# DRONE IT ’s
PETITION
F OR
EXEMPTION

Reinaldo Fuentes
19377 NE 10th AVE #510 Miami, FL 33179
Ph: 7862615714 / E

- mail: RPSflorida@gmail.com2

Reinaldo Fuentes DRONE IT,
19377 NE 10 th A VE #510 Miami, FL 33179
Ph: 7862615714 / E

- mail: R PS flor ida@gmail.com

DRONE IT seeks exemption from the requirements 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 pursuant to Section 333 of t he FAA Moder nization and Reform Act of 2012. This exemption will permit DRONE IT, to operate Unmanned Aircraft Systems, small (UASs) for the commercial purpose of conducting aerial video and photography of construction sites, real estate, events,
and searc h and rescue

.

INTRODUCTION AND INTERESTS OF THE PETITIONER

DRONE IT provides its clients with expertise and knowledge in advanced technologies and solutions to increase efficiency, productivity and effectiveness. Reinaldo Fuentes , founder of DRONE IT, has over 2 years recreational / hobby experience in all aspects of aerial video and photography, and

over 5 0 hours of flight time on various sizes Unmanned Aerial Vehicles (UAV). The objective of DRONE IT, A erial Video and P hotography is to provide high qu ality imaging for a variety of commercial, public, residential and governmental uses, specifically targeting:

• Construction sites ( before and after )

• Events ( public and private )

• Real

- estate marketing

• Aerial inspections

• Search and r escue operations

BAC KGROUND

Unmanned Aircraft Systems: DJI Phantom 2 Vision.3

DRONE IT seeks an exemption to operate UASs for compensation or hire
within the NAS. The DJI Phantom 2 Vision quadcopter is a vertical takeoff and landing (VTOL) Unmanned Aerial Vehicle (UAV) wit h a Ground Control Station (GCS) utilizing electronic d evice

. The DJI Phantom 2 Vision has a maximum gross weight of approximately 6 pounds, while having a length of 14 inches width of 14 inches, height of 5 inches, and a maximum s peed of approximately
15m /s (not recommended)

.

The DJI Phantom 2 Vision quadcopter UAVs is equipped with four main rotors; driven by a
5200mAh Lithium Polymer battery powered electric motors

.

The DJI Phantom 2 Vision quadcopter that will be operated by DRONE IT, will be register ed 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

DRONE IT, pursuant to the provisions of the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereby petitions the Administrator for permission to commercially operate The DJI
Phan tom 2 Vision quadcopter 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 U nmanned
A ircraft System and its operation, DRONE IT ’s DJI Phantom 2 Vision quadcopter meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certifi cate in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, DRONE IT, requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to
ai rcraft with an airworthiness certificate.4

DRONE IT submits that the requested relief is proper since an equivalent level of safety will be
ensured. DRONE IT will use experienced personnel or technicians 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 Instruction Manuals). Furthermore, DRONE
IT will document and keep all maintenance records for The DJI Phantom 2 Vision quadcopter UAV

.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and
limitations: Pilot in command , is requested by DRONE IT to theextent necessary to allow a Pilot in Command (PIC) holding a student pilot, 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, that the PIC is able to safely operate T he DJI Phantom 2 Vision quadcopter UAV in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

DRONE IT seeks relief from Section 91.7(a), entitled Civil A ircraft A irworthiness , because the DJI
Phantom 2 Vision quadcopter UAV do es not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, DRONE IT submits that it will ensure that t he DJI Phantom 2
Vision quadcopter is in an airworthy condit ion, prior to every fli ght, by determining hat the UAV is in compliance with the operating documents

.

DRONE IT also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , as t he DJI Phantom 2 Vision quadcopter UAV will no t have a typical barometric altimeter onboard. However, altitude information of t he DJI Phantom 2 Vision quadcopter UAV will be provided to the PIC via Global Positioning System (GPS) equipment, and radio communications telemetry data
lin k, which downlinks from the UAV to the GCS for active monitoring of the flight path. This altitude information, combined with DRONE IT’s operation of t he DJI Phantom 2 Vision quadcopter UAV within visual line of sight, at or below 4 00 feet AGL, will ensure a level of safety equivalent to Section
91.121.

Additionally, DRONE IT seeks an exemption from the requirements of Section 91.151(b), entitled
Fuel R equi rements for F light in VFR conditions

. DRONE IT submits that safety will not be affected by operation of t he DJI Phantom 2 Vision quadcopter UAV during daylight hours in visual meteorological conditions (VMC) under V isual F light R ules (VFR), with enough battery power to fly for a total5

duration of approximately 25 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 5 minutes.

In accordance with 14 C.F.R. § 11.81, DRONE IT provides the following information in support of its petition for exemption:

A. Name and a ddress o f t he p etitioner:

DRONE IT
Reinaldo Fuentes , owner/founder
19377 NE 10 th Ave. #510, Miami FL. 33179
Ph: 786.261.5714
E

- mail: rpsflorida@gmail.com

B. The s pecific Sections o f 14 C.F.R. from w hich DRONE IT seeks e xemption :

1. DRONE IT seeks e xemption from t h e r equirements o f Section 61.113(a) and (b):

S ection 61.113, entitled Private P ilot P rivileges and L imitations: Pilot in command , subsections (a) and (b) prescribe the following, in relevant part: (a) No person who holds a private pilot certificate may act a s a pilot in command (PIC) of an aircraft that is carrying passengers 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 aircr aft in connection with any business or employment if

— (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire.

