UNITED STATES OF AMER ICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

WASH I NGTON, DC

Regulatory Docket No.

**IN THE MATTER OF THE PETITION FOR EXEMPTION OF**  **: JESSE RICHARD**  **WALKER FOR AN 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) CONCERN ING COMMERCIAL**  **OPERATION O**  **F DJI PHANTOM 2 VISION+**  **UNMANNED AIRCRAFT SYSTEM**  **PURSUANT TO SECTION 333 OF THE**  **FAA MODERNIZATION**  **AND REFORM**  **ACT OF**  **2012**

**(PUBLIC LAW**  **112 -**  **95)**

Submitted on May

6 , 2015 Jesse Richard Walker 1407 Smith Cir, Wichita, KS , 67212 316

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- 20182 **TABLE OF CONTENTS** Page GLOSSARY OF ABBREVIATIONS...................................................................................3 SUMMARY.....................................................................................

.......... . ...........................4 I N TRODUCTION AND INTERESTS OF PETITIONER....................................................4 BACKGROUND..................................................................................................................

. .4 BAS I S FOR PETITION.........................................................................................................5 NAME AND ADDRESS OF PETITIONER.............................................................7 THE SPECIFI C SECTIONS OF 14 C.F.R. FRO M WHI CH JESSE RI CHARD WALKER SEEKS EXEMPT ION.............................................................

............ ....8 T HE EXTENT OF RELIEF JESSE RI CHARD WALKER SEEKS AND THE REASON JESSE RI CHARD WALKER SEEKS THE RELIEF.........................11 THE REASONS WHY GRANTING JESSE RI CHARD WALKER’S REQUEST WOU LD BE IN THE PUBLIC INTEREST .................................................. .......15 THE REASONS WHY GRANTING THE EXEMPT ION WOULD NOT ADVERSE L

Y AFFECT SAFETY..........................................................................19 SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REG I STER......34 ANY ADDITIONAL INFORMATION, VI EWS, OR ARGUMENTS AVAILABLE TO SUPPORT JESSE RI CHARD WALKER’S REQUEST........

........................................................................................ .34 CONC L USION............................................................................

...................................... . .35 APPEND ICES........................................................................................373 **GLOSSARY OF** **AB B**  **REVIATIONS** AG L Above Ground Level AO I Area of Interest ATC Air Traffic Control ATO Air Traffic Organization AV Aerial Vehicle CFR Cod e of Federal Regulations COA Certificate of Authorization FAA Federal Aviation Administration FAR Federal Aviation Regulation GCS Ground Control Station GPS Global Positioning S y stem LOL Lo ss of Link NA S National Airspace S ystem NOTAM Notice to Airman P IC Pilot I n Command Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333 S O Safety Observer SOP Standard Operating Procedures UA Unmanned Aircraft UA S Unmanned Aircraf t S ystem VF R Visual Flight Rules VLOS Visual Line of Site VMC Visual Meteorological Conditions VTOL Vertical Takeoff and Landing4 **SUMMARY** Jesse Richard Walker 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 91.4 17(a) & (b), to operate an Unmanned Aircraft Sy stem pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Jesse Richard Walker to operate an Unmanned Aircraft S ys tem (UAS) for the commercial purpose of c onducting aerial video and photography of outside events and
venues over certain areas of the United States.

**INTRODUCTION AND**  **INTERESTS OF**  **THE PETITIONER**  Jesse Richard Walker provides his clients with expertise and knowledge in advanced technologies and so lutions to increase efficiency , productivity and effectiveness in a photographical and video

- graphical setting. Jesse Richard Walker has over 5 y ears of professional experience in professional photography , videography , and graphic design. He has over 5 ye ars recreational/hobby experience in all aspects of aerial video and p hotograph y. The objective of Jesse Richard Walker aerial video and photography operations is to provide high quality imaging for a variety of commercial and public uses , specificall y tar geting:

 Motion Picture Filming  Professional Photography  Outdoor event/venue coverage
**BACKGROUND** UnmannedAircraft S ystems: DJ IPhantom2 Vision UAS Jesse Richard Walker seeks an exemption to operate DJ I s ystems for compensation or hire within the NAS. The DJ I Phantom 2 Vision+ is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing5

electronic tablet or smart phone sy stems. The DJ I Phantom 2 Vision+ has a maximum gross weight of approximately 2 pounds 11 ounces, while having a length of 16 inches width of 16 inches, height of 8 inches, and a maximum speed of approximately 29 knots. The D J I P hantom 2 Vision+ is equipped with four main rotors; driven by Lithium Pol y mer battery powered electric motors.
The DJ I Phantom 2 V ision+ UA that will be operated by Jesse Richard Walker will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft , as well as 14 C.F.R Part 47, Aircraft Registration , and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking

