1 March, 4 2016

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

Room w12

- 140 1200 New Jersey Ave, SE Washington, DC 20590

RE: AERO QUEST L.L.C. REQUEST AN EXEMPTION FROM THE REQUIREMENTS

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 UNMANNED AIRCRAFT SYSTEMS

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

2012 (PUBLIC LAW 112

- 95)

Wesley Parsons

Member

AERO QUEST L.L.C.

6 36 Baker St.

Costa Mesa, CA 92626

949

- 302

- 4631

wparsons.media@gmail.com2 TABLE OF CONTENTS

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

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

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

.... 4

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

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

BACKGROUND....

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

BASIS FOR PETITION................................................................

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

NAME AND ADDRESS OF PETITIONER...........

............ .................... .6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH AEROQUEST

SEEKS EXEMPTION..........................

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

THE EXTENT OF RELIEF AEROQUEST SEEKS AND THE REASON

AEROQUEST SEEKS THE RELIEF.........

............ ................. ................10

THE REASONS WHY GRANTING AEROQUEST’S REQUEST WOULD

BE IN THE PUBLIC I NTEREST ............... ............................................12

THE REASONS WHY GRANTING THE EXEMPTION TO AEROQUEST

WOULD NOT ADVERSELY AFFECT SAFETY..........................

... ....14

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER..... .25

ANY ADDITIONAL I NFORMATION, VIEWS, OR ARGUMENTS

AVAILABLE TO SUPPORT AEROQUEST’S REQUEST

.. .................. ............... 25

CONCLUSION.............

...................... ................... .................... ..............................26

APPENDICES.....................................................................................

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

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

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

SO Safety Observer

SOP Standard O perating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing4 SUMMARY

AERO QUEST L.L.C. hereafter referred to as AEROQUEST 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

System ( DJI Phantom 3 , DJI Inspire, DJI Matric e ) pursuant to Section 333 of the FAA

Modernization and Reform Act of 2012 (FMRA). This exemption will permit AEROQUEST to

operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial

video and photography of residential an d commercial real estate, construction sites , civil

landscapes and events o ver certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

AEROQUEST intends to provid e clients (which include private sector businesses and non

profits, along with local state and federal agencies) with expertise and knowledge in video and

multimedia marketing, advertising, and training using advan ced technologies and solutions. Each

member of the AEROQUEST team holds at least a Private Pilot Certificate, and has operated

both full size aircraft and UAS with a perfect safety record. The objective of AEROQUEST and

our Unmanned Aircraft System s ( DJI Phantom 3 , DJI Inspire

, DJI Matrice ) aerial operations is to

provide a more affordable, high

- quality imagery system for a variety of governmental,

commercial, public, and residential uses, specifically targeting

• Real E stat e

• Aerial Photography/Cinematography

• Land Surveying & Mapping

• Precision Agriculture

• Search & Rescue Aid

• Law Enforcement Operations

• Special event coverage

• Private and governmental training5 BACKGROUND

Unmanned Aircraft Syste ms: DJI Phantom 3 , DJI Inspire, DJI Matrice.

AEROQUEST seeks an exemption to operate DJI UAS for compensation or hire wi thin the

NAS. All DJI UAS operated by AEROQUEST are vertical takeoff and landing (VTOL)

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

smart phone systems. DJI UAS operated by AEROQUEST have a maximum gross weight of

approximately 6.4 lb

. while having a maximum diagonal dimension of 25.6 ”, a maximum speed

of approximately 22 m/s and a maximum flying height of 400'. DJI UAS operated by

AEROQUEST use GPS for a hovering accuracy of .5 meters verticall y, and 2.5 meters

horizontally. Each is equipped with Lithium Polymer batt ery powered electric motors.

The DJI UAS operated by AEROQUEST 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, AEROQUEST, 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 DJI UAS 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 operation, AEROQUEST s operation of DJI UAS meets the conditions

of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance

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

Accordingly, AEROQUEST requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1)

& (a)(2), an d 91.417(a) & (b), as these sections set forth requirements for maintenance that only

apply to aircraft with an airworthiness certificate.

