UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERALAVIATION ADMINISTRATION WASHINGTON, DC Regulatory Docket No.

_____ _

IN THE MATTEROF THE PETITION FOR EXEMPTION OF: EDWARD STANZA FORAN EXEMPTION SEEKING RELIEF 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 DJI Phantom 3, DJI Inspire 1 UNMANNEDAIRCRAFT SYSTEMS PURSUANTTO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on September 11, 2015 Edward Stanza 1954Argyle Ave. #D Los Angeles, CA 90068 409-599-9846



### liPage

# ...... ______________

TABLE 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

.............................................................................. 6 THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH EDWARD STANZA SEEKS EXEMPTION

........................................................................................................................... 6 THE EXTENT OF RELIEF EDWARD STANZAAND THE REASON EDWARD STANZA SEEKS THE RELIEF

.............................................................................................................9 THE REASONSWHY GRANTING EDWARD STANZA REQUESTWOULD BE IN THE PUBLIC INTEREST

....................................................................................................11 THE REASONSWHY GRANTING THE EXEMPTIONWOULD NOTADVERSELY AFFECT SAFETY

.................................................................................................................13 SUMMARYTHAT CAN BE PUBLISHED IN THE FEDERAL REGISTER

............................23 ANYADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT EDWARD STANZA'S REQUEST

...........................................................24 CONCLUSION

...................................................................................................................... 24 APPENDICES

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

21PageGLOSSARY OF ABBREVIATIONS AGLAbove Ground Level AOI Area of Interest ATC AirTraffic Control ATO AirTraffic Organization AVAerial Vehicle CFR Code of Federal Regulations GOA Certificate ofAuthorization FAA Federal Aviation Administration FAR Federal Aviation Regulation GCS Ground Control Station GPS Global Positioning System LOL Loss of Link NAS NationalAirspace System NOT AM Notice to Airman PIC Pilot In Command Section 333 FAA Modernization and Reform Act of2012 (FMRA) Section 333 SO Safety Observer SOP Standard Operating Procedures UA Unmanned Aircraft UAS Unmanned Aircraft System VFR Visual Flight Rules VLOS Visual Line ofSite VMC Visual Meteorological Conditions VTOL Vertical Takeoffand Landing

3IPageSUMMARY Edward Stanza 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 pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA). This exemption will permit EDWARD STANZA to operate an Unmanned Aircraft System (UAS) forthe commercial purpose of conducting aerial video and photography ofconstruction sites, real estate, Special Events and landscape over certain areas ofthe United States. INTRODUCTION AND INTERESTS OF THE PETITIONER Edward Stanza provides clients with expertise in advanced photography and videography technologies to increase productivity and effectiveness. He has over4 years recreational/hobby experience in remote controlled vehicles. Additionally, he currently has 41 hours flight in Airplane Single Engine Land; The objective of Edward Stanza's aerial video and photography operations is to provide high quality imaging for a variety ofcommercial, public, and residential uses, specificallytargeting: 

### D Real estate and private property aerial photography D Aerial event photography D Search and Rescue

o Aerial images used for inspections ofpublic and private structures, and D Increase public knowledge of UAS and promote safe UAS operations.

BACKGROUND Unmanned Aircraft Systems: DJI Phantom 3, DJI Inspire 1 Edward Stanza seeks an exemption to operate DJI systemsfor compensation or hire within the NAS.

D DJI Models: DJI Phantom 3, and Inspire 1 are lightweight (under 55 lbs), battery operated Multi-RotorVTOL aircraft DAn on-board flight computerwith GPS navigation and location abilitythat receives signals forflight controls from a ground-based transmitter/controller DAn on-board camera attached to the UAvia three axis gimbal, capable ofcapturing full color, high definition imagery D An on-board telemetry system that delivers flight data from the on-board flight computer to the on-board radio transmitter including altitude AGL, horizontal and vertical speed, compass direction offlight and direction backto its launch site

The OJI UAS that will be operated by Edward Stanza will be registered in accordance with 49 U.S.C. 44103, Registration ofAircraft, as well as 14 C.F.R Part 47, AircraftRegistration, and marked in accordance with 14 C.F.R. Part45, Identification andRegistration Marking.

41Pagel

BASIS FOR PETITION Petitioner, Edward Stanza, pursuantto the provisions ofthe Federal Aviation Regulations (14 C.F.R. 

### § 11.61) and the FAA Modernization and Reform Act of2012 (FMRA), Section 333, Special Rules forCertain UnmannedAircraftSystems, hereby petitionsthe Administratorto commercially operate the DJI Phantom 3, OJI Inspire 1 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 ofthe speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, Edward Stanza's operation of DJI Phantom 3, DJI Inspire 1 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, Edward Stanza requests relieffrom Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections setforth requirements for maintenance that only applyto aircraftwith an airworthiness certificate. Edward Stanza submits thatthe requested relief is proper since an equivalent level ofsafetywill be ensured. Edward Stanzawill use experienced personnel ortechnicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3, DJIInspire 1 Instruction Manual). Furthermore Edward Stanza will document and maintain all maintenance records forthe DJI Phantom 3, DJI Inspire 1 UAS. Edward Stanza seeks relieffrom Section 91.7(a), entitled Civilaircraftairworthiness, because the DJI Phantom 3, DJIInspire 1 UAS does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Edward Stanza submits that he will ensure thatthe DJI Phantom 3, DJI Inspire 1 UAS is in an airworthy condition, priorto every flight, by determining thatthe UAS is in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3, DJIInspire 1 Instruction Manual), and thatthe aircraft is in a condition for safe flight. Edward Stanza also seeks an exemption from the requirements ofSection 91.121, entitled AltimeterSettings, as the DJI Phantom 3, DJI Inspire 1 UAwill not have a typical barometric altimeter onboard. However, altitude information ofthe DJI Phantom 3, DJI Inspire 1 UAS will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UAto the GCSfor

SIPageactive monitoring ofthe flight path. This altitude information, combined with Edward Stanza's operation ofthe DJI Phantom 3, DJI Inspire 1 UAS within visual line ofsight, at or below 400 feetAGL, will ensure a level ofsafety equivalentto Section 91.121. Additionally, Edward Stanza seeks an exemption from the requirements ofSection 91.151(b), entitled Fuelrequirements forflightin VFR conditions. EDWARD STANZA submitsthat safetywill not be affected by operation ofthe DJI Phantom 3, DJIInspire 1 UA during daylight hours in visual meteorological conditions (VMC) undervisual flight rules (VFR), with enough battery powerto fly for atotal duration ofapproximately 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly afterthatfor at least4.5 minutes. In accordance with 14 C.F.R. 