. **BASIS FOR** **PETITION** Petitioner, Jesse Richard Walker , pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereb y petitions the Administrator to commercial ly operate the DJ I Phantom 2 Vision + UAS in the National Airspace S ystem (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, Jesse Richard Walker operation of DJ I Phantom 2 Vision+ 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. Accordingl y, Jesse Richard Walker 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 on l y app l y t o ai rcraft with an airworthiness certificate.6 Jesse Richard Walker submits that the requested relief is proper since an equivalent level of safety will be ensured. Jesse Richard Walker 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., M onthl y Maintenance Log, and DJI Ph antom 2 Vision+ Instruction Manual). Furthermore, Jesse Richard Walker will document and maintain all maintenance records for the DJ I Phantom 2 Vision+ UAS

. Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested by Je sse Richard Walker to the extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an airman medical certificate, and who has demonstrated, by meeting minimum flight

- hour and currency requirements, that the P IC is able to safely operate the DJ I Phantom 2 Vision+ UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appro priate distances from people, vessels, vehicles and structures. Jesse Richard Walker seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness , because the DJI P hantom 2 Vision+ UAS do es not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Jesse Richard Walker submits that he will ensure that the DJ I P hantom 2 Vision UAS is in an airworthy condition, prior to every flight, b y determining that the UAS is in compliance with the operating documents (i.e., Monthl y Maintenance Log, and DJ I Phantom 2 Vision + Instruction Manual), and that th e aircraft is in a condition for safe flight. Jesse Richard Walker also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , as the DJ I P hantom 2 Vision+ UA will not have a ty pical barometric altimeter onboard. However, altitude information of the DJI Phantom 27

Vision+ UAS will be provided to the PI C via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with Jesse Richard Walker ' s operation of the DJ I Phantom 2 Vision+ UAS within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. Additionally , Jesse Richard Walker seeks an exemption from the requirements of Section 9 1.151(b), entitled Fuel requirements for flight in VFR conditions

. Jesse Richard Walker submits that safety will not be affected by

operation of the DJ I Phantom 2 Vision+ UA during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to f l y for a total duration of approximately 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to f

l y after that for at least 4.5 minutes. In accordance with 14 C.F.R. § 11.81, Jesse Richard Walker provides the following information in support of its petition for exemption: **A . Name And Address Of The Petitioner.**  The name and address of the Petitioner and point of contact is: Jesse Richard Walker 1407 Smith Circle, Wichita, KS 316

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- 2018 Email: G cgraphics316@gmail.com **B. The Specific Sections Of 14**  **C.F.R. From**  **Whic h**  **Jesse Richard Walker Seeks**  **Exemption. 1.**  **Jesse Richard Walker Seeks Exemption From The Requirements Of**  **Secti on 61.113(a) And (b).**  Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections (a) and (b) prescribe the following, in relevant part:8 (a) No person who holds a private pilot certificate may act as a pilot in command (P IC) of an aircraft that is carry ing passengers or propert y for compensation or hire; nor may that person, for compensation or hi re, act as PIC of an aircraft. (b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with an y business or empl o y m ent i f

— (1) The flight is only incidental to that business or emplo y ment; and (2) The aircraft does not car ry passengers or property for compensation or hire.
**2. Jesse Richard Walker**  **Seeks Exemption From The Requirements Of**  **Section 91.7(a).** Section 91.7, entitled Civil aircraft airworthiness , subsection (a), states the following: (a) No person may operate a c ivil aircraft unless it is in an airworthy condition. **3. Jesse Richard Walker**  **Seeks Exemption From The Requirements Of Section 91.121.**  Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraf

t, as the case may be, b y reference to an altimeter that is set, when operating

-- (1) Below 18,000 feet MS L , to
-- (i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or (iii) I n the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure. **4. Jesse Richard Walker**  **Seeks Exemption From The Requirements Of Section 91.151(b).**  Section 91.151, entitled Fuel requirements for flight in VFR conditions , subsection (b), states the following:9

( b ) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fu e l to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes. **5. Jesse Richard Walker**  **Seeks Exemption From The Requirement 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 shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.] **6. Jesse Richard Walker**  **Se eks Exemption From The Requirements Of**  **Section 91.407(a)(1)** Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration , subsection (a)(1), states the following: (a) No person may operat e any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unles s -- (1) It has been approved for return to service b y a person authorized under § 43.7 of this chapter[.] **7. Jesse Richard Walker**  **Seeks Exemption From The Requirements Of Secti**  **ons 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) 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 approved for return to service b y a person authorized by § 43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordan ce with part 21 of this chapter. **8. Jesse Richard Walker**  **Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b).**  Section 91.417, entitled Maintenance re c ords , subsections (a) and (b), state the following: (a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods10 specified in paragraph (b) of this section: (1) Records of the maintenance, preventive maintenance, an d alteration and records of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must includ e - - (i) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of completion of the work performed; and (iii) The signature, and certificate number of the person approving the aircraft for return to service. (2) Records containing the following information: (i) The total time in service of the airframe, each engine, each propeller, and each rotor. (ii) The current status of lif e - 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 cur