2. DRONE IT seeks e xemption from t he r equiremen ts o f Section 91.7(a) :

Section 91.7, entitled Civil A ircraft A irworthiness , subsection (a), states the following: (a) No person may operate a civil aircraft unless it is in an airworthy condition.6

3. DRONE IT seeks exemption f rom t he r equirements o f Section 91.121 :

Section 91.121, entitled Altimeter S ettings, 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 par agraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting availab le before departure.

4. DRONE IT seeks e xemption from t he r equirements of Section 91.151(b):

Section 91.151, entitled Fuel R equirements for F light 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. DRONE IT seeks e xemption from t he r equirement of Section 91.405(a):

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

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

.7

6. DRONE IT seeks e xemption f rom t he r equirements o f Section 91.407(a)(1) :

Section 91.407, entitle d Operation A fter M aintenance, P reventive Maintenance, Rebuilding, or
A lteration , 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. DRONE IT seeks e xemption f rom t he r equirements o f Sections 91.409(a)(1) a nd 91.409(a)(2) :

Section 91.409, entitled Inspections , subsection (a), states t he following: (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

-- (1) An annual inspection in accordance with part 43 of this chapter and has been

approv ed for return to service by a person authorized by § 43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.

8. DRONE IT seeks e xemption from t he requirements o f Sections 91 .417(a) and 91.417(b):

Section 91.417, entitled Maintenance Records , subsections (a) and (b), states 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 f or 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 aircra ft (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; and8

(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 the 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, for 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 chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) of 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 time 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 ser vice.

C. The e xtent of r elief DRONE IT seeks a nd t he r eason DRONE IT seeks t he relief:

1. Extent o f r elief DRONE IT s eeks a nd t he r eason DRONE IT s eeks r elief f rom Section 61.113(a) and (b):9

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

- hour and curren cy requirements, to conduct the proposed UAVs 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 air craft 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, DRONE IT subm its that an equivalent level of safety will be maintained because no PIC will be allowed to operate The DJI Phantom 2 Vision quadcopter
UAV unless that PIC has met certain flight

- hour and currency requirements, demonstrating that the PIC is able to safely ope rate either The DJI Phantom 2 Vision quadcopter UAV 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,
vehi cles and structures.

Further, DRONE IT submits that all flights of The DJI Phantom 2 Vision quadcopter UAV , conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to DRONE IT, business; and (2) will not carry passengers or pr operty for compensation or hire.

2. Extent o f r elief DRONE IT s eeks a nd t he r eason DRONE IT s eeks r elief f rom Section 91.7(a):

Relief from Section 91.7(a) entitled Civil A ircraft A irworthiness , is requested to the extent required to allow DRONE IT to de termine t he DJI Phantom 2 Vision quadcopter is in airworthy condition prior to every flight by ensuring that the UAVs is in compliance with the operating documents (i.e., the DRONE IT, Aerial Operations Manual, Flight log, Monthly Maintenance Log, and Inst ruction Manuals).10

DRONE IT seeks the requested relief because The DJI Phantom 2 Vision quadcopter UAV do es not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, DRONE IT will ensure that DJI Phantom Vision U AV is in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and Instruction Manuals) prior to every flight, and further, determine that the aircraft is in condition for safe flight, as stated in the c onditions and limitations below.

3. Extent o f r elief DRONE IT s eeks a nd t he r eason DRONE IT s eeks r elief f rom Sect ion
91.121:

Relief from Section 91.121, entitled Altimeter S ettings, may be required to allow flight operations of t he DJI Phantom 2 Vision quadcopter UAV, which utilize s a barometric pressure sensor, GPS equipment, and a radio communications telemetry datalink to downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAVs operations be reported to air traffic control (ATC) in feet above ground level (AGL), DRONE IT seeks the requested relief because t he DJI Phantom 2 Vision quadcopter UAV altimeter may be set on the ground to zero feet AGL, rath er 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 conditions and limitations stated below. As more fully set forth herein, an equivalent level of safety will be maintained since t he DJI Phantom 2 Vision quadcopter UAV is equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level p ressure setting will be established prior to each flight, and provides the PIC with altitude information of the UAV on the heads

- up display of the GCS.

4. Extent o f r elief DRONE IT s eeks a nd t he r eason DRONE IT s eek s relief from Section 91.151(b):

Relie f from Section 91.151(b) entitled Fuel R equirements for F light in VFR conditions, is requested to the extent required to allow flights of the battery powered t he DJI Phantom 2 Vision quadcopter UAV during daylight hours in visual meteorological conditions (VMC), under visual11

flight rules (VFR), for a total duration of 25 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 5 minutes. DRONE IT seeks the requested relief because without an exemptio n from Section 91.151(b), the flight time duration of the battery powered t he DJI Phantom 2 Vision quadcopter UAV will severely constrain the practicality of any aerial video or still photo flight operations that DRONE IT proposes to conduct pursuant to th is Petition.

The DJI Phantom 2 Vision quadcopter UAV operating documents, and DRONE IT ’s proposed operating limitations, ensure that DRONE IT will safely operate the battery powered DJI Phantom 2 Vision quadcopter UAV during daylight hours in visual mete orological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total duration of 25 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after
that for at least 5 minutes.