### § 11.81, EDWARD STANZA provides the following information in support of its petition for exemption: A. Name And Address OfThe Petitioner. The name and address ofthe Petitioner and point of contact is: EDWARD STANZA 1954ARGYLE AVE. #D LOS ANGELES, CA90068 Tel: (409) 599-9846 Email: edwardstanza@yahoo.com B. The Specific Sections Of 14 C.F.R. From Which Edward Stanza Seeks Exemption. 1. Edward Stanza Seeks Exemption From The Requirements OfSection 61.113(a) And 

### (b). Section 61.113, entitled Private pilot privileges and limitations: Pilotin 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) ofan aircraftthat is carrying passengers or propertyfor compensation or hire; nor maythat person, for compensation or hire, act as PIC ofan aircraft. (b) A private pilot may, for compensation or hire, act as PIC ofan aircraft in connection with any business or employment if- (1) The flight is only incidental to that business oremployment; and (2) The aircraft does not carry passengers or property for compensation or hire. 2. Edward Stanza Seeks Exemption From The Requirements OfSection 91.7(a). Section 91.7, entitled Civilaircraftairworthiness, subsection (a), states the following: (a) No person mayoperate a civil aircraft unless it is in an airworthy condition.



### GIPage3. EDWARD STANZA Seeks Exemption From The Requirements OfSection 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 orflight level ofthat aircraft, as the case may be, by reference to an altimeterthat is set, when operating (1) Below 18,000feet MSL, to-- (i) The current reported altimeter setting ofa station along the route and within 100 nautical miles ofthe aircraft; (ii) Ifthere is no station within the area prescribed in paragraph (a)(1)(i) ofthis section, the current reported altimetersetting ofan appropriate available station; or (iii) In the case ofan aircraft notequipped with a radio, the elevation ofthe departure airport

or an appropriate altimeter setting available before departure. 4. EDWARD STANZA Seeks Exemption From The Requirements OfSection 91.151(b). Section 91.151, entitled Fuelrequirements forflightin VFR conditions, subsection (b), states the following: (b) No person maybegin 

### a flightin 

### a rotorcraft under VFR conditions unless (considering windandforecast weatherconditions) there is enough fuel to fly to the firstpointofintended landing and, assuming normalcruising speed, to flyafterthatforatleast20minutes. 5. EDWARD STANZA Seeks Exemption From The Requirement OfSection 91.405(a). Section 91.405, entitled Maintenance required, subsection (a), states the following: Each owner or operator ofan aircraft- (a) Shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter[.] 6. EDWARD STANZA Seeks Exemption From The Requirements OfSection 91.407(a)(1) Section 91.407, entitled Operation aftermaintenance, preventive maintenance, rebuilding,

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

71Page(1) It has been approved for return to service by a person authorized under § 43.7 ofthis chapter[.] 7. EDWARD STANZA Seeks Exemption From The Requirements OfSections 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) ofthis section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

- (1) An annual inspection in accordance with part43 ofthis chapter and has been approved for return to service by a person authorized by§43.7 ofthis chapter; or (2) An inspection forthe issuance ofan airworthiness certificate in accordancewith part 21 ofthis chapter. 8. EDWARD STANZA Seeks Exemption From The Requirements OfSections 91.417(a) And 91.417(b). Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following: (a) Exceptforwork performed in accordance with§§ 91.411 and 91.413, each registered owner or operator shall keep the following records forthe periods specified in paragraph (b) ofthis section: (1) Records ofthe maintenance, preventive maintenance, and alteration and records ofthe 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) ofthe work performed; and (ii) The date ofcompletion ofthe work performed; and (iii) The signature, and certificate numberofthe person approving the aircraftfor return to service. (2) Records containing the following information: (i) The total time in service ofthe airframe, each engine, each propeller, and each rotor (ii) The current status oflife-limited parts ofeach airframe, engine, propeller, rotor, and appliance.

BIPage(iii) Thetime since last overhaul ofall items installed on the aircraftwhich are required to be overhauled on a specified time basis. (iv) The current inspection status ofthe aircraft, including the time since the last inspection required by the inspection program underwhich the aircraft and its appliances are maintained. (v) The current status ofapplicable airworthiness directives (AD) and safety directives including, for each, the method ofcompliance, the AD orsafety directive number and revision date. Ifthe AD orsafety directive involves recurring action, the time and date when the next action is required. (vi) Copies ofthe forms prescribed by§43.9(d) ofthis chapterfor each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances. (b) The owneror operator shall retain the following records forthe periods prescribed: (1) The records specified in paragraph (a)(1) ofthis section shall be retained until the work is repeated orsuperseded by otherwork orfor 1year afterthe work is performed. (2) The records specified in paragraph (a)(2) ofthis section shall be retained and transferred with the aircraft atthe time the aircraft is sold. (3) A list ofdefects furnished to a registered owneror operator under§43.11 ofthis chapter shall be retained until the defects are repaired and the aircraft is approved for return to service. C. The Extent Of Relief EDWARD STANZA Seeks And The Reason EDWARD STANZA Seeks The Relief. 1. ExtentOf Relief EDWARD STANZA Seeks And The Reason EDWARD STANZA Seeks Relief From Section 61.113(a) And (b). Relieffrom Section 61.113(a) and (b) entitled Private pilotprivileges andlimitations: Pilot in command, is requested to the extent necessaryto 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 requirements, to conductthe proposed UAS flight operations for compensation or hire. This relief is requested since the limitations setforth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC ofan aircraft in connection with any business oremployment if: (1) The flight is only incidental to that business oremployment; and (2) The aircraft does notcarry passengers or property for compensation or hire. As setforth more fully below, EDWARD STANZA submitsthat an equivalent level of