rent 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 saf ety directives including, for each, the method of compliance, the AD or safe t y 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 b y § 43.9(d) of this chapter for each major alteration to the airframe and currentl y insta lled engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or super seded b y other work or for 1 ye ar 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.11 (3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service. **C. The Extent Of Relief Jesse Richard Walker**  **Seeks And The Reason Jesse Richard**  **Walker Seeks Th**  **e Relief. 1. Extent Of Relief**  **Jesse Richard Walker Seeks And The Reason**  **Jesse Richard Walker**  **Seeks Relief From Section 61.113(a) And (b).** Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in comman d, is reques ted to the extent necessary to allow a P IC 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 conduct the proposed UAS flight operations for compensation or hire. This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act a s P IC of an aircraft in connection with an y business or empl o y m ent if: (1) The flight is only incidental to that business or emplo y ment; and (2) The aircraft does not carry passengers or propert y for compensation or hire. As set forth more full y below, Jesse Richard Walker submits that an equivalent level of safety will be m aintained because no PI C will be allowed to operate the DJ I Phantom 2 Vision+ UAS unless that PI C has met certain flight

hour and currency requirements, demonstrating that the PI C is able to safely operate the DJ I Phantom 2 Vision+ UAS in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency
maneuv ers, as well as maintaining appropriate distances from people, vessels, vehicles and structures. Further, Jesse Richard Walker submits that all flights of12

the DJI Phantom 2 Vision UAS, conducted b y the PI C pursuant to the grant of this Petition: (1) will be incidental to Jesse Richard Walker 's business; and (2) will not
carry passengers or property fo r compensation or hire. **2. Extent Of Relief Jesse Richard Walker**  **Seeks And The Reason Jesse Richard**  **Walker Seeks Relief From Section 91.7(a).**  Relief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to the extent required to allow Jesse Richard Walker to determine that the DJ I Phantom 2 Vision + UAS is in airworth y condition prior to every flight b y ensuring that the UAS is in compliance with the operating documents (i.e., the Jesse Richard Walker Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ Instruction Manual). Jesse Richard Walker seeks the requested relief because the DJ I Phantom 2 Vision + UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Jesse Richard Walker will ensure that the DJ I Phantom 2 Vision+ UAS is in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJ I Phantom 2 Vision+ Instruction Manual) prior to every flight, and further, determine that the aircraft is in
c o ndition for safe flight, as stated in the conditions an d limitations listed.
**2. Extent O f Relief**  **Jesse Richard Walker Seeks And The Reason**  **Jesse Richard Walker**  **Seeks Relief From Section 91.121.** Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the DJ I Phantom 2 Vision+ UAS , which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the P IC at the ground control station13

(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), Jesse Richard Walker seeks the requested relief because the DJ I P hantom 2 Vision+ UA’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight. Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply with the applicable conditions and limitations stated below. As more ful l y set forth herein, an equivalent level of safet y will be maintained since the DJI Phantom 2 Vision+ UA is equipped with a barometric pressure sensor and GPS equipment, which automatical l y ensures that a ground level pressure setting will be established prior to each flight, and provides the P IC with altitude information of the UA on the heads

- u p display of th e GCS. **4. Extent Of Relief Jesse Richard Walker**  **Seeks And The Reason Jesse Richard**  **Walker Seeks Relief From Section 91.151(b).**  Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to allow flights of the battery powered D J I Phantom 2 Vision+ UA during day light hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to the first point of intended landing and, ass uming normal cruising speed, to fl y after that for at least 4.5 minutes. Jesse Richard Walker seeks the requested relief because without an exemption from Section 91.151(b), the flight time durati o n of the battery powered D JI Phantom 2 Vision+ UA will seve rely constrain the practicality o f any aerial video or still photo flight operations that Jesse Richard Walker proposes to conduct pursuant to this Petition.14 Significantl y, as set forth below, the technical specifications of the D J I P hantom 2 Vision+ UAS , the DJ I P hantom 2 Vision+ operating documents, and Jesse Richard Walker ' s proposed operating limitations, ensure that Jesse Richard Walker will safely operate the battery

p o wered DJ I Phantom 2 Vision+ UA during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fl y for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fl y after that for at least 4.5 minutes. **5. Extent Of Relief Jesse Richard Walker**  **Seeks And The Reason Jesse Richard**  **Walker 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) onl y appl y to aircraft with an airworthiness certificate, Jesse Richard Walker requests relief from these Sections because the DJ I P hantom 2 Vision+ UAS do es not require airworthiness certificates. As set forth more full y below, the DJ I P hantom 2 Vision+ UAS meets the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingl y , Jesse Richard Walker will use trained technicians to perform maintenance, alterations, or pr eventive maintenance on the UAS using the meth ods, techniques, and practices prescribed in the UAS operating documents (i.e., the Jesse Richard Walker Aerial Operations Manual, Monthly Maintenance Log, and DJ I Phantom 2 Vision+ 1 Instruction Manual). Furthermore, Jesse Richard Walker will document and maintain all maintenance records for the DJ I P hantom 2 Vision+ UAS

