must return to a pre

- determined location within the planned operating area and land or be recovered in accordance with the operating documents.

23. The PIC must abort the flight in the event of unpredicted obstacles

or emergencies in accordance with the operating documents.

24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and la nd the UA V with 25% battery power remaining.

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will also require th e operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airsp ace, altitude level and potential transponder requirements.

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

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

27. Before conducting operations, the radio frequency spectrum used for operation and control of the UA V must comply with the Federal Communications Commission (FCC) o r other appropriate government oversight 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 Ground Control Station of the UAS anytime the UAS is operating. These documents must be mad e available to the Administrator or any law enforcement official upon request.

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

30. The UA V may not be operated by the PIC from any m oving 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 struc tures are present that sufficiently protect nonparticipating persons from the UA V and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating p ersons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has grant ed permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, and;

c. Operations nearer to the PIC, SO, operator trainees or essential persons do not prese nt an undue hazard to those persons per § 91.119(a).

32. All operations shall be conducted over private or controlled

- access property with permission from the land owner/controller or authorizedrepresentative. Permission from land owner/controller or au thorized representative will be obtained for each flight to be conducted.

33. 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 th e FAA's UAS Integration Office (AFS

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

2. Reasons Why An Exemption From The Requirements Of Sec tion 61.113(a) And (b) Would Not Adversely Affect Safety.

WILLIAM P THRASHER submits that the equivalent level of safety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’ s in a manner consistent with the exemption, includin g evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

Considering WILLIAM P THRASHER proposed area of operations, and the operating limitations set forth

- above; the parallel nature of priva te pilot aeronautical knowledge requirements to those of commercial pilot requirements ( See Exemption No. 11062); and the airmanship skills necessary to safely operate
the DJI Inspire 1, Phantom 2 & 3 a nd 3DR SOLO UAS’ s , WILLIAM P THRASHER
submits that th e additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for
WILLIAM P THRASHER specific proposed flight operations.

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

.WILLIAM P THRASHER will not allow any PIC to operate the DJI Inspire 1,

Phantom 2 & 3 and 3DR SOLO UAS’ s unless the PIC has demonstrated, by meeting minimum flight

- hour requirements or the DJI Inspire 1, Phantom 2 & 3 and
3DR SOLO UAS’ s training and c urrency requirements, that the PIC is able to safely operate the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’ s in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vesse ls, 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 hours 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 purposes).

As in Exemption Nos. 11062, 11138, and 11153 , prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during WILLIAM P THRASHER proposed operations. The Administrator has held that prior documented flight experience tha t was obtained in compliance with applicable regulations would ensure safe operations, stating as follows:

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

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

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

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

- building flights can also be conducted under t he grant of exemption to accomplish the required flight time. During training, proficiency, and experience

- building flights the PIC is required to operate
the UA S with appropriate distances in accordance with 14 C.F.R 91.119.

Exemption No. 11138 at page 15.

Accordingly, WILLIAM P THRASHER will ensure safe operations by not allowing any PIC to operate DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’ s unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’ s in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

3. Reaso ns Why a n Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.7(a) will be maintained because prior to every flight, WILLIAM P THRASHER will ensure that DJI Inspir e 1, Phantom 2 & 3 and 3DR SOLO UAS’ s is in an airworthy condition based upon the UAS’s compliance with its operating documents and as stated in the conditions
and limitations herein.

Additionally, the FAA has previously granted relief from Section 91.7( a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160,
1116 1).

4. Reasons Why An Exemption From The Requirements Of Section

91.121 Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained
because the altitude information of the DJI Inspire 1, Phantom 2 & 3 and 3DRSOLO UAS’s 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 WILLI AM P THRASHER operation of the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s within visua l line of sight, at or below 4 00 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information will be generated by GPS equipment in stalled onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically established by the UASs at ground
level.

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

5. Reasons Why An Exemption From The Requirements Of Sectio n

91.151(b) Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJI Inspire 1, DJI Phantom 2 and DJI Pha ntom 3 UASs; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, WILLIAM P THRASHER will ensure that it will safely operate the battery powered DJI Inspire 1, Phantom 2 & 3 and 3DR SOL O UAS’s during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 15 minutes to the first point of intended landing and, assuming normal cruising speed, t o fly after that for at least 5 minutes.

Here, as in Exemptio n No. 11109, the technical specifications of the DJI Inspire 1, DJI Phantom 2 & 3 and 3D Robotics SOLO UAS’s ; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s provide audible and visual warnings to the PIC at the GCS when the UAs experiences low battery voltage, the first warning occurring at a pproximately 33% remaining battery power, and again at approximately 10% remaining battery power. At the critically low batte ry level, The DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UASs will descend and land automatically.Significantly, previous exemptio ns granted by the FAA concerning Section 91.151

establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

6. Reasons Why An Exemption From The Requirements Of Sections

91.405(a), 91.407 (a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety.