91Pagesafety will be maintained because no PIC will be allowed to operate the OJI Phantom 3, OJI Inspire 1 UAS unlessthat PIC has met certain flight-hour and currency requirements, demonstrating thatthe PIC is able to safely operate the DJI Phantom 3, DJIInspire 1 UAS in a mannerconsistentwith 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, EDWARD STANZAsubmits that all flights ofthe OJI Phantom 3, OJI Inspire 1 UAS, conducted by the PIC pursuantto the grantofthis Petition: (1) will be incidental to EDWARD STANZA business; and (2) will not carry passengers or propertyfor compensation or hire. 2. Extent Of Relief EDWARD STANZA Seeks And The Reason EDWARD STANZA Seeks Relief From Section 91.7(a). Relieffrom Section 91.7(a) entitled Civilaircraftairworthiness, is requested to the extent required to allow EDWARD STANZAto determine thatthe DJI Phantom 3, DJIInspire 1 UAS is in airworthy condition priorto every flight by ensuring thatthe UAS is in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3, DJI Inspire 1 Instruction Manual). EDWARD STANZAseeks the requested relief because the OJI Phantom 3, OJI Inspire 1 UAS does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, EDWARD STANZAwill ensure thatthe DJI Phantom 3, DJIInspire 1 UAS is in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3, DJI Inspire 1 UAS Instruction Manual) prior to every flight, and further, determine thatthe aircraft is in condition for safe flight, as stated in the conditions and limitations below. 3. Extent Of Relief EDWARD STANZA Seeks And The Reason EDWARD STANZA Seeks Relief From Section 91.121. Relieffrom Section 91.121, entitled Altimeter settings, may be required to allowflight operations ofthe OJI Phantom 3, OJI Inspire 1 UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data linkto downlink altitude information from the UAto the PIC atthe ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), EDWARD STANZAseeks the requested relief because the DJI Phantom 3, OJI Inspire 1 UA altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure orfield altitude, before each flight. Considering the limited altitude ofthe proposed operations, relieffrom 14 CFR 91.121 is soughtto the extent necessaryto comply with the applicable conditions and limitations stated below. As more fully setforth herein, an equivalent level ofsafety will be maintained since the DJI Phantom 3, OJ! Inspire 1 UA is equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established priorto each flight, and provides the PIC with altitude information ofthe UAon the heads-up display ofthe GCS.

10 

### I Page4. ExtentOf Relief EDWARD STANZA Seeks AndThe Reason EDWARD STANZA Seeks Relief From Section 91.151(b). Relieffrom Section 91.151(b) entitled Fuel requirements forflight in VFR conditions, is requested to the extent required to allow flights ofthe battery powered OJI Phantom 3, OJI Inspire 1 UA during daylight hours in visual meteorological conditions (VMC), undervisual flight rules (VFR), for a total duration of 13.5 minutes to the first point ofintended landing and, assuming normal cruising speed, to fly afterthat for at least4.5 minutes. EDWARD STANZAseeks the requested relief because without an exemption from Section 91.151(b), the flight time duration ofthe battery powered OJI Phantom 3, OJI Inspire 1 UAwill severely constrain the practicality ofany aerial video or still photo flight operations that EDWARD STANZA proposes to conduct pursuantto this Petition. Significantly, as set forth below, the technical specifications ofthe OJI Phantom 3, OJI Inspire 1 UAS, the DJI Phantom 3, DJIInspire 1operating documents, and EDWARD STANZA'S proposed operating limitations, ensure that EDWARD STANZAwill safely operate the battery powered OJI Phantom 3, OJI Inspire 1 UAduring daylight hours in visual meteorological conditions (VMC), undervisual flight rules (VFR), with enough battery power to fly for atotal duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly afterthatfor at least4.5 minutes. 5. ExtentOf Relief EDWARD STANZA Seeks And The Reason EDWARD STANZA 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 applyto aircraftwith an airworthiness certificate, EDWARD STANZA requests relief from these Sections because the DJI Phantom 3, DJI Inspire 1 UAS does not require airworthiness certificates. As setforth morefully below, the DJI Phantom 3, DJIInspire 1 UAS meets the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, EDWARD STANZAwill use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3, DJIInspire 1). Furthermore, EDWARD STANZAwill document and maintain all maintenance records forthe OJI Phantom 3, OJI Inspire 1 UAS. D. The Reasons Why Granting EDWARD STANZA's RequestWould Be InThe Public Interest; That Is, How ItWould BenefitThe PublicAs A Whole. Granting the present Petition will furtherthe public interest by allowing EDWARD STANZA to safely, efficiently, and economically perform aerial video and photography ofconstruction sites, real estate, Special Events and landscape over certain areas ofthe United States. Additionally, use ofthe OJI Phantom 3, OJI Inspire 1 UASwill decrease congestion ofthe NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of EDWARD STANZA'S proposed operation ofthe DJI Phantom 3, DJIInspire 1 UAS will be realized without implicating any privacy issues.

111Page1. The PublicWill Benefit From Decreased Congestion OfThe NAS. The OJI Phantom 3, DJI Inspire 1 UA is battery powered and serves as a safe, efficient, and economical alternative to the manned aircrafttraditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions,

an exemption allowing the use ofa DJI Phantom 3, DJIInspire 1 UAS would reduce the amount ofmanned 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 ofmanned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraftwill be reduced. The OJI Phantom 3, OJI Inspire 1 UA does not require an airportto takeoffor land. Likewise, a reduction ofmanned aircraft conducting aerial video and photography missionswould result in fewer aircraftthat must be handled by airtraffic control during the ground, takeoff, departure, arrival, and landing phases offlight operations. 2. The PublicWill Benefit From The SafetyAnd EfficiencyOfThe DJI Phantom 3, DJI Inspire 1 UAS. Conducting aerial acquisitions with the DJI Phantom 3, DJIInspire 1 UAS, instead of manned aircraft, will greatly benefitthe public by drastically reducing the levels ofair and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, the DJI Phantom 3, DJIInspire 1 UAS produces no air pollution, and is the mostviable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraftthat are typically utilized for aerial video and photography, while burning approximately 20-30 gallons per hourof leaded aviation fuel. The OJI Phantom 3, OJI Inspire 1 UA, while reducing the carbon footprint ofaerial acquisitions, also eliminates noise pollution, as the UAs are propelled by battery powered electric motors, ratherthan an internal combustion engine. By using the DJI Phantom 3, DJIInspire 1 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 access methods, will be substantially reduced or completely eliminated. Aside from the lack offlight crew members located onboard the aircraft, the OJI Phantom 3, OJI Inspire 1 UA (under 31bs, and 6.51b. gross weight 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 to the manned aircraftthattypically conduct similar operations (weighing approximately 6,000 pounds with awingspan ofapproximately42 feet, a length of 34 feet, and afuel capacity of 180gallons). 3. Performing Aerial Video and Photography OperationsWith The DJI Phantom 3, DJI Inspire 1 UASWill BenefitThe Economy. In addition to being safe and efficient, the DJI Phantom 3, DJIInspire 1 UAS is also an economical alternative to using manned aircraftto conduct similar aerial operations. As such, operation ofthe OJI Phantom 3, OJI Inspire 1 UAS will allow United States based companies, like EDWARD STANZA'S, to remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost ofaviation fuel and the Environmental Protection Agency ("EPA") regulatory actions phasing out leaded aviation fuels, U.S. owned