. **D. The Reasons Why Granting Jesse Richard Walker**  **Request Would Be In The Interest; That Is, How It Would Benefit The Public As A Whole.**  **Public**15 Granting the present Petition will further the public interest b y allowing Jesse Richard Walker t o safel y, efficientl y, and economically perform aerial video and photograph y of outside events and venues over certain areas of the United States. Additionall y, use of the DJI Phantom 2 Vision+ UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the
economy . Notabl y, the benefits of Jesse Richard Walker ' s proposed operation of the DJI Phantom 2 Vision+ UAS will be realized without impli cating any privacy issues. **1. The Public Will Benefit From Decreased Congestion Of The NAS.** The D J I Phantom 2 Vision UA is battery powered and serve s as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery . B y reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a D J I Phantom 2 Vision+ UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as w ell as increase the safe t y of life and propert y in the air and on the ground. Furthermore, b y reducing the number of manned aircraft operating in the NAS, congestion around airports caused b y arriving and departing aircraft will be reduced. The DJ I Phantom 2 Vision+ UA does not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photograp h y missions would result in fewer aircraft that must be handled b y air traffic control duri n g the ground, takeoff, departure, arrival, and landing phases of flight operations. **2. The Public Will Benefit From The Safety And Efficiency Of The DJI**  **Phantom 2 Vision+ UAS**  **.**16 Conducting aerial acquisitions with the DJI Phantom 2 Vision+ UAS, instead of
manned aircraft, will great l y benefit the public b y drasticall y reducing the levels of air and noise pollution generated during traditional aerial video and still photograp h y flight operations. By

using battery

power a nd electric motors, the D J I Phantom 2 Vis ion+ UAS produce s no air pollution, and is the most viable
environmental l y conscious alternative to the cabin class, six c y linder internal combustion engine aircraft that are t ypical l y utilized for aerial video and photography, while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The D J I Phantom 2 Vision+ UA , while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution , as the UA is propelled b y battery powered electric motors, rather than an internal combustion engine. B y using the D J I Phantom 2 Vision+ UAS to perform aerial acquisitions, the substantial risk to life and property in the air and on the gro und, which is usually associated with traditional manned aircraft flight operations, w ill be substantially reduced or complete l y eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJ I Phantom 2 Vision+ UA (weighing approximately 2 pounds 11 ounce , at its maximum gross weight with a length of 16 inches and a width of 16 inches and with no fuel on board), has l es s ph ysical potential for collateral damage to life and proper t y on the ground, and in the air, compared to the manned aircraft that ty picall y conduct similar operations (weighing approximately 6,00 0 pounds with a wingspan of approximately 42 feet, a len gth of 34 feet, and a fuel capacity of 180 gallons).17 **3. Performing Aerial Video and Photography Operations With The DJI Phantom 2 Vision+**  **UAS Will Benefit The Economy.**  In addition to being safe and efficient, the D J I P hantom 2 Vision+ UAS is also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJ I Phantom 2 Vision+ UAS will allow United States based companies, lik e Jesse Richard Walke r ’s , to remain competitive and contribute to growth of the U.S. economy . Specifically , with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating th e battery powered DJ I Phantom 2 Vision+ UAS is one such technology that not onl y allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft. B y operating the DJ I P hantom 2 Vision+ UAS , companies such as Jesse Richard Walker ’s , can remain competitive and profitable, and therefore, provide greater job st ability t o employees and contractors, which will ultimately contribute to growth of the U.S. economy . Improved financial performance of U.S. companies, through commercial use of the DJ I Phantom 2 Vision+ 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 order to remain competitive both in the United States and abroad. **4. There Are No Privacy Issues.** Similar to the manned aerial acquisition flight operations that have been conducted for decades, Jesse Richard Walker 's proposed operation of the DJ I Phantom 2 Vision+ UAS will not implicate any privac y issues. Specifical l y , th e D J I Phantom 218

Vision+ UAS will be operated onl y in compliance with operating documents (i.e., the Jesse Richard Walker Aerial Operations Manual, Monthly Maintenance Lo g, and DJI P hantom 2 Vision+ Instruction Manual) which requires propert y owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119. **E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Pr**  **ovide A Level Of Safety At Least Equal To That Provided By The Rule From Which**  **Jesse Richard Walker Seeks Exemption.**  **1. Reasons Why The DJI Phantom 2 V i**  **sion+ UA**  **Meet The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333.**  In co nsideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, Jesse Richard Walker operation of the DJ I Phantom 2 Vision+ UAS meet s the conditions of FMRA Section 333, and will not require an ai rworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national securi t y. Specifical l y, FMRA Section 333 states the follo w ing, 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.19 ( b ) Assessment of Unmanned Aircraft Systems.