AEROQUEST submits that the requested relief is proper since an equivalent l evel of safety will

be ensured. AEROQUES T will use experienced personnel or technicians to perform

maintenance, alterations, or preventive maintenance on the DJI UAS using the methods,

techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log,

and DJI UAS Ins truction Manual s ). Furthermore, AEROQUEST will document and maintain all

maintenance records for the DJI UAS

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

and limitations: Pilot in command, is request ed by AEROQUEST to the extent necessary to

allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an

airman medical certificate, and who has demonstrated, by meeting minimum flight

- hour and

currency requirements, th at the PIC is able to safely operate the DJI UAS in a manner consistent

with this exemption, including evasive and emergency maneuvers and maintaining appropriate

distances from people, vessels, vehicles and structures.

AEROQUEST seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the

DJI UAS do not require an airworthiness certificate in accordance wit h 14 C.F.R. Part 21,

Subpart H. As such, AEROQUEST submits that they will ensure that the DJI UAS is in an

airworthy condition , prior to every flight, by determining that the DJI UAS are in compliance

with the operating documents (i.e., Monthly Maintenance Log, and DJI UAS Instruction

Manual s ), and that the aircraft are in a condition for safe flight.

AEROQUEST also seeks an exe mption from the requirements of Section 91.121, entitled

Altimeter Settings, as the DJI UAS will not have a typical barometric altimeter onboard.

However, altitude information of the DJI UAS will be provided to the PIC via Global Positioning

System (GPS) e quipment and radio communications telemetry data link, which downlinks from

the UA to the GCS for active monitoring of the flight path. This altitude information, combined

with AEROQUEST’s operation of the DJI UAS within visual line of sight, at or below 400 feet

AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, AEROQUEST seeks an exemption from the requirements of

Section 91.151(b), entitled Fuel requirements for flight in VFR conditi ons. AEROQUEST

submits that safety will not be affected by operation of the DJI UAS during daylight hours in

visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery

power to fly for a total duration of approximately 23 m inutes. Battery power indicators are also

able to show exactly how much battery power is left, as well as how much time is needed to

return safely back to point of take off.

In accordance with 14 C.F.R. § 11.81, AEROQUEST provides the following information in

support of its petition for exemption:

A. Name And Address Of The Petitioner.

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

Wesley Parsons

Member

AEROQUEST L.L.C.

63 6 Baker St.

Costa Mesa, CA 92626

949

- 302

- 4631

wparsons.media@gmail.com7 B. The Specific Sections Of 14 C.F.R. From Which AEROQUEST

Seeks Exemption.

1. AEROQUEST Seeks Exemption From The Requirements Of Section 61.113(a) And (b).

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

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

(a) No person who holds a private pilot certificate may act as a pilot in command

(PIC) of an aircraft that is carrying passeng ers or property for compensation or

hire; nor may that 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 wit h 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. AEROQUEST Seeks Exemption From The Requirements Of Section 91.7(a).

Section 91.7, entitled Civil aircraft airworth in ess, subsection (a), states the following: (a)

No person may operate a civil aircraft unless it is in an airworthy condition.

3. AEROQUEST Seeks Exemption From The Requirements Of Section 91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part:

(a) Each person operating an aircraft shall 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 o f an appropriate available station;

or8 (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. AEROQUEST 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. AEROQUEST Seeks Exemption From The Requirement Of Section 91.405(a).

Section 91.405, entitled Maintenance required, subsec tion (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 paragr aph (c) of this

section, have discrepancies repaired as prescribed in part 43 of this chapter[.]

6. AEROQUEST Seeks Exemption From The Requirements Of Section 91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive maintenance,

rebu ilding, or alteration, subsection (a)(1), states the following:

(a) No person may operate any aircraft that has undergone maintenance,

preventive maintenance, rebuilding, or alteration unless

—

(1) It has been approved for return to service by a person authorized under

§ 43.7 of this chapter[.]