12 

### I Pageand operated companies must adopt new and alternative technology in orderto remain competitive. Operating the battery powered DJI Phantom 3, DJI Inspire 1 UASs is one such technology that not only allows companies greateroperational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost ofatraditional manned aircraft. By operating the DJI Phantom 3, DJIInspire 1 UAS, companies such as EDWARD STANZA's, can remain competitive and profitable, and therefore, provide greaterjob stabilityto employees and contractors, which will ultimately contribute to growth ofthe U.S. economy. Improved financial performance of U.S. companies, through commercial use of the DJI Phantom 3, DJIInspire 1 UAS, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in orderto remain competitive both in the United States and abroad. 4. ThereAre No Privacy Issues. Similarto the manned aerial acquisition flight operations that have been conducted for decades, EDWARD STANZA's proposed operation ofthe DJI Phantom 3, OJI Inspire 1 UAS will not implicate any privacy issues. Specifically, the DJI Phantom 3, DJIInspire 1 UAS will be operated only in compliance with operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3, DJI Inspire 1) 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 ReasonsWhy GrantingThe ExemptionWould NotAdverselyAffectSafety, Or HowThe ExemptionWould ProvideA Level OfSafetyAt Least Equal ToThat Provided ByThe Rule From Which EDWARD STANZA Seeks Exemption. 1. ReasonsWhyThe DJI Phantom 3, DJI Inspire 1 UA Meets The Conditions Of The FAA Modernization and Reform Act of2012 (FMRA) Section 333. In consideration ofthe size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, EDWARD STANZA'S operation ofthe DJI Phantom 3, DJI Inspire 1 UAS meets 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 operatewithout airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users ofthe NAS orthe public, orotherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part: (a) In Generai.--Notwithstandinganyotherrequirement ofthis subtitle, andnot laterthan 180 days afterthe date ofenactmentofthisAct, the SecretaryofTransportation shalldetermine ifcertain unmannedaircraftsystems mayoperate safelyin the national airspace system before completion oftheplan andrulemaking requiredbysection 332 of thisActorthe guidance requiredbysection 334 ofthisAct.

13IPage(b) Assessment ofUnmannedAircraftSystems.--ln making the determination under subsection (a), the Secretaryshalldetermine, at

### a minimum-- (1) which types ofunmannedaircraftsystems, ifany, as a result oftheirsize, weight, speed, operationalcapability, proximityto airports andpopulatedareas, andoperation within visual line ofsightdo notcreate a hazardto users ofthe nationalairspace system orthepublic or pose 

### a threatto nationalsecurity; and (2) whether

### a certificate ofwaiver, certificate ofauthorization, orairworthiness certification undersection 44704 oftitle 49, United States Code, 

### is requiredfor the operation ofunmannedaircraftsystems identified underparagraph (1). (c) Requirements forSafe Operation.--lfthe Secretarydetermines underthis section that certain unmannedaircraftsystems mayoperate safelyin the nationalairspace system, the Secretaryshallestablish requirements forthe safe operation ofsuch aircraftsystems in the nationalairspace system. In seeking this exemption, EDWARD STANZA submitsthatthe DJI Phantom 3, DJIInspire 1 UAS can operate safely in the NAS pursuantto FMRA Section 333, as demonstrated by: (a) the characteristics ofthe DJI Phantom 3, DJI Inspire 1 UAS; (b) the pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications OfThe DJI Phantom 3, DJI Inspire 1 UAS Demonstrate Its Safe Characteristics. The DJI Phantom 3, DJIInspire 1 UAS does not create a hazard to users ofthe NAS orthe public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability. 

### i. Technical Specifications OfThe DJI Phantom 3, DJI Inspire 1 UAS. The technical specification ofthe DJI Phantom 3, DJI Inspire 1 UAS is setforth bythe DJI Phantom 3, DJIInspire 1 Specifications and Data Sheet, attached hereto as ExhibitA and B. ii. The DJI Phantom 3, DJI Inspire 1 UAS Autonomous FlightAnd Navigation Modes Enable The UASs To Remain Within A Defined Operational Area. The DJI Phantom 3, DJIInspire 1 UAS may be operated in both manual and fully autonomous flight modes. A complete description ofthe flight and navigational modes ofthe DJI Phantom 3, DJIInspire 1 UAS is provided in the DJI Phantom 3, DJIInspire 1 User Manual, attached hereto as Exhibit C and D. iii. The DJI Phantom 3, DJI Inspire 1 UAS is Designed ForAutomatic Return To Home Point Or Hover In The Event Of Loss OfThe Control Link Or Navigation.

14 

### I PageWhen the Control Link is lost, the DJI Phantom 3, DJI Inspire 1 UAwill remain stationary, in flight, for 

### 3 seconds or more. If, after 

### 3 seconds, the DJI Phantom 

### 3, DJI Inspire 

### 1 UA does not reacquire control link data from the GCS, the UAs will assumethatthe 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 ofthe Failsafe Functions ofthe DJI Phantom 

### 3, DJI Inspire 

### 1 UAS

are setforth in the DJI Phantom 3, DJI Inspire 1 User Manual, attached hereto as Exhibit C and D. iv. The DJI Phantom 

### 3, DJIInspire 

### 1 GCSAnd Its Operation. A complete description ofthe operation and specifications ofthe DJI Phantom 3, DJIInspire 1 GCS and flight control software is provided in the User Manual. DJI Phantom 3, DJI Inspire 

### 1 User Manual is attached hereto as Exhibits C and D. b. FlightOperations Of DJI Phantom 

### 3, DJI Inspire 

### 1 UAS is Limited ToThe Line Of SightOfA Pilot in Command With A Safety Observer. EDWARD STANZAwill only utilize pilots who possess a current and valid medical certificate to act as a pilot in command (PIC) ofthe DJI Phantom 3, DJIInspire 1 UAS. Additionally, a safety observerwill assist all pilots during flight time.

c. Flights Of DJI Phantom 

### 3, DJIInspire 

### 1 UASWill Be Conducted PursuantTo Specific Operating Limitations. In seeking this exemption, EDWARD STANZA proposes to commercially operate DJI Phantom 3, DJI Inspire 1 UAS for the special purpose ofconducting aerial video and photography over certain areas of United States, pursuantto the following specific operating limitations: 

### 1. Operations authorized bythis grant ofexemption will be limited to the following aircraft described in the operating documents, rotorcraft UASsweighing less than 

### 55 pounds maximum gross weight: DJI Phantom 3, DJIInspire 1 Unmanned Aircraft Systems. Proposed operations ofany otheraircraftwill require a new petition or a petition to amend this grant. 2. UASoperations underthis exemption will be limited to conducting operations forthe purpose ofaerial 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 morethan 400 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved byATC. All altitudes reported to ATC must be in feet AGL. 