5. Ext ent o f r elief DRONE IT s eeks a nd t he r eason DRONE IT s eeks r elief f rom 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, DRONE IT requests relief from these Sections because

t he DJI Phantom 2 Vision quadcopter UAV do es not require airworthiness certificates. As set forth more fully below, t he DJI Phantom 2 Vision quadcopter UAV meet s the co nditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, DRONE IT will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices pres cribed in the UASs operating
documents (i.e., the DRONE IT, Aerial Operations Manual, Monthly Maintenance Log, and Instruction Manuals). Furthermore, DRONE IT will document and keep all maintenance records
for t he DJI Phantom 2 Vision quadcopter UAV

.12

D. The r easons why g ranting DRONE IT r equest w ould b e i n the p ublic i nterest; t hat i s, how i t

w ould b enefit t he p ublic as a whole:

Granting the present Petition will further the public interest by allowing DRONE IT to safely, efficiently, and economicall y perform aerial video and photography of construction sites, real estate, events and landscape over cert ain areas of the United States.

Additionally, use of t he DJI Phantom 2 Vision quadcopter UAV will decrease congestion of the NAS, reduce pollution, an d provide significant benefits to the economy. Notably, the benefits of DRONE IT ’s proposed operation of t he DJI Phantom 2 Vision quadcopter UAVs will be realized without implicating any privacy issues.

1. The p ublic w ill b enefit f rom d ecreased c ongestion o f the NAS:

The DJI Phantom 2 Vision quadcopter UAV is battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to pe rform aerial acquisitions, an exemption allowing the use of a The DJI Phantom 2 Vision quadcopter UAV 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 aircraft will be reduced. The DJI Phantom 2 Vision quadcopter UAV do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight oper ations.

2. The p ublic will b enefit f rom t he s afety a nd e fficiency of t he DJI Phantom 2 Vision quadcopter UAV :

Conducting aerial acquisitions with t he DJI Phantom 2 Vision quadcopter UAV , instead of manned aircraft, will greatly benefit the public by drasti cally reducing the levels of air and noise13

pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, t he DJI Phantom 2 Vision quadcopter UAV produce s no air pollution, and is th e 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 fue l. The DJI Phantom 2 Vision quadcopter UAV , while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAVs are propelled by battery powered electric motors, rather than an internal combustion engine.

By using t he DJI Phantom 2 Vision quadcopter UAV 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 co mpletely eliminated. Aside from the lack of flight crew members located onboard the aircraft, t he DJI Phantom 2 Vision quadcopter UAV ( weighing approximately 6 pounds , at their maximum gross

we ights with lengths of 14 inches widths of 14 inches , and with n o fuel on board), has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approx imately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

3. Performing a erial v ideo and p hotography o perations w ith t he DJI Phantom 2 Vision quadcopter UAV w ill b enefit t he e conomy:

In addition to being safe and efficient, t he DJI Phantom 2 Vision quadcopter UAV is also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of t he DJI Phantom 2 Vision quadcopter UAV will allow United States based companies, like DRONE IT, to remain compet itive and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new a nd alternative technology in order to remain competitive. Operating the battery powered DJI Phantom 2 Vision quadcopter UAV is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft.14

By operating t he DJI Phantom 2 Vision quadcopter UAV, companies such as DRONE IT , can remain competitive and profitable, and therefore, provide greater job stability to empl oyees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through commercial use of t he DJI Phantom 2 Vision quadcopter UAV , 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 order to remain competitive both i n the United States and abroad.

4. There a re n o p rivacy issues:

Similar to the manned aerial acquisiti on flight operations that have been conducted for decades,
DRONE IT ’s proposed operation of t he DJI Phantom 2 Vision quadcopter UAV will not implicate any privacy issues. Specifically, t he DJI Phantom 2 Vision quadcopter UAV will be operated only in compli ance with operating documents (i.e., the DRONE IT, Aerial Operations Manual, Monthly Maintenance Log, and Instruction Manuals) which requires property owner involvement as well as local law enforcement notification, and in accordance with the Federal
Aviat ion Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.

E. The reasons w hy g ranting t he e xemption w ould n ot a dversely a ffect safety; o r h ow t he

e xemption w ould p rovide a l evel o f s afety a t l east e qual to t hat p rovided b y t he r ule from w hich
DRONE IT s eeks exemption:

1. Reasons w hy t he DJI Phantom 2 Vision quadcopter UAV m eet s t he c onditions of t he
FAA Modernization and Reform Act of 2012 (FMRA) Section 333:

In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, DRONE IT ’s operation of t he DJI Phantom 2 Vision quadcopter UAV meet the conditions of FMRA Section 333, and will not require an
airworthiness certificate in accordance wit h 14 C.F.R. Part 21, Subpar t H.

Section 333 provides authority for a UAVs to operate without airworthiness certification and sets forth requirements for considering whether a UAVs will create a hazard to users of the NAS or15

the public, or otherwise pose a threat to national securit y. Specifically, FMRA Section 333 states the following, in part: (a) In General.

-- Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall
determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act. (b) Assessment of Unmanned Aircra ft Systems.

-- In making the determination under subsection (a), the Secretary shall determine, at a minimum

— (1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and po pulated 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 airwort hiness 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 airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system.

In seeking this exemption, DRONE IT submits that t he DJI Phantom 2 Vision quadcopter UAV can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the
characteristics of t he DJI Phantom 2 Vision quadcopter UAV ; (b) the pilot certification requirement; and (c) the specific operating limitations.

a. The s pecifications o f t he DJI Phantom 2 Vision quadcopter UAV
d emonstrate i ts s afe characteristics:

The DJI Phantom 2 Vision quadcopter UAV do es 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.16

i. Technical specifications:

The technical specification of the DJI Phantom 2 Vision quadcopter UAV is set forth by the Specifications and Data Sheet, atta ched hereto as Exh ibit A

.

ii. The DJI Phantom 2 Vision quadcopter UAV Autonomous Flight And Navigation Modes Enable The UAVs To Remain Within A Defined Operational Area.