- -In making the determination under subsection (a), the Secretary shall determine, at a minimu m -- ( 1 ) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace sys tem or the public or pose a threat to national security; and ( 2 ) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned a ircraft systems identified under paragraph (1). (c) Requirements for Safe Operation

. --If the Secretary determines under this section that certain unmanned aircraft systems may operate s afely 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, Jesse Richard Walker submits that the DJ I Phantom 2 Vision+ UAS can operate safel y in the NAS pursuant to FMRA Section 333, as demonstrated b y : (a) the characteristics of the D J I Phantom 2 Vision+ UAS ; (b) the pilot certification requirement; and (c) the specific operating limitations.

**a. The Specifications Of The DJI Phantom 2 Vision+ UAS**  **Demonstrate Its Safe Characterist** **ics.** The D J I Phantom 2 Vis i on+ UAS do not create a hazard to users of the NAS or the public, or otherwise pose a threat to national securi t y considering its size, weight, speed, and operational capability .

**i. Technical Specifications Of The DJI Phantom 2 Vision+**  **UAS .**  The technical specifications of the D J I Phantom 2 Vision+ UAS is set forth b y th e D J I Phantom 2 Vision+ Specifications and Data Shee t, attached hereto as Exhibit A.20 **ii. The DJI Phantom 2 Vision+ and**  **UAS Autonom**  **ous Flight And Navigation Modes Enable The UASs To Remain Within A Defined**  **Operational Area.** The D J I Phantom 2 Vision+ UAS may be operated in both manual and ful l y autonomous flight modes. A comp lete description of the flight and navigational modes of the D J I Phantom 2 Vision+ UAS is provided at pages 25

- 35 of the D J I Phantom 2 Vision+ User Manual , attache d hereto as Exhibit B

.

**iii. The**  **DJI Phantom**  **2 Vision+**  **and UAS**  **Is Designed**  **For Automatic**  **Retu rn**  **To Home**  **Point Or**  **Hover In**  **The Event**  **Of Loss**  **Of The**  **Control Link Or Navigation.** When the Control Link is lost, the DJ I Phantom 2 Vision+ UA will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the D J I Phantom 2 Vision+ UA do es not reacquire control link data from the GCS, the UAs will assume that the Control Link is lost and the UAs will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown. A complete description of th e Failsafe Functions of the D J I Phantom 2 Vision+ UAS is set forth at pages 27 through 29 of the D J I Phantom 2 Vision+ User Manual , attached hereto as Exhibit B

.

**iv. The DJI Phantom 2 Vision+ GCS And Its Operation** 

**.** A complete description of the operation and specifications of the D J I Phantom2 Vision+ and flight control software is provided at pages 32 through 43 of the D J I Phantom 2 Vision+ User Manual. D J I Phantom 2 Vision+ User Manual is atta ched hereto as Exhibit B
.

**b. Flight Operations Of DJI Phantom 2 Vision+**  **UAS Is**  **Limited To The Line Of Sight Of A Certificated Pilot in Command With A**  **S afety**  **Observer.**21 Jesse Richard Walker will only utilize certificated pilots who possess a current and valid airman medical certificate to act as a pilot in command (PI C) of the DJI P hantom 2 Vision+ UAS . Additionally , a safety observer will assist all pilots during flight time. **c. Flights Of DJI Phantom 2 Vision+ UAS**  **Will Be**

**Conducted Pursuant To Specific Operating Limitations.** In seeking this exemption, Jesse Richard Walker proposes to commercially operat e DJ I Phantom 2 Vision+ UAS for the special purpose of conducting aerial video and photograph y 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 desc ribed in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: D J I Phantom 2 Vision+ Unmanned Aircraft S ys tems. Proposed operations of an y 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 photograp h y. 3. The UAs may not be flown at an indicate d airspeed exceeding 20 knots. 4. The UA must be operated at an altitude of no more than 500 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved b y ATC. All altitudes reported to ATC must be in feet AGL. 5. The UAs must be operated within visual line of sight (VLOS) of the P IC at all times. This requires the PIC to be able to use human vision unaided by an y device other than corrective lenses, as specified on the P IC’s FAA

- issued airman medical certificate.6. The use of first person view (FPV) b y the P IC or safe t y observer (SO) is not permitted. 7. All operations must utilize a safe t y observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PI C always maintains V LO S capability . The SO and P IC must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. Th e P IC must ensure that the SO can perform the functions prescribed in the operating documents.22 8. The SO must not perform any other duties be yond assisting the P IC with seeing and avoiding other air traffic and other ground based obstacles/obstructio n s and is not permitted to operate the camera or other instruments. 9. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon requ est. If a discrepancy exists between the c o nditions and limitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption take precedence and must be f

ollowed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised docum ents 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 wh ich the FAA granted the exemption, then the operator must petition for amendment to its grant of exemption. The FAA’s UAS I ntegration Office (AF S