### 5. The UA must be operated within visual line ofsight (VLOS) ofthe PIC at all times. This requires the PIC to be able to use human vision unaided by any device otherthan corrective

15 

### I Pagelenses. 6. The use offirst person view (FPV) by the PIC orsafety observer (SO) is not permitted. 7. All operations must utilize a safety observer (SO). The SO may be used to satisfythe 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 ortexting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or herdesignation forthe duration ofthe flight. The PIC must ensure thatthe 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 avoiding other air traffic and otherground based obstacles/obstructions and is not permitted to operate the camera or other instruments. 9. The operating documents and the grant ofexemption must be accessible during UAS operations and made available to the Administrator upon request. Ifa discrepancyexists between the conditions and limitations contained in the grant ofexemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant ofexemption take precedence and must be followed. Otherwise, the operator mustfollow 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 updated and revised documentsto the Administrator upon request. The operator must also present updated and revised documents ifit petitions for extension

or amendmentto the grantofexemption. Ifthe operator determines that any update or revision would affectthe basis upon which the FAAgranted the exemption, then the operator must petition for amendmentto its grant ofexemption. The FAA's UAS Integration Office (AFS-80) may be contacted ifquestions arise regarding updates or revisions to the operating documents. 10. Priorto each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. Ifthe inspection reveals a condition that affects the safe operation ofthe UAS, the aircraft is 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 mustbe 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 affectthe UAS operation

orflight characteristics, e.g. replacement ofa flight critical component, must undergo a functional test flight. The PIC who conducts the functional testflight must make an entry in the aircraft records. 12. The pre-flight inspection mustaccountfor all potential discrepancies, e.g. inoperable components, items, or equipment, notalready covered in the relevant sections ofthe operating documents. 13. The operator mustfollow the UAS manufacturer's aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. 14. The operator mustcarry out its maintenance, inspections, and record keeping

16 

### I Pagerequirements, 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 ofwork accomplished, and the signature ofthe authorized person returning the UAS to service. 15. Each UAS operated underthis exemption must comply with all manufacturer Safety Bulletins. 16. The authorized person must make an entry in the aircraft record ofthe corrective action taken against discrepancies discovered between inspections. 17. The PIC must possess at least a current medical certificate. 18. The operator may not permit any PIC to operate unless the PIC meets the operator's qualification criteria and demonstratesthe abilityto safely operate the UAS in a manner consistent with how the UAS will be operated underthe 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 forthe purposes oftraining the operator's PIGs are permitted underthe terms ofthe exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experiencebuilding flights, all persons not essential forflight operations are considered nonparticipants, and the PIC must operate the UAwith 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 undervisual meteorological conditions (VMC). Ifflight at night is required, a special request will be made atthe FAA office closest to proposed area ofoperations. Flights underspecial visual flight rules (SVFR) are notauthorized. 20. The UA may notoperate within 5 nautical miles ofan airport reference point as denoted

on a current FAA-published aeronautical chart unless a letterofagreementwith that airport's management is obtained, and the operation is conducted in accordance with a NOT AM as required by the operator's COA. The letter ofagreementwith the airport management must be made available to the Administrator upon request. 21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud orwhen visibility is less than 3 statute miles from the PIC. 22. Ifthe UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in accordance with the operating documents. 23. The PIC mustabortthe flight in the event of unpredicted obstacles oremergencies in accordance with the operating documents. 24. The PIC is prohibited from beginning a flight unless (considering wind and forecast

17 

### I Pageweather conditions) there is enough powerto fly at normal cruising speed to the intended landing point and land the UAwith 25% battery power remaining. 25. The operator must obtain an AirTraffic Organization (ATO) issued Certificate ofWaiver

orAuthorization (COA) priorto conducting any operations underthe grant ofexemption. This COAwill also require the operatorto request a Notice to Airman (NOT AM) not more than 72 hours in advance, but not less than 48 hours priorto the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class ofairspace, altitude level and potential transponder requirements. 26. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (NNumber) markings in 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 ofthe UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 28. The documents required fewerthan 14 C.F.R. 91.9 and 91.203 must be available to the PIC atthe Ground Control Station ofthe UAS any timethe UAS is operating. These documents must be made available to the Administrator or any law enforcement official upon request. 29. The UA must remain clear and yield the right ofway to all manned aviation operations and activities at all times. 30. The UAS may not be operated bythe PIC from any moving device orvehicle. 31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons otherthan the PIC, SO, operatortrainees or essential persons), vessels, vehicles, and structures unless:

a. Barriers orstructures are presentthat sufficiently protect nonparticipating persons from the UA and/or debris in the event ofan accident. The operator must ensure that nonparticipating persons remain undersuch protection. Ifa situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe UA, flight operations must cease immediately and/or; b. The aircraft is operated nearvessels, vehicles orstructureswhere the owner/controller ofsuch vessels, vehicles or structures has granted permission and the PIC has made a safety assessment ofthe risk ofoperating closerto those objects and determined that it does not present an undue hazard, and;

c. Operations nearerto the PIC, SO, operatortrainees or essential persons do not present an undue hazard to those persons per§ 91.119(a). 32. All operations shall be conducted over private or controlled-access propertywith

18 

### I Pagepermission from the land owner/controller orauthorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted. 33. Any incident, accident, orflight operation thattransgresses the lateral orvertical boundaries ofthe operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. 2. ReasonsWhyAn Exemption From The Requirements OfSection 61.113(a) And (b) Would NotAdverselyAffectSafety. EDWARD STANZAsubmits thatthe equivalent level ofsafety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI Phantom 3, DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, thatthe PIC is able to safely operate the DJI Phantom 3, DJIInspire 1 UAS in a mannerconsistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. EDWARD STANZA'S specific proposed flight operations. The FAA has previously granted relieffrom Section 61.113(a) and (b) specificto 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). EDWARD STANZAwill not allow any PIC to operate the DJI Phantom 3, DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight-hour requirements orthe DJI Phantom 3, DJIInspire 1 UAS training and currency requirements, that the PIC is able to safely operate the DJI Phantom 3, DJI Inspire 1 UAS in a manner consistentwith this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Specifically, the PIC must have accumulated and logged, in a mannerconsistent with 14 C.F.R. 