7. AEROQUEST 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.9 8. AEROQUEST Seeks Exemption From The Requirements Of Sections 91.417(a) And

91.417(b).

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following:

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

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

specified in paragraph (b) of this section:

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

and records of the 100

- hour, annual, progressive, and other required or

approved inspections, as appropriate, for each aircraft (including the

airframe) and each engine, propeller, rotor, and appliance of an aircraft.

The records must include

—

(i) A description (or reference to data acceptable to the

Administrator) of the work performed; and

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

(iii) The signature, and certificate number of the person approving

the aircraft for return to service.

(2) Records containing the following information:

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

propeller, and each rotor.

(ii) The current status of life

- limited parts of each airframe, engine,

propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the

aircraft which are required to be overhauled on a specified time

basis.

(iv) The current inspection status of t he aircraft, including the time

since the last inspection required by the inspection program under

which the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD)

and safety directives including, fo r each, the method of compliance, the

AD or safety directive number and revision date. If the AD or safety

directive involves recurring action, the time and date when the next action

is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this c hapter for10 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 this 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 ti me the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under §

43.11 of this chapter shall be retained until the defects are repaired and the

aircraft is approved for return to service.

C. The Extent Of Relief AEROQUEST Seeks And The Reason AEROQUEST Seeks The

Relief.

1. Extent Of Relief AEROQUEST Seeks And The Reason AEROQUEST Seeks Relief

From Section 61.113(a) And (b).

Relief from Section 61.113(a) and (b) entitled Private pi lot privileges and limitations: Pilot in

command, is requested to the extent necessary to allow a PIC holding a private pilot or higher

l evel certificate, as well as a current and valid airman medical certificate, 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 in Section 61.113(a) and (b) state that 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.

As set forth more fully below, AEROQUEST submits that an equivalent level of safety will be

maintained because no PIC will be allowed to operate the DJI UAS unless that PIC has met

certain flight

- hour and currency requirements, demonstrating that the PIC is able to safely

operate either the DJI UAS in a manner consistent with the operations specifications as described

in this exemption, including evasive and emergency maneuvers, as well as maintaining

appropriate distances from people, vessels, vehicles and structures.

Further, AEROQUEST submits that all flights of the DJI UAS

, co nducted by the PIC pursuant to

the grant of this Petition: (1) will be incidental to AEROQUEST’s business; and (2) will not

carry passengers or property for compensation or hire.11 2. Extent Of Relief AEROQUEST Seeks And The Reason AEROQUEST Seeks Relief

F rom Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent

required to allow AEROQUEST to determine that the DJI UAS are i n airworthy condition prior

to every flight by ensuring that the DJI UAS is in compliance with the operating documents (i.e.,

AEROQUEST Aerial Operations Manual, Monthly Maintenance Log, and DJI UAS Instruction

Manual s ).

AEROQUEST seeks the requested relief because the DJI UAS do not require an airworthiness

certificate in accord ance with 14 C.F.R. Part 21, Subpart H. Therefore, AEROQUEST will

ensure that the DJI UAS are in airworthy condition based upon its compliance with the operating

documents (i.e., Monthly Maintenance Log, and DJI UAS ) prior to every flight, and further,

det ermine that the aircraft are in condition for safe flight, as stated in the conditions and

limitations below.

3. Extent Of Relief AEROQUEST Seeks And The Reason AEROQUEST Seeks Relief

From Section 91.121.

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

operations of the DJI UAS, 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 sta tion (GCS). Since the FAA requires that any altitude information

concerning UAS operations be reported to air traffic control (ATC) in feet above ground level

(AGL), AEROQUEST seeks the requested relief because the DJI UA’s altimeter may be set on

the grou nd 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 comply with the applicable co nditions and limitations stated below. As

more fully set forth herein, an equivalent level of safety will be maintained since the DJI UAS

are equipped with a barometric pressure sensor and GPS equipment, which automatically ensures

that a ground level pres sure 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 AEROQUEST Seeks And The Reason AEROQUEST Seeks Relief

From Section 91.151(b).