- 80 ) may be contacted if questions arise regarding updates or revisions to the operating documents. 10. Prior to each flight the P IC must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properl y documented in the aircraft records. 11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The P IC 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 alread y covered in the relevant sections of the operating documents.23 13. The operator must follow the UAS manufacturer’s aircraft/component, maint enance, overhaul, replacement, inspection, and life limit requirements. 14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircra f t records, including total time in service, description of work accomplished, and the signature of the authorized person returning the UAS to service. 15. Each UASs operated under this exemption must comply with all manufacturer Safety Bulletins. 16. The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections. 17. The P IC must possess at least a private pilot certificate and at least a current third

- class medical certificate. 18. The operator may not permit any PI C to operate unless the P IC meets the operator’s qualification criteria and dem onstrates the ability to safe l y operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PI C qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator’s PICs are permitted under the terms of the exemption. However, training operations may onl y be conducted during dedicated training sessions. During training, proficienc y, and experienc e - building flights, all persons not essential for f light operations are considered nonparticipants, and the P IC must operate the UA with appropriate distance from nonparticipants in a ccordance with 14 C.F.R. § 91.119. 19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will b e made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized. 20. The UA may not operate within 5 nautical miles of an airport reference point as denoted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request.24 21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the P IC. 22. If the UA loses communications or loses its GPS signal, it must return to a p re determined location within the planned operating area and land or be recovered in accordance with the operating documents. 23. The P IC must abort the flight in the event of unpredicted obstacles or emergenci es in accordance with the operating document s. 24. The P IC 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 UA with 25% battery power remaining. 25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting an y operations under the grant of exemption. This COA will also require the operator t o request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitud e level and potential transponder requirem ents. 26. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (N
- Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable. 27. Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency require ments. 28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS a n y time the UAS is operating. These documents must be made available to the Administrator or an y law enforcement official upon request. 29. The UA must remain clear and y i eld the right of way to all manned aviation operations and activities at all times. 30. The UAS may not be operated b y the PIC from any moving device or ve hicle. 31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than the P IC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless:25 a. Barriers or structures are present that su f ficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permi ssion and the P IC h as made a safe t y assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, and; c. Operations nearer to the P IC, SO, operator trainees or essential persons do not present an und

ue hazard to those persons per § 91.119(a). 32. All operations shall be conducted over private or controlle d

- access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative wi l l be obtained for each flight to be conducted. 33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AF S

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

. **2. Reasons Why An Exemption From The Requireme**  **n ts Of Section 61.113(a)**  **And (b) Would Not Adversely Affect Safety.** Jesse Richard Walker submits that the equivalent level of safety established by Section 61.113(a) and (b) will be maintained because no PI C will be allowed to operate the DJ I Phantom 2 VisionUAS unless that PI C has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safel y operate the DJ I Phantom 2 Vision+ UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering Jesse Richard Walker ' s proposed area of operations, and the operating lim itations set forth

- above; the parallel nature of private pilot aeronautic al knowledge requirements to those of commercial pilot requirements ( See Exemption26

No. 11062); and the airmanship skills necessary to safel y operate the DJ I P hantom 2 Vision+ UAS, Jes se Richard Walker submits that the additional manned airmanship experience of a commercially certi f icated pilot would not correlate to the airmanship skills necessary for Jesse Richard Walker ' s specific proposed flight operations. The FAA has previously gr anted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153 , 11156, 11158, 11159, 11160, 11161). Jesse Richard Walker will not allow any PI C to operate the DJ I P hantom 2 Vision+ UAS unless that PI C has demonstrated, by meeting minimum flight

- hour requirements or the DJ I Phantom 2 Vision+ UAS training and currency requirements, that the PI C is able to safel y operate the DJ I P hantom 2 Vision+ UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and struc tures. Specifical l y, the P IC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In addition to the hour requirements, th e P IC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). As in Exemption Nos. 11062, 11138, and 11153, prior documented flight exp erience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety durin g Jesse Richard Walker 's proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance w ith applicable regulations would ensure safe operations, stating as follows:27 In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar operations), the PI C 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 log ged as a UAS pilot with a multi

- rotor UAS. Prior to operations under Exemption No. 11062, the P IC must also have accumulat e d and logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exempti on. 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 UA S rotorcraft time. In addition to the hour requirements, the P IC must accomplish 3 takeoffs and landings in the preceding 9 0 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 safel y conduct the petitioner’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficienc y, and experienc e - building flights can also be conducted under the grant of exemption to accomplish the required flight time. During training, proficienc y, and experienc e - building flights the P IC is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15. Accordingl y, Jesse Richard Walker will ensure safe operations b y not allowing any PI C to operate the D J I Phantom 2 Vision+ UAS unless that P IC has demonstrate d, b y meeting minimum flight

- hour and currency requirements, that the P IC is able to safe l y operate the DJ I Ph antom 2 Vision+ UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances fro m people, vessels, vehicles and structures. **3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety.**  The equivalent level of safety esta b lished by

Section 91.7(a) will be maintained because prior to every flight, Jesse Richard Walker will ensure that the DJ I P hantom 228