### § 61.51 (b), 25 hours oftotal time as a UAS rotorcraft pilot (with a minimum of5 hours ofthose hours as a UAS pilot operating the same make and model of UAS to be used for operations underthe exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (forcurrency purposes). As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience

19 

### I Pagethat was obtained in compliance with applicable regulations will ensure an equivalent level ofsafety during EDWARD STANZA'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 priorto conducting operations for the purpose ofmotion picture filming (or similaroperations), 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. Priorto operations under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of5 hours as a UAS pilot operating the same make and model of UAS to be used for operations underthe exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive ratherthan additive; i.e. 5 hours make and model time may be included in the 10 hours ofmulti-rotortime 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 and landings in the preceding 90 days (for currency purposes). The FAAfinds that at a minimum, the flight-hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessaryto safely conductthe petitioner's proposed operations. The FAA also finds that priordocumented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience building flights can also be conducted underthe grant ofexemption to accomplish the required flight time. During training, proficiency, and experience-building flights the PIC is required to operate the UAwith appropriate distances in accordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15. Accordingly, EDWARD STANZAwill ensure safe operations by not allowing any PIC to operate the OJI Phantom 3, DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, thatthe PIC is able to safely operate the DJI Phantom 3, OJI Inspire 1 UAS in a mannerconsistentwith 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 OfSection 91.7(a) Would NotAdversely Affect Safety. The equivalent level ofsafety established by Section 91.7(a) will be maintained because priorto everyflight, EDWARD STANZA will ensure that the OJI Phantom 3, DJI Inspire 1 UAS is in an airworthy condition based upon the UAS's compliance with its operating documents and as stated in the conditions and limitations herein. Additionally, the FAA has previously granted relieffrom Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136,11138,11150,11153,11156,11157,11158,11159,11160, 11161).

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### I Page4. Reasons Why An Exemption From The Requirements OfSection 91.121 Would NotAdversely Affect Safety. The equivalent level ofsafety established by Section 91.121 will be maintained because the altitude information ofthe DJI Phantom 3, OJI Inspire 1 UAwill be provided to the PIC via GPS equipment and a radio communications telemetry data link, which downlinks from the UAto the GCSfor active monitoring ofthe flight path and altitude. This altitude information, combined with EDWARD STANZA'S operation ofthe DJI Phantom 3, DJI Inspire 1 UAwithin visual line ofsight, at or below 400 feetAGL, will ensure a level of safety equivalentto Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Priorto each flight, a zero altitude initiation point is automatically established bythe UASs at ground level. The FAA has previously granted relieffrom 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 OfSection 91.151(b) Would NotAdversely Affect Safety. A grant ofthis exemption would ensure an equivalent level ofsafety established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications ofthe DJI Phantom 3, DJIInspire 1 UAS; (2) the limitations on the proposed flight operations; and (3) the location ofthe proposed flight operations. Accordingly, EDWARD STANZAwill ensure that it will safely operate the battery powered DJI Phantom 3, DJIInspire 1 UA during daylight hours in VFR conditions, with enough battery powerto fly fora total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly afterthatfor at least4.5 minutes. Here, as in Exemption No. 11109, the technical specifications ofthe DJI Phantom 3, DJI Inspire 1 UAS; the limitations on the proposed flight operations; and the location ofthe proposed operations, will ensure an equivalent level ofsafety established by 14 C.F.R. Section 91.151(b). Furthermore, safetywill be ensured as the DJI Phantom 3, DJI Inspire 1 UAS provide audible and visual warnings to the PIC atthe GCSwhen the UAs experiences low battery voltage, the firstwarning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery power. Atthe critically low battery level, the DJI Phantom 3, DJIInspire 1 UAS UAS will descend and land automatically. Significantly, previous exemptions granted bythe FAA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations ofthe UAS are considered. Relief has been granted for manned aircraftto 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 specificto 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)

.

21 

### I Page6. Reasons Why An Exemption From The Requirements OfSections 91.405(a), 91.407(a)(1), 91.409(a)(1) 

### & (a)(2), And 91.417(a) 

### & (b) Would NotAdversely Affect Safety. In seeking this exemption, EDWARD STANZA submits thatthe equivalent level of safetywith 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 EDWARD STANZAwill use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3, DJIInspire 1 Instruction Manual). Furthermore, EDWARD STANZAwill document and maintain all maintenance records forthe DJI Phantom 3, OJI Inspire 1 UAS. Since the DJI Phantom 3, DJI Inspire 1 UASwill be inspected as prescribed bythe operating documents, EDWARD STANZAwill maintain the equivalent level ofsafety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy ofthe DJI Phantom 3, DJI Inspire 1 User Manual is attached hereto as Exhibit B; a copy ofthe DJI Phantom 3, DJIInspire 1 UAS Maintenance LOG is attached hereto as Exhibit C. Likewise, the exemption soughtwill not adversely affect safety because EDWARD STANZA will usetrained technicians to perform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed bythe operating documents. Furthermore, the exemption soughtwould maintain an equivalent level ofsafety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance ofthe DJI Phantom 3, DJIInspire 1 UAS will be performed bytrained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log. Significantly, previous exemptions granted bythe 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 ofthe UAS are considered. In consideration of EDWARD STANZA's proposed operating limitations, the operating documents, and the technical aspects ofthe DJI Phantom 3, OJI Inspire 1 UAS, EDWARD STANZA submits that safetywill 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 reliefspecific 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 PrescribeAny Other Conditions ForSafe Operation. In accordance with Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA) and 14 C.F.R. 

### § 21.16 entitled Special Conditions, EDWARD STANZA requests that the FAA prescribe special conditions forthe intended operation ofthe DJI Phantom 3, DJI Inspire 1 UAS, which contain such safety standards thatthe Administratorfinds

22 

### I Pagenecessaryto establish a level ofsafety equivalentto that established by 14 C.F.R. Part21, 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 ofthe UAsforthe limited purpose ofconducting aerial video and photography overcertain areas ofthe United States for compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users ofthe NAS orthe public, or otherwise pose a threatto national security; and further, provides the authorityfor such UAS to operate without airworthiness certification in accordance with any requirements that must be established for the safe operation ofthe UAS in the NAS. Likewise, the Administrator may prescribe special conditions pursuantto 14 C.F.R. 

### § 21.16, for operation ofthe DJI Phantom 3, OJI Inspire 1 UAS, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate orappropriate safety standards, dueto the novel or unusual design features ofthe aircraft. Section 21.16, entitled Special Conditions, states the following: Ifthe FAAfinds thatthe airworthiness regulations ofthis subchapterdo not contain adequate orappropriate safety standards for an aircraft, aircraft engine, or propeller because ofa novel or unusual design feature ofthe aircraft, aircraft engine or propeller, he prescribes special conditions and amendmentsthereto forthe product. The special conditions are issued in accordance with Part 11 ofthis chapter and contain such safety standards forthe aircraft, aircraft engine or propeller as the FAAfinds necessaryto establish a level ofsafety equivalentto 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 Edward Stanza's intended operation ofthe DJI Phantom 3, DJI Inspire 1 UAS, which contain such safety standards thatthe Administrator finds necessaryto establish a level ofsafety equivalentto 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). 