Relief f rom 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 UAS during daylight

hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total

duration of 23 minutes. AEROQUEST seeks the requested relief because without an exemption

from Section 91.151(b), the flight time duration of the battery powered DJI UAS will severely

constrain the practicality of any aerial video or sti ll photo flight operations that AEROQUEST

proposes to conduct pursuant to this Petition.12 Significantly, as set forth below, the technical specifications of the DJI UAS, the DJI UAS

operating documents, and AEROQUEST’s proposed operating limitations, ensur e that

AEROQUEST will safely operate the battery powered DJI UAS during daylight hours in visual

meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power

to fly for a total duration of 23 minutes.

5. Extent Of Relief AE ROQUEST Seeks And The Reason AEROQUEST 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 airworthiness certificate, AEROQUEST requests relief from t hese Sections

because the DJI UAS do not requ ire airworthiness certificates. As set forth more fully below, the

DJI UAS meet the conditions of FMRA Section 333 for operation without an airworthiness

certificate. Accordingly, AEROQUEST will use trained technicians to perform maintenance,

alterations, or preventive maintenance on the UAS using the met hods, techniques, and practices

prescribed in the UAS operating documents (i.e., the AEROQ UEST Aerial Operations Manual,

Monthly Maintenance Log, and DJI UAS Instruction Manual s ). Furthermore, AEROQUEST will

document and maintain all maintenance records for the DJI UAS.

D. The Reasons Why Granting AEROQUEST Request Would Be In The Public Inter est;

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

Granting the present Petition will further the public interest by allowing AEROQUEST to safely,

efficiently, and economically perform aerial video and photography of construction sites, real

estate , agriculture, events and civil landscape over certain areas of the United States.

Additionally, use of the DJI UAS will decrease congestion of the NAS, reduce pollution, and

provide significant benefits to the economy. Notably, the benefits of AEROQUEST’s proposed

operation of the DJI UAS will be realized without implicating any privacy issues.

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

The DJI UAS are battery powered and serve as a safe, efficient, and economical alterna tive 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

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.

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion

around airports caused by arriving and departing airc raft will be reduced. The DJI UAS do not

require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial

vi deo 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 UAS.13 Conducting aerial acquisitions with the DJI UAS, instead of manned aircraft, will greatly benefit

the public by drastically reducing the levels of air and noise pollution generated during

traditional aerial video and still photography flight operations. By using battery power and

electric motors, the DJI 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 and photography, while burning approximately 20

- 30 gallons

per hour of leaded aviation fuel. The DJI UAS, while reducing the carbon footprint of aerial

acquisitions, also eliminates noise pollution, as the UAS are propelled by battery powered

electric motors, rather than an internal combustion engine.

By using the DJI 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 locat ed onboard the aircraft, the DJI UAS (weighing approximately 6.4 pounds at

their maximum gross weight with a maximum diagonal dimension of 25.6 inches, and with no

fuel on board), has less physical potential for collateral damage to life and property on th e

ground, and in the air, compared to 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 Aeri al Video and Photography Operations With The DJI Inspire 1 UAS Will

Benefit The Economy.

In addition to being safe and efficient, the DJI UAS are also an economical alternative to using

manned aircraft to conduct similar aerial operations. As such, operation of the DJI UAS will

allow United States based companies, like AEROQUEST , 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”) regu latory actions phasing out leaded aviation fuels,

U.S. owned and operated companies must adopt new and alternative technology in order to

remain competitive. Operating the battery powered DJI UAS is one such technology that not

only allows companies great er operational flexibility compared to manned aircraft, but provides

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

By operating the DJI UAS, companies such as AEROQUEST, can remain competitive and

profitable, and the refore, 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 UAS, provides a stable workforce that in creases consumer spending; improves local, state, and federal tax revenues; and allows companies to

invest in research and development in order to remain competitive both in the United States and

abroad.