Vision+ UAS is in an airworthy condition based upon the UAS compliance with its operating documents and as stated in the conditions and limitations herein. Additionall y, the FAA has previousl y granted relief from Section 91.7(a) specific to UAS, in circumstanc e s 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, 1115 6, 11157, 11158, 11159, 11160, 11161). **4. Reasons Why An Exemption F r**  **o m**  **The Requirements Of Section 91.121 Would Not Adversely Affect Safety.**  The equivalent level of safe t y established b y Section 91.121 will be maintained because the altitude information of the D J I Phantom 2 Vision+ UA will be provided to the P IC via GPS equipment and a radio communications telemetry d ata link, which downlinks from the UA to the GCS for active monitoring of the flight path and altitude. This altitude informati o n, combined with Jesse Richard Walker 's operation of the DJ I Phantom 2 Vision UA within visual line of sight, at or below 500 feet AGL , will ensure a level of safety equivalent to Section 91.121. The altitu de information will be generated b y GPS equipment installed o nboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically established by the UASs at ground level. The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material resp ects, 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).29 **5. Reasons Why An Exemption From The Requirements Of Section 91.151(b)**  **Would Not Adversely Affect Safety.** A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of th e D J I Phantom 2 Vision+ UAS ; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingl y, Jesse Richard Walker will ensure that it will safel y operate the battery powered DJ I P hantom 2 Vision+ UA during daylight hours in VFR conditions, with enough battery power to fl y for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fl y after that for at least 4.5 minutes. Here, as in Exemption No. 11109, the technical specifications of the D J I Phantom 2 Vision+ UAS ; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safety established b y 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJ I Phantom 2 Vision+ UA provide audible and visual warnings to the P IC at the GCS when the UAs experiences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery power. At the critically lo w battery level, the D J I Phantom Vision+ UAS will descend and land automaticall y . Significantl y, previous exemptions granted b y the FAA concerning Section 91.151 establish that saf

e t y is not adverse l y affected when the technical characteristics and operating limitations of the UAS is 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 relief30

from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). **6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Woul**  **d Not Adversely Affect Safety.**  In seeking this exemption, Jesse Richard Walker 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 becaus e Jesse Richard Walker will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating document s (i.e., the Jesse Richard Walker Aerial Operations Manual, Monthly Maintenance Log, and DJI P hantom 2 Vision+ Instruction Manual). Furthermore, Jesse Richard Walker will document and maintain all maintenance
rec o rds for the DJ I P hantom 2 Vision+ UAS

. Sinc e the DJ I Phan

t om 2 Vision+ UAS will be inspected as prescribed b y the operating documents, Jesse Richard Walker will maintain the equivalent level o f safety established by

Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy
o f th e DJ I Phantom 2 Vision+ User Manual is attached hereto as Exhibit B ; a cop y of the DJI Phantom 2 Vision+ UAS Maintenance log is attached hereto as Exhibit C

. Likewise, the exemption sought will not adversel y a f fect safety because Jesse Richard Walker will use trained technicians to perform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed b y the operating documents.31 Furthermore, the exemption sought would maintain an equivalent level of safe t y established b y Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJ I Phantom 2 Vision+ UAS will be performed b y trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log. Signi f icant l y, previous exemptions granted b y the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safe t y is not adverse l y affected when the technical characteristics and op erating limitations of the UAS is co nsidered. In consideration of Jesse Richard Walker ' s proposed operating limitations, the operating documents, and the technical aspects of the DJ I P hantom 2 VisionUAS , Jesse Richard Walker submits that safety will not be adversel y affec te d by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a) (2), and 91.417(a) and (b). The FAA has previously granted relief specific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). **7. The FAA May Prescribe Any Other Conditions For Safe Operation.** Inaccordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Jesse Richard Walker requests that the FAA prescribe special conditions for the intended operation of the DJI Phantom 2 Vision+ UAS , which contain such safety st andards that th e Administrator finds necessary to establish a level of safe t y equivalent to that established b y 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)( 1 ), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAs for the limited purpose of32

conducting aerial video and photograp h y over certain areas of the United States for compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certifi c ation in accordan ce with any requirements that must be established for the safe operation of the UAS in the NAS. Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of the D J I Phantom 2 Vision+ UAS , since the airworthi ness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safe t y standards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special Conditions, states the followin g : If the FAA finds that the airworth iness regulations of this subchapter do not contain adequate or appropriate safe t y 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 co nditions 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 f inds necessary to establish a level o f safety equivalent to that established in the regulations. See 14 C.F.R. § 21.16. Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA
may prescribe special conditions for Leading Edge’s int ended operation of the D J I Phantom 2 Vision+ UAS , which contain such safe t y standards that the Administrator finds necessary to establish a level of safe t y equivalent to that established b y 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 Summary That Can Be Published In The Federal Register, stating: The Rules From Which**  **Jesse Richard Walker Seeks Exemption:** 33 Jesse Richard Walker seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a )(2), and 91.417(a) & (b). **A Brief Description Of The Nature Of The Exemption Jesse Richard Walker**  **Seeks:** This exemption will permit Jesse Richard Walker to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States. **G .**  **Any Additional Information, Views, Or Arguments Available To Support Jess**  **e Richard Walker’s**  **Request.** This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. As such, Jesse Richard Walker 's 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 securi t y; and further, provides the authority for such UAS to operate without airworth iness certification. As discussed in detail above, Jesse Richard Walker will operate the DJ I Phantom 2 Vision+ UAS safel y in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national securit y . **CONCLUSION** As set forth herein, Jesse Richard Walker seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJIPhantom 2 Vision+ UAS34

commerciall y, without an airworthiness certi f icate, 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, b y all owing Jesse Richard Walker to safel y, efficientl y, and economicall y operate the DJI Phantom 2 Vision+ UAS commerciall y within the NAS.