The DJI Phantom 2 Vision quadcopter may be operated in both manual and fully autonomous flight mod es. A complete description of the flight and navigational modes of the DJI Phantom 2 Vision quadcopter is provided at pages of the DJI
Phantom 2 Vision User Manual, attached hereto as Exhibit B

.

iii. The DJI Phantom 2 Vision quadcopter UAV Are Designed F or Automatic
Return To Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation.

When the Control Link is lost, the DJI Phantom 2 Vision quadcopter UAV will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the D JI Phantom 2 Vision quadcopter UAV do not reacquire control link data from the GCS, the UAVs will assume that the C ontrol Link is lost and the UAV will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown.

A complete description of the Failsafe Functions of the DJI Phantom 2 Vision quadcopter UAV are set forth on pages of the DJI Phantom 2 Vision User Manual, attached hereto as Exhibit B

.17

iv. The DJI Phantom 2 Vision quadcopter UAV GCS And I ts Operation.

A complete description of the operation and specifications of the DJI Phantom 2 Vision quadcopter UAV GCS and flight control software is provided at pages of
the User Manual. User Manuals are attached hereto as Exhibits B

.

b. Flight o peratio ns o f DJI Phantom 2 Vision quadcopter UAV. UAS a re l imited to t he l ine of s ight o f a C ertificated Pilot in Command w ith a Safety
Observer:

DRONE IT will only utilize certificated pilots who possess a current and valid airman
medical certificate to act as a pilot in command (PIC) of the DJI Phantom 2 Vision quadcopter UAV . Additionally, a safety observer will assist all pilots during flight time.

c. Flights o f DJI Phantom 2 Vision quadcopter UAV w ill b e c onducted p ursuant t o

s pecific o perating limitations :

In seeking this exemption, DRONE IT proposes to commercially operate DJI Phantom 2
Vision quadcopter UA V for the special purpose of conducting aerial video and photography over certain areas of United States, pursuant to the following specific operating limitations:

1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: DJI Phantom 2 Vision quadcopter UAV Unman ned Aircraft 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 photograph y.

3. The UAVs may not be flown at an indicated airspeed exceeding 100 knots.18

4. The UAVs must be operated at an altitude of no more than 4 00 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a sp ecial request is made and approved by ATC. All altitudes reported to ATC must be in feet AGL.

5. The UAVs 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
dev ice other than corrective lenses, as specified on the PIC’s FAA

- issued airman
medical certificate.

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

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS 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 de signated 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 assi sting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is not permitted to operate the camera or other instruments.

9. The operating documents and the grant of exemptio n must be accessible during
UAV op erations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations contained in the grant of exemption and the procedures outlined in the operating documents, the
conditions and limitations contain ed 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 revisions and19

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 UAVs Integration Office (AFS

- 80) may be contacted if questions arise regarding u pdates or revisions to the operating documents.

10. Prior to each flight th e PIC must inspect the UAV 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 p rohibited from operating until the necessary maintenance has been perfo rmed 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 UAVs that has undergone maintenance or alterations that affect the UAVs operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraft records.

12. The pre

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

13. The operator must follow the UASs manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements.

14. The operator must carry out its maintenance, inspections, and record keepi ng 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 of20

work accomplished, and the signature of the authorized person returning the
UAVs to service.

15. Each UAVs 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

correct ive action taken against discrepancies discovered between inspections.

17. The PIC must possess at least a student pilot, private pilot certificate, or greater and at least a current third class medical certificate.

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safely operate the UAVs in a manner consistent with how the UAVs will be operated under the exemption, including evasive and emergency maneuvers and m aintaining 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 th e terms of the exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

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

19. UAVs operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual m eteorological 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 UAVs may not operate wit hin 5 nautical miles of a airport reference point
as denoted on a current FAA

- published aeronautical chart unless a letter of21

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

21. The UAVs may not be operated less than 4 00 feet below or less than 1 ,000 feet horizontally from a cloud or when visibility is less than 2 statute miles from
the PIC.

22. If the UAVs loses communications or loses its GPS signal, it must return to a
Pre

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

23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents.

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

25. The operator must obtain an Air Traffic Organizat ion (ATO) issued
Certificate of Waiver or Authorization (COA) prior to conductin g 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 accordan ce with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requirements.

26. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordan ce 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.22

27. Before conducting operations, the radio frequency spectrum used for operation and contr ol of the UAVs must comply with the Federal Communications Commission (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 UAV any time the UAV is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

29. The UAVs must remain clear and yield the right of way to all manned aviation operations and ac tivities at all times.

30. The UAVs may not be operated by the PIC from any moving device or
vehicle.

31. Flight operations must be conducted at least 4 00 feet from all nonparticipating persons (persons other than the PIC, SO, operator trainees or esse ntial 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 perso ns remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 4 00 feet of the UAVs, flight operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or struct ures where the owner/controller of such vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, and;23

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

32. All operations shall be conducted over private or controlled

- access property with permission from the land owner/con troller 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 boundarie s of the 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 W eb site: www.ntsb.gov

.

2. Reasons w hy an exemption f rom t he r equirements o f Section 61.113(a) a nd (b) w ould n ot

a dversely a ffect s afety :

DRONE IT 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 Phantom 2 Vision quadcopter UAV unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI Phan tom 2 Vision quadcopter UAV in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, ve ssels, vehicles and structures.