In seeking this exemption, WILLIAM P THRASHER submits that the equivalent level of safety with regard to the regulatory maintenance and alteration requirements establis hed by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because WILLIAM P THRASHER will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques , and practices prescribed in the operating documents (i.e., the WILLIAM P THRASHER Aerial Operations Manu al, Monthly Maintenance Log, DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO Instruction Manual). Furthermore, WILLIAM P THRASHER will
document and mainta in all maintenance records for the DJI Inspire 1, Phantom 2
& 3 and 3DR SOLO UASs.

Since the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s will be inspected as prescribed by the operating documents, WILLIAM P THRASHER will maintain the equivalent leve l of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI Inspire 1 DJI Phantom 2 & 3 User Manuals are

att ached hereto as links ; a copy of the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s Maintenance LOG is attache d hereto as Appendix A

. Likewise, the exemption sought will not adversely affect safety because WILLIAM P THRASHER will use trained technicians to perform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and pra ctices prescribed by the operating documents.

Furthermore, the exemption sought would maintain an equivalent level of safety established by Sections 91.407, 91.417(a) and 91.417(b), because allmaintenance of the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s will be

performed by trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log.

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the technical characteristics and operating
limitations of the UAS are considered.

In consideration of WILLIAM P THRASHER proposed operating limitations, the operating documents, and the technical aspects of the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s

, WILLIAM P THRASHER submits that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417 (a) and (b). The FAA has previously granted relief specific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

7. The FAA 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

, WILLIAM P THRASHER requests that the FAA prescribe special conditions for the intended operation of the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UASs, which contain such safety standards that the Administrator finds necessary to establish a
level of saf ety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAs for the limited purpose of conducting aerial video and photography over certain areas of the United States for compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will
create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to 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 Inspire 1, Phantom 2 & 3 and 3DR SOLO UASs, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate

or appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special Conditions , states the following:If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. The special co nditions are issued in accordance with Part 11 of this chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent to that established in the regulations.

S ee 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for Leading Edge’s intended operation of the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s , which contain such safety

st andards 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 Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

• A Summary That Can Be Published i n The Federa l Register, stating: The Rules f rom Which WILLIAM P THRASHER Seeks Exemption:

WILLIAM P THRASHER seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91. 121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

A Brief Description Of The Nature Of The Exemption WILLIAM P THRASHER Seeks:

This exemption will permit WILLIAM P THRASHER to commercially operate
an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States.• Any Additional Information, Views, Or Arguments
Available To Support WILLIAM P THRASHER Request.

This Petition is made pursu ant to the FAA Modernization and Reform Act of
2012

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. As such, WILLIAM P THRASHER request for exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above.

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a 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, WILLIAM P THRASHER will operate the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s safely in the NAS, without creating a
haza rd to users of the NAS, or the public, or otherwise pose a threat to national security.

CONCLUSION

As set forth herein, WILLIAM P THRASHER seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FM RA), which will permit safe operation of the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s 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 will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing WILLIAM P THRASHER to safely, efficiently, and economi cally operate the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s commercially within the NAS.

WHEREFORE , in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, WILLIAM THRASHER respectfully requ ests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Leading Edge to operate the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLOUAS’s commercially for the purpose of conducting aerial video and photography

over certain areas of the United States.

November 11, 2015

A ttachments to this submission :

1. PETITION FOR EXEMPTION
2. william.p.thrasher.ppl.1878535
3. Phantom 2 quick start
4. 3DR SOLO quic k start
5. 3D Robotics SOLO Manual
6. Maintenance log spreadsheet

WILLIAM P THRASHER only utilizes safe and reliable UASs. DJI are industry leader s in small UAS production. DJI UASs are loaded with ground breaking software enabling the user to set parameters which will not all ow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJI & 3D Robotics software provides real

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

Very respectfully,

William P Thrashermaximum upload to this site would not support some of my attachments:

I've added link s instead:

1. DJI Inspire 1 Manual

http://download.dji

innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.2_en.pdf

2. DJI Phantom 2 Manual

htt p://download.dji

innovations.com/downloads/phantom_2/en/PHANTOM2_User_Manual_v1.00_en. pdf

3. DJI Phantom 3 Manual

http://download.dji

innovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manu al_v1.0_en.pdf

3. 3D Robotics SOLO Manual

https://3drobotics.com/kb/solo

- user

- manual/