**WHEREFORE** , in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Secti on 333, Jesse Richard Walker respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit L eading Edge to operate the DJ I Phantom 2 Vision+ UAS commerciall y for the purpose of conducting aerial video and photograph y over certain areas of the United States. Dated: May

6 , 2015 Respectfully submitted, Jesse Richard Walker35 Jesse Richard Walker 1407 Smith Circle, Wichita, KS , 67212 316

- 302

- 2018 Email: Gcgraphics316@gmail.com Appendi ce s : A

– D J I Phantom 2 Vision+ Specifications Data Sheet B

– DJ I Phantom 2 Vision+ Manufacturer’s User Manual C

– Monthl y Maintenance Log APPENDIX

– A **DJI PHANTOM 2 VISION+ TECHNICAL**

**SPECIFICATIONS** Jesse Richard Walker only utilizes safe and reliable UASs. DJ I is an industry leader in small UAS production. DJI U ASs are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJIsoftware provides real

time altitude and location information to the PI C via the linked monitor (smart phone/tablet devices) 1.1 DJ I Phantom 2 Vision+ 1.1.1 Aircraft 1.1.1.1 Supported Battery

– D J I 5200mAH Li Po Battery 1.1.1.2 Weight (Battery & Propellers Included)

– 2lbs 11.810oz (1242g) 1.1.1.3 Hover Accuracy (Ready to F l y )

– Vertical: .8m; Horizontal: 2.5m 1.1.1.4 Max Yaw Angular Veloci t y - 200 0 /s 1.1.1.5 Max Tilt Angel

- 35 0 1.1.1.6 Max Ascent Speed

– 6m/s 1.1.1.7 Max Descent Speed

– 2m/s 1.1.1.8 Max Flight Speed

– 15m/s (NOT RECOMMENDED) 1.1.2 Gimbal 1.1.2.1 Working Current

– Static: 750mA; D y namic: 900mA 1.1.2.2 Control Accuracy

- ±0.03 0 1.1.2.3 Controllable Range

– Pitch:

- 90 0
- 0 0 1.1.2.4 Maximum Angular Speed

– Pitch: 90 0 /s 1.1.3 Camera 1.1.3.1 Operating Temperature Range

- 32 0 F
- 10 4 0 F ( 0 0 C

- 40 0 C) 1.1.3.2 Sensor Size

– 1/2.3” 1.1.3.3 Effective Pixels

– 14M36 1.1.3.4 Resolution

– 4384x3288 4.1.3.5 HD Video Recording

– 1080p30 & 720p 4.1.3.6 Recording Field of View

- 110 0 /85 0 1.1.4 Transmitter 1.1.4.1 Operating Frequency

– 5.728GHz

– 5.85GHz 1.1.4.2 Communication Distance (unobstructed)

– FCC Complianc e : 800m 1.1.4.3 Receiver Sensitivity (1%PER)

- - 93dBm 1.1.4.4 Transmitter Power

– FCC Compliance: 100mW 1.1.4.5 Working Voltage

– 120mA@3.7V 1.1.5 Range Extender 1.1.5.1 Operating Frequency

– 241 2

- 2462MHz1.1.5.2 Communication Distance (unobstructed)

– 500

- 700m 1.1.5.3 Transmitter Power

– 20dBm 1.1.5.4 Power Consumption

– 2W37 APPENDIX

– B DJ I Phantom 2 Vision+ Manufacturer’s User Manual38 **U A**  **S $**  **# :**  **$** D a t e ( I s s u e (

D is c o v e r e d D a t e ( I s s u e (

A dd r e s s e d I ss u e ( D e s cr i p t i on ( & ( M a i n t e n a n c e (C o n du c te d M a i n t e n a n c e ( P e r fo rm e d ( By: ( ( ( P r i n t ( & (S i g n S oft w a re ( U pd a t e s
A i r f r a m e (
En g i n e s
P r op e l l e r s
C a m e r a (G i m b a l
L a nd i n g ( G e a r
V i b r a t i on ( D a m p e n i n g
O t h er : APPENDIX

– C

**M O**  **N T**  **H L**  **Y $** 

**M A**  **IN T**  **E N**  **A N**  **C E**  **$**

**L O**  **G** m on t h : ( y e a r :