Considering DRONE IT, ' proposed area of operations, and t he operating limitations set forth

above; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI Phantom 2 Vision quadcopter UAV , DRONE IT, submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for DRONE IT, ' speci fic proposed flight operations.24

The FAA has previousl y granted relief from Section 61.113(a) and (b) specific to UAVs, 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). DRONE IT, will not allow any PIC to operate the DJI Phantom 2 Vision quadcopter UAV unless that PIC has demonstrated, by meeting minimum flight

- hour requirements or the DJI Phantom 2
Vision quadcopter UAV trainin g and currency requirements, that the PIC is able to safely operate the DJI Phantom 2 Vision quadcopter UAV in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people,

ve ssels, ve hicles 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 UAVs rotorcraft pilot (with a minimum of 5 hours of those hours as a UAVs pilot operating the same make and model of UAS to be used for operations under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 9 0 days (for currency purposes).

As in Exemption Nos. 11062, 11138, and 11153, pr ior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during DRONE IT, ' proposed operations. The Administrator has held that prior documented flight experience that was obtain ed in compliance with applicable regulations would ensure safe operations, stating as follows:

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

- rotor UAVs. Prior to operations under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of 5 hours as a UAVs pilot operating the same make and model of UAVs to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to
be inclusive rather 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 UAVs
rotorcraft time.25

In addition to the hour requirements, the PIC must accomplish 3 takeoffs and la ndings 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 propo sed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience

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

building flights the PIC is required to operate the UAVs with appropriate distances in accordance
with 14 C.F.R 91.119. Exemption No. 11138 at page 15.

Accordingly, DRONE IT, will ensure safe operations by not allowing any PIC to operate UAS unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

3. Reasons w hy a n exemption f rom t he r equirements o f Section 91.7(a) w ould n ot a dversely affect safety:

The eq uivalent level of safety established by Section 91.7(a) will be maintained because prior to every flight, DRONE IT, will ensure that the DJI Phantom 2 Vision quadcopter UAV is in an airworthy condition based upon the UAV’s compliance with its operating doc uments and as
stated in the con ditions and limitations herein.

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAVs, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos.
11 062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).26

4. Reasons why an exemption from t he requirements o f Section 91.121 w ould n ot a dversely affect safety:

The equival ent level of safety established by Section 91.121 will be maintained because the
altitude information of the DJI Phantom 2 Vision quadcopter UAV will be provided to the PIC via GPS equipment and a radio communications telemetry data link, which downlinks f rom the UAVs to the GCS for active monitoring of the flight path and altitude. This altitude information,
combined with DRONE IT, ' operation of the DJI Phantom 2 Vision quadcopter UAV within visual line of sight, at or below 4 00 feet AGL, will ensure a lev el of safety equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically establish ed by the UAVs at ground level.

The FAA has previously granted relief from Section 91.121 specific to UAV 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 w hy a n e xemption f rom t he r equirements o f Section 91.151(b) w ould n ot

a dversely a ffect safety:

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R.
Section 9 1.151(b) as a result of (1) the technical specifications of the ach flight, a zero altitude initiation point is; (2) the limitations on the proposed fl ight operations; and (3) the location of the proposed flight operations. Accordingly, DRONE IT, will ensu re that it will safely operate the battery powered the during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 25 minutes to the first point of intended landing and, assuming normal cruising speed, to fly aft er tha t for at least 5 minutes.

Here, as in Exemption No. 11109, the technical specifications of t he DJI Phantom 2 Vision quadcopter ; 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, UASs provide audible and visual warnings to the PIC at the GCS when the UASs27

experiences low battery voltage, the first warning occurring at approximately 25% remaining battery power, and at approximately 10% remaining battery power UASs 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 o perating 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 f rom 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, 111 56, 1115 7, 11158, 11159, 11160, 11161).

6. Reasons w hy a n e xemption f rom t he r equirements o f Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), a nd 91.417(a) & (b) w ould n ot a dversely a ffect s afety :

In seeking this exemption, DRONE IT, 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 DRONE IT, will
use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques and practices prescribed in the operating documents (i.e.,
the DRONE IT, Aerial Operations Manual, Monthly Maintenance Log, DJI Phantom 2 Vision
Instructi on Manual). Furthermore, DRONE IT, will document and maintain all maintenance
records for the DJI Phantom 2 Vision UAS

.

7. The FAA m ay p rescribe a ny other c onditions f or s afe o peration :

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, DRONE IT, requests that the FAA prescribe special conditions for the intended operation of the DJI Phantom 2 Visio n 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), and 91.417(a) & (b).28

Such special conditi ons 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 c reate a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification in accordance with any requirements that must be established for the safe o peration
of the UAS in the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of the DJI Phantom 2 Vision UAS , since the airworthiness regulations of
14 C.F.R. Part 21 do not contai n 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 conta in adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent to that
established in the re gulations. 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 Leading Edge’s intended operation of the DJI Phantom 2 Vision
UAS , which contain such safety standards t hat 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 91.4 17(a) & (b).

F. A Summary That Can Be Published In The Federal Register, stating: The Rules From Which Deland Drones Seeks Exemption:29

Deland Drones 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 b rief d escription o f t he n ature o f t he e xemption DRONE IT s eeks :

This exemption will permit DRONE IT, to commercially operate an Unmanned Aircraft System, small (UASs) for the purp ose of conducting aerial video and photography over certain areas of the United
States.