4. There Are No Privacy Issues.

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

AEROQUEST’s proposed operation of the DJI UAS will not implicate any privacy issues.

Specifically, the DJI UAS will be operated only in compliance with operating documents (i .e.,14 AEROQUEST Aerial Operations Manual, Monthly Maintenance Log, and DJI UAS Instruction

Manual s ) which requires property owner involvement as well as local 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 Would Provide A Level Of Safety At Least Equal To That Provided

By The Rule From Which AEROQUEST See ks Exemption.

1. Reasons Why The DJI UAS 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 operati on, AEROQUEST’s operation of the DJI UAS meet the

conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance

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

Section 333 provides authority for a UAS to operate without airworthiness certification and sets

forth requirements for considering whether a UAS will create a hazard to users 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

a irspace 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 Secret ary shall determine, at a minimu m

(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 operation 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) Requirements for Safe Operation.

-- If the Secretary determines under this section that

certain unmanned aircraft systems may operate safely in the national airs pace system, the

Secretary shall establish requirements for the safe operation of such aircraft systems in

the national airspace system.15 In seeking this exemption, AEROQUEST submits that the DJI UAS can operate safely in the

NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI UAS;

(b) the pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The DJI UAS Demonstrate Its Safe Characteristics.

The DJI UAS does 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 capability.

i. Technical Specificati ons Of The DJI UAS.

The technical specifications of the DJI UAS are set forth by the DJI User Manual s , attached

hereto as Appendix A , Appendix B, and Appendix C

.

ii. The DJI UAS Global Positioning Modes Enable The UAS To Remain Within A

Defined Operational Area.

The DJI UAS may be operated in both manual and global positioni ng flight modes. A complete

description of the flight and navigational modes of the DJI UAS is provided at pages 11 of the

DJI Inspire 1 User Manual attached hereto as Appendix A

, pages 11 of the DJI Phantom 3

Professional User Manual attached hereto as Ap pendix B, and pages 35 of the DJI Matrice 100

User Manual attached hereto as Appendix C

.

iii. The DJI UAS Are Designed For Automatic Return To Home Point Or

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

When the Control Link is lost, the DJI UAS will remain stationary, in flight, for 3 seconds or

more. If, after 3 seconds, the DJI UAS does not reacquire control link data from the GCS, the

UAS will assume that the Control Link is lost and the will return to the home position (i.e.,

failsafe mode) via GPS, and will descend to the takeoff position and shutdown.

A complete description of the Failsafe Functions of the DJI UAS are set forth at pages

12 through 14 of the DJI Inspire 1 User Manual , attache d hereto as Appendix A, pages 12

through 1 4 of the DJI Phantom 3 Professional User Manual attached hereto as Appendix B, and

pages 42 through 44 of the DJI Matrice 100 User Manual attached hereto as Appendix C

.

iv. The DJI GCS And Its Operation.

A complete description of the operation and specifications of the DJI GCS and flight

control software is provided at pages 23 through 29 of the DJI Inspire 1 User Manual , attached

hereto as Appendix A, pages 23 through 29 of the DJI Phantom 3 Professional User Manual

attached hereto as Appendix B, a nd pages 29 through 41 of the DJI Matrice 100 User Manual

attached hereto as Appendix C

.16 b. Flight Operations Of DJI Inspire 1 UAS Is Limited To The Line Of Sight Of A

Certificated Pilot in Command With A Safety Observer.

AEROQUEST authorized production staff will be the only persons to act as a pilot i n command

(PIC) of the DJI UAS. Additionally, a safety observer will assist him /her at all times during

flight time.

c. Flights Of DJI Inspire 1 UAS Will Be Conducted Pursuant To Specific Operating

Limitations.

In seeking this exemption, AEROQUEST proposes to commercially operate DJI UAS for the

special purpose of conducting aerial video and photography over certain areas of United States,

pursuant to the following specific operating limitations.