### F. A SummaryThatCan Be Published In The Federal Register, stating: The Rules From Which EDWARD STANZA Seeks Exemption: EDWARD STANZA 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), and91.417(a) & (b). 

### A Brief Description OfThe Nature OfThe Exemption EDWARD STANZA Seeks: This exemption willpermit

### EDWARD STANZA to commerciallyoperate an Unmanned AircraftSystem (UAS) forthe purpose ofconducting aerial video andphotographyover certain areas ofthe United States.

23 

### I PageG. AnyAdditional Information, Views, OrArgumentsAvailableTo Support EDWARD STANZA'S Request. This Petition is made pursuantto the FAA Modernization and Reform Act of2012 (FMRA) Section 333, which directs the Secretary ofTransportation to determine ifcertain UAS may operate safely in the NAS. As such, EDWARD STANZA'S request forexemption may be granted pursuantto the authority of FMRA Section 333 and 14 C.F.R. Part 11, as setforth above. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users ofthe NAS orthe public, or otherwise pose athreat to national security; and further, provides the authority for such UAS to operate without airworthiness certification. As discussed in detail above, EDWARD STANZAwill operate the DJI Phantom 3, DJI Inspire 1 UAS safely in the NAS, without creating a hazard to users ofthe NAS, orthe public, or otherwise pose a threat to national security. CONCLUSION As set forth herein, EDWARD STANZA seeks an exemption pursuant to 14 C.F.R. 

### § 11.61 and Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA), which will permit safe operation ofthe DJI Phantom 3, DJI Inspire 1 UAS commercially, without an airworthiness certificate, forthe limited purpose ofconducting aerial video and photography

over certain areas ofthe United States. By granting this Petition, the FAAAdministratorwill be fulfilling the Congressional mandate ofthe FAA Modernization and Reform Act of2012, while also advancing the interests ofthe public, by allowing EDWARD STANZAto safely, efficiently, and economically operate the DJI Phantom 3, DJIInspire 1 UAS commercially within the NAS. WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of2012, Section 333, EDWARD STANZA respectfully requests thatthe Administrator grantthis 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 EDWARD STANZAto operate the DJI Phantom 3, OJI Inspire 1 UAS commercially forthe purpose ofconducting aerial video and photography over certain areas ofthe United States. Dated: September 11, 2015 Respectfully submitted, EDW TANZ

Tel: (409) 599-9846 edwardstanza@yahoo.com

241 PageAppendices: A- OJI Phantom 3 Specifications Data Sheet B- DJIInspire 1 Specifications Data Sheet C- DJI Phantom 3 Manufacturer's User Manual D- DJI Inspire 1 Manufacturer's User Manual E

- Monthly Maintenance Log 

### APPENDIX-A DJI Phantom 3 TECHNICAL SPECIFICATIONS EDWARD STANZA only utilizes safe and reliable UASs. DJI is an industry leader in small UAS production. DJI UASs are loaded with ground breaking software enabling the userto set parameters which will not allowflight into controlled airspace. Parameters can also be set to limitflight to no higherthan a predetermined and set altitude as well as limitflight to a predetermined and set distance. In addition, DJI software provides real-time altitude and location information to the PIC via the linked monitor (smart phone/tablet devices) Aircraft Weight (including battery and propellers) 1280 g Diagonal size (including propellers) 590 mm MaxAscent Speed 5 m/s Max Descent Speed 3 m/s HoverAccuracy Vertical: +/- 0.1 m (when Vision Positioning is active) or+/- 0.5 m Horizontal: +/- 1.5 m Max Speed 16 m/s (ATTl mode, no wind) MaxAltitude Above Sea Level 6000 m Operating Temperature

# ooc to 40°C GPS Mode GPS/GLONASS Camera Sensor Sony EXMOR 1 /2.3" Effective pixels: 12.4 M (total pixels: 12.76 M) Lens FOV 94° 20 mm (35 mm format equivalent) f/2.8, focus at oo ISO Range 100-3200 (video) 100-1600 (photo) Shutter Speed 8s -1/8000s Image Max Size 4000 x 3000 Still Photography Modes •Single Shot •Burst Shooting: 3/5/7 shots •Auto Exposure Bracketing (AEB): 3/5 •Bracketed Frames at 0.7EV Bias

25 

## I P 2 g

### e•Time-lapse Video Recording Modes Phantom 3 Professional •UHD: 4096x2160p 24/25, 3840x2160p 24/25/30 •FHD: 1920x1080p 24/25/30/48/50/60 •HD: 1280x720p 24/25/30/48/50/60 Phantom 3 Advanced •FHD: 1920x1080p 24/25/30/48/50/60 •HD: 1280x720p 24/25/30/48/50/60 Supported SD Card Types Micro SD Max capacity: 64 GB. Class 10 or UHS-1 rating required Max Bitrate ofVideo Storage Phantom 3 Professional 60 Mbps Phantom 3 Advanced 40 Mbps Supported File Formats •FAT32/exFAT •Photo: JPEG, DNG •Video: MP4, MOV (MPEG-4 AVC/H.264) Operating Temperature

# ooc to 40°C Gimbal Controllable Range Pitch -90° to +30° Stabilization 3-axis (pitch, roll, yaw) Vision Positioning MaxVelocity Less than 8 m/s (when 2 m above ground) Altitude Range 30 cm-300 em Operating Range 30 cm-300 em Operating Environment Surfacewith clear pattern and adequate lighting (Lux > 15) Remote Controller Operating Frequency 2.400 GHz-2.483 GHz Max Distance 2000m (outdoors and unobstructed) Video Output Port USB Operating Temperature 0°C- 40°C Battery 6000 mAh LiPo 2S Mobile Device Holder Fortablet or phone Receiver Sensitivity (1%PER) -101 dBm ±2 dBm Transmitter Power (EIRP) •FCC: 20 dBm

261 Page•CE: 16 dBm Working Voltage 1.2A @7.4 V Battery Charger Voltage 17.4 V Rated Power Phantom 3 Professional •100W Phantom 3 Advanced •57W Intelligent Flight Battery Capacity 4480 mAh Voltage 15.2 V BatteryType LiPo 4S Energy 68 Wh NetWeight 365 g Max FlightTime Approximately 23 minutes Operating Temperature -10°C to 40°C Max Charging Power 100W App 

### I Live View Mobile App DJI Pilot EIRP 100mW Live ViewWorking Frequency2.4GHz ISM Live View Quality 720P @ 30fps (depending on conditions and mobile device) Latency 220ms (depending on conditions and mobile device) Required Operating Systems •iOS 8.0 or later •Android 4.1.2 or later Recommended Devices •iOS: iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad AirWi-Fi 