G. Any Additional i nformation, v iews or a rguments a vailable t o s upport DRONE IT ’s

re quest:

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. As such, DRONE IT, ' request for exemption may be granted pursuant to the authority of FMRA
Section 333 and 14 C.F. R. Part 11, as set forth above.

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to op erate without airworthiness certification. As discussed in detail above, DRONE IT, will operate the DJI Phantom 2 Vision UAS safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.

CONCLUSION

As set forth herein, DRONE IT seeks an ex emption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI
Phantom 2 Vision UAS commercially, without an a irworthiness certificate, for the limited purpose of conducting aerial video and photography over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization
and Reform Act of 2012, while also advancing the interests of the public, by allowing DRONE IT, to30

safely, efficiently, and economically operate the DJI Phantom 2 Vision UAS commercially within the
NAS.

WHEREFORE , in accordance with the Federal Aviation Reg ulations and the FAA Modernization and Reform Act of 2012, Section 333, DRONE IT, 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), 91.4 05(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Leading Edge to operate the DJI Phantom 2 Vision UAS commercially for the purpose of conducting aerial video and photography over certain areas of the United States.

Dated: Marc h 29 th , 2015

Respectfully submitted by
Reinaldo Fuentes , Owner DRONE IT,
19377 NE 10 th A VE #510
Miami , FL 33179
Ph: 786.261.5714 / E

- mail: RPSflorida@gmail.com

Appendices:

A

- DJI Phantom 2 Vision Specifications Data Sheet
B

- DJI Phantom 2 vision Owner Manual

The DJI Phantom 2 Vision Maintenance guidelines ensure an equivalent level of safety to the maintenance requirements. In addition, any component failure detectable by the system will be reported
to the control station and will cause the UAV to perform a Fatal Condition Response (FCR) or Nonfatal Condition Response.31

Appendix A

The Phantom 2 Vision ushers in a new era of aerial Pho tography, the sharp, powerful DJI

- designed camera, making professional imaging tools easily accessible to e veryone. Vision+ Battery
5200mAh LiPo

Phantom 2 Vision 1160g (with battery & Weight propellers)
Hover Accuracy (Ready Vertical:0.8m to Fly) Horizontal:2.5m
Max Yaw Angular 200°/s Velocity
Max Tilt Angle 35°
Max Ascent / Descent Ascent: 6m/s Sp eed Descent: 3m/s
Max Flight Speed 15m/s(Not Recommended)
Diagonal Length 350mm
Tilting Range of Gimbal Pitch : 0°

- 60°

1. Ready to fly
2. Precision flight and stable hovering
3. Radar positioning & return home
4. Onscreen real

- time flight parameters
5. High pe rformance camera
6. Camera tilt control
7. Film straight down
8. Supports Adobe DNG RAW
9. Adobe lens profile support
10. Camera parameter settings
11. Album synchronization32

TRANSMITTER
1. Operating Frequency: 5.728 GHz

– 5.85 GHz
2. Communication Distance (open area): C E: 300m; FCC: 500m
3. Receiver Sensitivity (1%PER):

- 93dBm
4. Transmitter Power: CE: 25mw; FCC: 125mw
5. Working Voltage: 80 mA@6V
6. Battery: 4 AA Batteries

CAMERA
1. Resolution: 14 Megapixel
2. FOV: 120°/ 110 ° / 85°
3. Sensor size: 1/2.3"
4. HD Recording: 1080p30 /1080p6 0

RANGE EXTENDER
1. Operation Frequency: 2412

- 2462MHz
2. Communication Distance (Open Area) 300m
3. Transmitter Power: <=17dbm
4. Power Consumption: 1.5W

The Phantom 2 Vision Range Extender is a wireless communication device that operates within the 2.4 GHz freque ncy band. It is used to extending the effective range of communication between a Smartphone and the Phantom 2 Vision. In an open, unobstructed area, the transmission distance can reach up to 300 meters. This can be reduced by trees, buildings and other sou rces of the same frequency. Before every flight, it is suggested that you ensure the Range Extender is functioning properly; otherwise communication issues between the mobile device and the Phantom 2 Vision may occur.
DJI VISION APP

System Requirement o f Mobile Device:
1. IOS recommended: iPhone4s, iPhone 5, iphone5s, iPhone6, iPhone6 Plus, IPod Touch5 ( available but not recommended: iPad3, iPad4, iPod mini)
2. Android recommended: Samsung Galaxy S3, S4, Note 2, Note 3 or phones of similar configuration
Pha ntom 2 Vision Before Flight33

Once pre

- flight preparation is complete, it is recommended to carry out the tasks in the Phantom Pilot Training Guide to prepare for more complex flight maneuvers and learn to fly safely. Ensure that all flights are carried ou t in a suitable location.

Flight Environment Requirements
1. Do not use the aircraft in severe weather conditions. These include wind speed exceeding category 4, snow, rain and smog.
2. Fly in open fields as high buildings or steel structures may affect the accuracy of the onboard

compass. 3. Keep the Phantom away from obstacles, crowds, high voltage power lines, trees or bodies of water when in flight.
4. Reduce the chance of electromagnetic interference by not flying in areas with high levels of electromagnetis m, including base stations or radio transmission towers.
5. The Phantom cannot operate within the polar areas.
6. Do not fly the aircraft within no

- fly zones specified by local laws and regulations.