1 . Operations authorized by this grant of exemption will be limited to the following

aircraft described in the operating documents, rotorcraft UAS weighing less than 55

pounds maximum gross weight: DJI Inspire 1 , DJI Phantom 3 , and DJI Matrice

Unmanned Airc raft Systems. Proposed operations of any other aircraft will require a new

petition or a petition to amend this grant.

2. UAS operations under this exemption will be limited to conducting operations for the

purpose of aerial video and photography.

3. The UAS may not be flown at an indicated airspeed exceeding 20 knots.

4. The UA must be operated at an altitude of no more than 400 feet above ground level

(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 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

cor rective 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 satis fy the

VLOS requirement as long as the PIC always maintains VLOS capability. The SO and

PIC must be able to communicate verbally at all times. Electronic messaging or texting is

not permitted during flight operations. The PIC must be designated before the flight and

cannot transfer his or her designation for the duration 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 se eing and

avoiding other air traffic and other ground based obstacles/obstructions and is not

permitted to operate the camera or other instruments.17 9. The operating documents and the grant of exemption must be accessible during UAS

operations and made avail able to the Administrator upon request. If a discrepancy exists

between the conditions and limitations contained in the grant of exemption and the

procedures outlined in the operating documents, the conditions and limitations contained

in the grant of exemption take precedence and must be followed. Otherwise, the operator

must follow the procedures as outlined in its operating documents. The operator may

update or revise its operating documents. It is the operator’s responsibility to track such

revision s 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 or 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

Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or

revisions to the operating documents.

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

safe flight. 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 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 funct ional 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 docume nts.

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, description 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 manufacturer Safety

Bulletins.

16. The authorized person must make an entry in the aircraft record of the corrective

action taken against discrepancies discovered between inspections.18 17. The PIC must possess at least a private pilot certificate and at least a current

thirdclass medical certificate.

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s

qua lification criteria and demonstrates the ability to safely operate the UAS in a manner

consistent with how the UAS will be operated under the exemption, including evasive

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

vehicles and structures. PIC 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 m ay

only be conducted during dedicated training sessions. During training, proficiency, and

experience

- building flights, all persons not essential for flight operations are considered

nonparticipants, and the PIC must operate the UA with appropriate distance from

nonparticipants in accordance with 14 C.F.R. § 91.119.

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All

operations must be conducted under visual meteorological conditions (VMC). If flight at

night is required, a special request will be made at the FAA office closest to proposed

area of operations. Flights under special visual flight rules (SVFR) are not authorized.

20. The UA may not operate within 5 nautical miles of an airport reference point as

den oted 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 airpor t

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 l oses 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 PIC must abort the flight in the event of unpredicted ob stacles 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 po int and land the UA 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 the 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 clas s of airspace, altitude level and potential transponder19 requirements.

26. All aircraft operated in accordance with the exemption must be identified by serial

number, registered in accordance with 14 C.F.R. part 47, and have identification (N

Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as

large as practicable.

27. Before conducting operations, the radio frequency spectrum used for operation and

control of the UA must comply with the Federal Communications Commiss ion (FCC) or

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 any time the UAS is operating. These

documents m ust be made available to the Administrator or any law enforcement official

upon request.

29. The UA must remain clear and yield the right of way to all manned aviation

operations and activities at all times.

30. The UAS may not be operated by the PIC fro m 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 a situation

arises where nonparticipat ing persons 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 g ranted 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

pr esent 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 authorized representative. Permission from

land owner/controller or authorized 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 to20 t he 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 Section 61.113(a) And (b)

Would Not Adversely Affect Safety.

AEROQUEST 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 UAS unless that PIC

has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is

able to safely operate the DJI UAS in a manner consistent with the exemption, including evasive

and emergency maneuvers and maintaining app ropriate distances from people, vessels, vehicles

and structures.

Considering AEROQUEST’s proposed area of operations, and the operating limitations set forth

above; the parallel nature of private pilot aeronautical knowledge requirements to those of

comm ercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary

to safely operate the DJI UAS, AEROQUEST submits that the additional manned airmanship

experience of a commercially certificated pilot would not correlate to the airma nship skills

necessary for AEROQUEST ’s 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).