### + Cellular, iPad mini 2, iPad mini 2 Wi-Fi + Cellular, iPad Air2, iPad Air2 Wi-Fi + Cellular, iPad mini 3, and iPad mini 3Wi-Fi 

### + Cellular. This app is optimized for iPhone 5s, iPhone 6, and iPhone 6 Plus •Android: Samsung S5, Note 3, SonyXperia Z3, Google Nexus 7 II, Google Nexus 9, Mi 3, Nubia Z7 mini APPENDIX-8

.DJI Inspire 1 TECHNICAL SPECIFICATIONS

EDWARD STANZA only utilizes safe and reliable UASs. DJI is an industry leader in small UAS production. DJI UASs are loaded with ground breaking software enabling the userto set parameters which will not allowflight into controlled airspace. Parameters can also be set to limitflight to no higherthan a predetermined and set altitude as well as limitflight to a predetermined and setdistance. In addition, DJI software provides real-time altitude and location information to the PIC via the linked monitor (smart phone/tablet devices)

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## I PageAircraft Model T600 Weight (Battery Included) 2935 g Hovering Accuracy (GPS mode) Vertical: 0.5 m Horizontal: 2.5 m MaxAngular Velocity Pitch: 300°/S Yaw: 150°/S Max TiltAngle 35° MaxAscent Speed 5 m/s Max Descent Speed 4 m/s Max Speed 22 m/s (ATTl mode, no wind) Max FlightAltitude 4500 m MaxWind. Speed Resistance 10 m/s Max Flight Time Approximately 18 minutes Motor Model DJI 3510 Propeller Model DJI 1345 Indoor Hovering Enabled by default Operating Temperature Range -10° to 40° C Diagonal Distance 559 to 581 mm Dimensions 438x451x301 mm Gimbal Model ZENMUSE X3 Output Power (with camera) Static: 9W In Motion: 11 W Operating Current Station: 750 rnA Motion: 900 rnA AngularVibration Range ±0.03° Mounting Detachable Controllable Range Pitch: -90° to +30° Pan:±320° Mechanical Range Pitch: -125° to +45° Pan: ±330° Max Controllable Speed Pitch: 120°/S Pan: 180°/S Camera NameX3 Model FC350 Total Pixels 12.76M Effective Pixels 12.4M Image Max Size 4000x3000 ISO Range 100-3200 (video) 100-1600 (photo) Electronic Shutter Speed 8s

- 1 /8000s

281 PageFOV (Field ofView) 94o CMOS Sony EXMOR 1/2.3" Lens 20mm (35mm format equivalent)f/2.8 focus at oo 9 Elements in 9 groups Anti-distortion Still Photography Modes Single shoot Burst shooting: 3/5/7 frames Auto Exposure Bracketing (AEB): 3/5 bracketed frames at 0.7EV Bias Time-lapse Video Recording Modes UHD (4K): 4096x2160p24/25, 3840x2160p24/25/30 FHD: 1920x1080p24/25/30/48/50/60 HD: 1280x720p24/25/30/48/50/60 Max Bitrate ofVideo Storage 60 Mbps Supported File Formats F

AT32/exFAT Photo: JPEG, DNG Video: MP4/MOV (MPEG-4 AVC/H.264) Supported SD Card Types Micro SD Max capacity: 64 GB. Class 10 or UHS-1 rating required. Operating Temperature Range oo to 40° C Remote Controller Name C1 Operating Frequency 5.725-5.825 GHz 2.400-2.483 GHz Transmitting Distance (outdoor and unobstructed) 2 km EIRP 1OdBm@900m, 13dBm@5.8G, 20dBm@2.4G Video Output Port USB, mini-HDMI Power Supply Built-in battery Charging DJI charger Dual User Capability Host-and-Slave connection Mobile Device HolderTablet or Phone Max Mobile Device Width 170mm Output Power 9W Operating Temperature Range -10° to 40° C Storage Temperature Range Less than 3 months: -20° to 45° C More than 3 months: 22° to 28° C Charging Temperature Range 0-40° C Battery 6000 mAh LiPo 2S Charger Model A14-100P1A Voltage 26.3 V Rated Power 100 W

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### IPage.Battery (Standard) Name Intelligent Flight Battery Model TB47 Capacity4500 mAh Voltage 22.2 V Battery Type LiPo 6S High voltage battery Energy 99.9 Wh NetWeight 570 g Operating Temperature Range -1

# oo to 40° C Storage Temperature Range Less than 3 months: -20° to 45° C More than 3 months: 22° C to 28° C Charging Temperature Range

# oo to 40° C Max Charging Power 180W Battery (Optional) Name Intelligent Flight Battery Model TB48 Capacity 5700 mAh Voltage 22.8 V BatteryType LiPo 6S Energy 129.96Wh NetWeight 670 g Operating Temperature Range -1

# oo to 40° C Storage Temperature Range Less than 3 months: -20 to 45° C More than 3 months: 22° to 28° C Charging Temperature Range

# oo to 40° C Max Charging Power 180W Vision Positioning Velocity Range Below 8 m/s (2 m above ground) Altitude Range 5-500 em Operating Environment Brightly lit (lux > 15) patterned surfaces Operating Range 0-250 em App 

### I Live View MobileApp DJI Pilot EIRP 100mW Live ViewWorking Frequency 2.4GHz ISM Live View Quality 720P @ 30fps (depending on conditions and mobile device) Latency 220ms (depending on conditions and mobile device) Required Operating Systems •iOS 8.0 or later •Android 4.1.2 or later MONTH: YEAR: UAS #DATE (ISSUE DISCOVERED)DATE (ISSUE CORRECTED)ISSUE DESCRIPTION & MAINTENANCE CONDUCTEDMAINTENANCE PERFORMED BY: (PRINT 

### &SIGN)SOFTWAREUPUPDATESAIRFRAMEENGINESCAMERALANDING GEARVIBRATIONDAMPENINGOTHER:UAS MONTHLY MAINTENANCE LOG

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## I PageRecommended Devices •iOS: iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad AirWi-Fi 

### + Cellular, iPad mini 2, iPad mini 2Wi-Fi 

### + Cellular, iPad Air 2, iPad Air2 Wi-Fi 

### + Cellular, iPad mini 3, and iPad mini 3Wi-Fi 

### + Cellular. This app is optimized for iPhone 5s, iPhone 6, and iPhone 6 Plus •Android: Samsung S5, Note 3, Sony Xperia Z3, Google Nexus 7 II, Google Nexus 9, Mi 3, Nubia Z7 mini 

### APPENDIX-C http://www.dji.com/productlphantom-3/download 

### APPENDIX-0 http://www.dji.com/productlinspire-1/download 

### APPENDIX- E

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### I Page