Preflight Checklist
1. Remote Controller, smart battery, Ran ge Extender and smartphone are fully charged.
2. Propellers are mounted correctly.
3. Damping absorbers are in good condition, not broken or worn.
4. Anti

- drop kits have been mounted correctly.
5. Camera lens cap has been removed.
6. Micro

- SD card has been inserted if necessary.
7. Motors can start and are functioning as normal.
8. DJI VISION App can connect to the camera.

DJI Vision App Usage The DJI VISION App controls the Phantom 2 Vision camera including capture, recording, settings and pitch angle. It also displa ys essential flight information including flight parameters and battery. Calibrating the Compass34

IMPORTANT: Make sure to calibrate the compass in every new flight location. The compass is very sensitive to electromagnetic interference, which can cause ab normal compass data leading to poor flight performance or even flight failure. Regular calibration is required for optimum performance.
Calibration Procedures Choose an open space to carry out the following procedures. Watch the Phantom 2 Vision quick st art video for more details.

Hints and Tips: If compass calibration is needed before flight, a prompt will appear on the DJI VISON App’s camera page. It will disappear after successful calibration.

When to Recalibrate
1. When compass data is abnormal, th e rear LED flight indicator will blink red and yellow.
2. Flying in different location to last flight.
3. Mechanical structure of the Phantom has changed, i.e. changed mounting position of the compass.
4. Severe drifting occurs in flight, i.e. Phantom does not f ly in straight lines.

Starting Motors A Combination Stick Command (CSC) is used to start the motors instead of simply pushing the stick up. Push both sticks to their bottom corners to start the motors. Once the motors have spun up, release both
sticks s imultaneously.

Stopping Motors There are two methods to stop the motors. Method 1: When the Phantom has landed, push the throttle down, then conduct CSC. Motors will stop immediately. Release both sticks once motors stop.
Method 2: When the aircraft h as landed, push the throttle down and hold. Motors will stop after 3
seconds.

Warning: Do not execute CSC during normal flight. This will stop the motors and cause the aircraft to drop without control.

References: Conduct the CSC as neatly as you can. Release the sticks once motors start/stop. Take off /35

Landing Procedures
1. Place the Phantom 2 Vision on open flat ground with battery indicators facing towards you.
2. Power on the Remote Controller and Range Extender, then the Smart Flight Battery.
3. Launch the DJI VISION App and start bind it with your smartphone then enter the camera preview

page. 4. Wait until the Rear LED Flight Indicator blinks green. This means it has initialized and is Ready to Fly. If it flashes yellow, it is in Ready to Fly (non

- GPS ) mode and will require more careful flight.
Execute the CSC command to start motors.
5. Push the throttle up slowly to take off. Refer to Remote Controller Operation for more details.

6. Shoot photos and videos using the DJI VISION App. Refer to DJI VISION App Usage for more
details.
7. To land, hover over a level surface and gently pull down on the throttle gently to descend.
8. After landing, execute the CSC command or hold the throttle at its lowest position for 3 seconds or more until the motors stop.
9. Tur n off the smart battery, Range Extender and Remote Controller.

Important:
1. When the Rear LED Flight Indicator blinks yellow rapidly during flight, the aircraft has entered
Failsafe mode.
2. A low battery level warning is indicated by the Rear LED Flight Ind icator blinking red slowly or rapidly during flight.
3. View tutorials about flight for more flight information: www.dji.com/phantom2vision/training.

Video Suggestions and Tips
1. Work through the checklist before each flight.
2. Aim to shoot when flying in Re ady to Fly only.
3. Always fly in good weather, such as sunny or windless days.
4. Change camera settings to suit you. These include FOV, photo format and exposure compensation.
5. Take flight tests to establish flight routes and scenes.
6. Push the sticks gently to make aircraft movements stable and smooth.36

Failsafe Function The Phantom will enter Failsafe mode when its connection to the Remote Controller is lost. The Flight Control System will automatically control the aircraft to return to home and land to p revent injury or damage.

Hints and Tips: Home Point: When the Phantom enters ’Ready to Fly’ from the ‘Ready to Fly status (non

- GPS)’, the GPS coordinates will be recorded and set as the home point.
1. When Remote Controller signal is lost, the aircraft wil l return to the recorded home point
coordinates and land.
2. Home point coordinates are used to calculate the horizontal distance of the aircraft (shown as “Distance” on the GUI of the DJI VISION App).
3. After successfully recording the home point, rear LED f light indicators blink fast green.

When will Failsafe Activate?
1. The Remote Controller is powered off.
2. The Phantom has flown out of effective communication range.
3. The signal between the Remote Controller and the Phantom has been blocked.
4. There is inte rference causing a signal problem with the Remote Controller.

Failsafe Procedure Initiating the Failsafe mode from different flying statuses will results in different landing processes. Ready to Fly (non

- GPS)

---- Automatic landing The Flight Control System will keep the aircraft level during descent and landing. It may be drift during the descent and landing process. Ready to Fly

---- Automatic go home and land The Flight Control System will automatically control the aircraft to fly back to the home point and land. The below demonstrates the complete Ready to Fly Failsafe landing process.

Important:
1. To ensure the aircraft successful return to home after Failsafe activation, aim to only fly in Ready to Fly mode.37

2. The Phantom will automatically d escend during the Failsafe process if there are less than 6 GPS

satellites detected for more than 20 seconds.
3. The aircraft cannot avoid obstacles during Failsafe. Hints and Tips: Quickly flipping the S2 switch of the Remote Controller from top to bottom 5 times or more will reset the current aircraft position as a new home point. Rear LED flight indicators will blink green rapidly when successful. Failsafe on the DJI VISION App The DJI VISION App will provide information during Failsafe Regaining Contr ol During Failsafe Procedures Low Battery Level Warning Function The low battery level warning alerts users when the battery is close to depletion during flight. When it appears, users should promptly fly back and land to avoid accidental damage. The Pha ntom 2 Vision has two levels of low battery level warning. The default battery level warning thresholds are 30% (low battery level warning) and 15% (critical low battery level warning) respectively.