AEROQUEST will not allow any PIC to operate the DJI UAS unless that PIC has demonstrated,

by meeting minimum flight

- hour requirements or the DJI UAS training and currency

requirements, that the PIC is able to safely operate the DJI UAS in a manner consistent with this

exemption, including evasive and emergency maneuvers and maintaining appr opriate 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 hours of those

hours as a UAS pilot operati ng 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 AEROQUEST’s proposed operations. The Administrator has held that prior documented

flight experience that was obtained in compliance with applicable regulations would ensure safe

operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for the

purpose of motion picture filming (or similar operations), t he PIC must have accumulated21 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 r ather 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 takeoff s and landings in the preceding 90

days (for currency purposes). The FAA finds that at a minimum, the flight

- hour

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

the skills necessary to safely conduct the petitioner ’s proposed operations. The FAA also

finds that prior documented flight experience that was obtained in compliance with

applicable regulations would satisfy this requirement. Training, proficiency, and

experience

- building flights can also be conducted unde r the grant of exemption to

accomplish the required flight time. During training, proficiency, and experience

- building

flights the PIC is required to operate the UA with appropriate distances in accordance

with 14 C.F.R 91.119.

Exemption No. 11138 at page 15.

Accordingly, AEROQUEST will ensure safe operations by not allowing any PIC to operate the

DJI UAS unless that PIC has demonstrated, by meeting minimum flight

- hour and currency

requirements, that the PIC is able to safely operate the DJI UAS in a mann er consistent with the

exemption, including evasive and emergency maneuvers and maintaining appropriate distances

from people, vessels, vehicles and structures.

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not

Adversely Affect Safety.

The equivalent level of safety established by Section 91.7(a) will be maintained because prior to

every flight, AEROQUEST will ensure that the DJI UAS is in an airworthy condition based upon

the UAS’s compliance with its operating documents and as stated in the conditions and

l imitations 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, 11 063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150,

11153, 11156, 11157, 11158, 11159, 11160, 11161).

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not

Adversely Affect Safety.

The equivalent leve l of safety established by Section 91.121 will be maintained because the

altitude information of the DJI UAS will be provided to the PIC via GPS equipment and a radio

communications telemetry data link, which downlinks from the UA to the GCS for active22 monitoring of the flight path and altitude. This altitude information, combined with

AEROQUEST’s operation of the DJI UAS within visual line of sight, at or below 500 feet AGL,

will ensure a level of safety equivalent to Section 91.121. The altitude inform ation will be

generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude

initiation point is automatically established by the UAS at ground level.

The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063,

11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157,

11158, 11159, 11160, 11161).

5. Reasons Why An Exemption From The Requirements Of Section 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 UAS; (2) the

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

operations. Accordingly, AEROQUEST will ensure that it will safely operate the battery

powered DJI UAS during daylight hours in VFR conditions, with enough battery power to fly for

a total duration of 23 minutes.

Here, as in Exemption No. 11109, the technical specifications of the DJI UAS; the limitations on

the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be

ensured as the DJI UAS provide audible and visual warnings to the PIC at the GCS when the

UAS experiences low battery voltage, the first warning occurring at approximately 33%

remaining battery power, and again at approximately 10% remaining battery power. At the

critically low battery level, the DJI UAS will descend and land automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that

safety is not adversely affected when the technical characteristics and operating limitations of the

UAS are considered. Relief has been granted for manned aircraft to operate at less than the

minimums prescribed in Section 91 .151, including Exemption Nos. 2689, 5745, and 10650.

Moreover, the FAA has previously granted 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), An d 91.417(a) & (b) Would Not Adversely Affect Safety.

In seeking this exemption, AEROQUEST submits that the equivalent level of safety with regard

to the regulatory maintenance and alteration requirements established by Sections 91.405(a),

91.407(a)(1), 91 .409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because AEROQUEST will

use trained technicians to perform maintenance, alterations, o r preventive maintenance on the

UAS using the methods, techniques, and practices prescribed in the operating documents (i.e.,23 AEROQUEST Aerial Operations Manual, Monthly Maintenance Log, and DJI UAS User

Manual s ). Furthermore, AEROQUEST will document and maintain all maintenance

records for the DJI Inspire 1 UAS.

Since the DJI UAS will be inspected as prescribed by the o perating documents, AEROQUEST

will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and

91.409(a)(2). A copy of the DJI UAS User Manuals are attached hereto as Appendix A , B, C

.

Likewise, the exemption sought will not adversely affect safety because AEROQUEST will use

trained technicians to perform maintenance, alterations or preventive maintenance on the UAS

using the methods, techniques, and practices prescribed by the operating documents.

Furthermore, the exemption sought would maintain an equivalent level of safety established by

Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI UAS will

be performed by trained technicians. Maintenance will be docume nted 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 AEROQUEST’s proposed operating limitations, the operating documents,

and the technical aspects of the DJI UAS, AEROQUEST 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 p resented 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 accorda nce with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA)

and 14 C.F.R. § 21.16 entitled Special Conditions, AEROQUEST requests that the FAA

prescribe special conditions for the intended operation of the DJI 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 §§ 61.113(a) & (b), 91.7 (a),

91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), a nd 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

accordanc e 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, for24 operation of the DJI UAS, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain

adequate or appropriate safety standards, due to the novel or unusual design features of the

aircraft. Section 21.16, entitled Special Conditions, states the following:

If the FAA finds that the airworthiness regulations of this subchapter do not contain

adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller

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

he prescribes special conditions and amend ments thereto for the product. 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 equivalen t to that established in the regulations.

See 14 C.F.R. § 21.16.

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

prescribe special conditions for AEROQUEST ’s intended operation of the DJI UAS, which

contain such safety s tandards 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 In The Federal Register, stating: The Rules

From Which AEROQUEST Seeks Exemption:

AEROQUEST 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 AEROQUEST Seeks:

This exemption will permit AEROQUEST to commercially operate an Unmanned

Aircraft System (UAS) for the purpose of con ducting aerial video and photography over

certain areas of the United States.

• Any Additional Information, Views, Or Arguments Available To Support

AEROQUEST’s Request.

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

(FMR A) Section 333, which directs the Secretary of Transportation to determine if certain UAS

may operate safely in the NAS. As such, AEROQUEST’s request for exemption may be granted

pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set f orth 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 wit hout airworthiness certification.

As discussed in detail above, AEROQUEST will operate the DJI UAS safely in the NAS,25 without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to

national security.26 CONCLUSION

As set forth herein, AEROQUEST seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section

333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe

operation of the DJI UAS commercially, without an airworthiness certificate, for the limited

p urpose 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 t he interests of the public, by

allowing AEROQUEST to safely, efficiently, and e conomically operate the DJI UAS

commercially within the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA

Modernization and Reform Act of 2012, Se ction 333, AEROQUEST respectfully requests 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 AEROQUEST to operate the DJI UAS commercially for

the purpose of conducting aerial video and photography over certain areas of the United States.

Dated: March 3, 2016

Respectfully submitted,

Wesley Parsons

Member

AERO QUEST L.L.C.

63 6 Baker St.

Costa Mesa, CA 92626

949

- 302

- 4631

wparsons.media@gmail.com27 Appendices:

Appendix A

– Link to DJI Inspire 1 User Manual: Click on link below

http://download.djiinnovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.4_en.p

df

Appendix B

– Link to DJI Phantom 3 Professional User Manual: Click on link below

https://dl.djicdn.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual__V1.6.p

df

Appendix C

– Link to DJI Matrice 100 User Manual: Click on li nk below

http://download.dji innovations.com/downloads/dev/Matrice/en/M100_User_Manual_v1.0_en.pd

f