Flight Limits All unmanned aerial vehicle (UAV) operat ors should abide by all regulations from such organizations as the ICAO (International Civil Aviation Organization) and their own national airspace regulations. For safety reasons, the flight limits function is enabled by default to help users use this pro duct safely and legally. The flight limits function includes height, distance limits and No Fly Zones. In Ready to Fly mode, height, distance limits and No Fly Zones work together to manage flight. In Ready to Fly (non

- GPS) status, only height limits work and flights cannot go higher than 120m.

References : Default parameters in Assistant Software are compliant within the definitions of class G ruled by ICAO. (Refer to Airspace Classification to get more details). As each country has its own rules,
make s ure to configure these parameters to comply with these rules before flying. Max Height & Radius Limits Max Height & Radius limits flying height and distance. Configuration can be done in the Phantom 2 Vision Assistant. Once complete, your Phantom will fl y in a restricted cylinder. Preparing the Remote Controller The Phantom 2 Vision Remote Controller is a wireless communication device using the 5.8GHz frequency band. Remote Controller and Phantom are paired before delivery. The Remote Controller is38

set t o Mode 2 by default. This can be adjusted in the PHANTOM RC Assistant Software. See Using the
PHANTOM RC

Definitions: Compliance Version: The Phantom 2 Vision Remote Controller is compliant with CE and FCC (see the FCC ID) regulations.

Operating Mode: Mode 1 and Mode 2 refer to different channel mappings. Mode 1: The right stick
controls throttle. Mode 2: The left stick controls throttle. Hints and Tips:

The Range Extender and Phone Holder are already mounted on the Remote Controller. Twist the Phone Holder to face outwards and fix it in position for mobile device installation.

Warning: Large smartphones and tablets are not recommended for the Phone Holder as they do not fit.
The Remote Controller

Before every flight, it is suggested that you ensu re the Range Extender is functioning properly; otherwise communication issues between the mobile device and the Phantom 2 Vision may occur.

Safe operating procedures:

Getting ready for take off

- Turn on the remote controller.

- Be sure that both switches (S1 & S2) are in their top position.

- Turn on the range extender.

- Turn on the intelligent flight battery pressing once, release then press and hold.

- Connect your smart device to the Phantom’s WiFi signal.

- Start the vision application.

- Calibrate the Phantom’ s compass by:

- Flipping the S1 switch located on the top right on the remote controller between its top and bottom positions at least 5 times, ending with the S1 switch in the top position; or tap “compass calibration”39

in the DJI vision app. When the LED fl ight indicator lights display solid yellow, DJI Phantom 2
Vision is ready for calibration.

- Pick up the Phantom and rotate it 360* horizontally with the front facing away from you. When the LED flight indicator changes to solid green the horizontal calibrat ion was a success.

- Continue the calibration process by holding the Phantom vertically with the front facing downward and rotating it 360* again. When the LED flight indicator lights blink green the full calibration was a

success.

- If the LED flight indicato rs blink red and yellow, the calibration was not successful and you should try the calibration process again.

Takeoff

- Set Phantom on a flat surface with the camera pointing away from pilot.

- Ensure home point has been achieved by checking the vision app fo r at least 6 GPS satellites. The LED flight indicators will flash green quickly when a home point is recorded.

- Start the Phantom by pushing both sticks on the radio to their bottom corners, towards one another (4
o’clock with the left stick and 7 o’clock w ith the right stick). This will start the motors.

- Slowly push left throttle stick up to increase power to the motors until the Phantom lifts off the ground. Always push the sticks softly.

- Allow the Phantom to hover at 10

- 15 feet to check for proper stabili ty and get your bearings.

- Gently adjust the sticks to ensure Phantom responds accordingly.

- Frame the shot via the FPV view on mobile device.

- Push the shutter button in the vision app to take images or video.

Landing

- Select a safe landing area and hover ov er it.

- Descend by gently reducing the throttle taking the left stick down.

- Once safely landed push the throttle down and hold until motors stop completely.

- Download videos and photos to your mobile device through the vision app.

- Turn off the intelligent fl ight battery, range extender and remote controller.

Post

- flight debrief

- After each flight, and before your next flight, always inspect the Phantom for any damage.40

Other comments:

- No personal modifications are recommended to the Phantom

- Do the compass ca libration and always ensure the home point has been recorded before flying.

- Stay focused while flying; alternate your eyes between the Phantom and on the smart device.

- Be aware of the flight parameters. Monitor battery telemetry closely.

- You can get a max of 25 minutes of flight time with the intelligent flight battery, depending on location, environmental conditions and flight maneuvers.

- The remote controller has a typical range of about 2,600 feet while the video feed has a range of about 2,300 feet. Howe ver, we do not recommend flying beyond “Line of Sight” (LOS).

- The default height limit is 400 feet and we recommend never exceeding this height.

- The Phantom can fly a max of 33mph, howeve r we do not recommend flying at this speed. Always be careful, a s the Phantom can pick up additional speed when flying down wind.

- Including battery and camera the Phantom weighs 2.7lbs

- The Phantom can climb at a speed of 20feet/second and descend at a speed of 6feet/second.