**UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION**  **FEDERAL AVIATION ADMINISTRATION**

**WASHINGTON, DC**

**Regulatory Docket No.**

**IN THE MATTER OF THE PETITION FOR EXEMPTION OF:**

**Christian Nowosiadly 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) CONCERNING COMMERCIA**  **L OPERATION OF DJI Inspire 1 (Model T600)UNMANNED AIRCRAFT**  **SYSTEM PURSUANT TO SECTION 333 OF**  **THE FAA MODERNIZATION AND REFORM ACT OF 2012**

**(PUBLIC LAW 112-95)**

**Submitted on Sep 22th, 2015 Christian Nowosiadly**  **45 Leyden Street Boston, MA 02128**  **(617) 501-3437 GLOSSARY OF ABBREVIATIONS** 

**AGL Above Ground Level AOI Area of Interest**  **ATC Air Traffic Control ATO Air Traffic Organization**  **AV Aerial Vehicle CFR Code of Federal Regulations**  **COA Certificate of Authorization FAA Federal Aviation Administration**  **FAR Federal Aviation Regulation GCS Ground Control Station**  **GPS Global Positioning System LOL Loss of Link**  **NAS National Airspace System NOTAM Notice to Airman**  **PIC Pilot In Command Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333**  **SO Safety Observer SOP Standard Operating Procedures**  **UA Unmanned Aircraft UAS Unmanned Aircraft System**  **VFR Visual Flight Rules VLOS Visual Line of Site**  **VMC Visual Meteorological Conditions VTOL Vertical Takeoff and Landing** **SUMMARY**

**Christian Nowosiadly seeks exemption from the requirements of 14 C.F.R §§ 61.1 13(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 the FAA Moderniz ation and**  **Reform Act of 2012 (FMRA). This exemption will permit Christian Nowosiadly to operate a n**  **Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial vide o and**  **photography of construction sites, real estate, and landscape o ver certain areas of the United States.** 

**INTRODUCTION AND INTERESTS OF THE PETITIONER Christian Nowosiadly has active ATP Multi-Engine land, Commercial Helicopter, an**  **d CFI Airplane ratings, as well as achieving the Master Wings phase through the FA**  **AST program. Christian Nowosiadly owns a successful helicopter tour and Aerial Photography**  **business operating in the New England area for over 4 years, providing his clients with expertise a**  **nd knowledge of working inside the National Airspace System to satisfy their project. Christian Nowo**  **siadly has over 4 years of professional experience in Aerial Photography along with bein**  **g an AMA model Aircraft hobbiest for 6 years flying both rotor and fixed wing aircraft. The objective o**  **f Christian Nowosiadly’s aerial video and photography operations is to provide high qua**  **lity imaging for a variety of commercial, public, and residential uses, specifically targeting:** 

• **Construction sites before and after**

• **Appraisals**

• **Real-estate marketing**

• **Motion Picture Filming**

• **Aerial acquisitions used for inspections of public and private structures.**

• **Search and Rescue operations**

• **Charity Events BACKGROUND** 

**Unmanned Aircraft Systems: DJI Inspire 1 (Model T600) UASs Christian Nowosiadly seeks an exemption to operate DJI systems for compensa**  **tion or hire within the NAS. The DJI Inspire 1 (Model T600) UASs are vertical takeo**  **ff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing e**  **lectronic tablet or smart phone systems. The DJI Inspire 1 (Model T600) has a maximum gross weight of a**  **pproximately 7.75 pounds, while having a length of 17 inches width of 18 inches, height o**  **f 12 inches, and a maximum speed of approximately 43 knots. The DJI Inspire 1 (Model T600) UA**  **s are equipped with four main rotors; driven by Lithium Polymer battery powere**  **d electric motors.**

**The** DJI Inspire 1 (Model T600) **UAs that will be operated by Christian Nowosiadly 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, Christian Nowosiadly, pursuant to the provisions of the Fe**  **deral Aviation Regulations (14**  **C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Sectio n 333,**  Special Rules for Certain Unmanned Aircraft Systems **, hereby petitions the Administrator to commercially operate the DJI Inspire 1 (Model T600) UASs in the National Airspace System (NAS), and for**  **an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.1**  **21, 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 associat ed with the**  **unmanned aircraft and its operation, Christian Nowosiadly operation of DJI In spire 1 (Model** **T600) UASs meets the conditions of FMRA Section 333 and therefore, will not require an** 

**airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingly, Christian Nowosiadly requests relief from Sections 91.405(a), 91**  **.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set**  **forth requirements for maintenance that only apply to aircraft with an airworthiness certificate. Christian Nowos**  **iadly submits that the requested relief is proper since an equivalent level of safety will be ensured.**  **Christian Nowosiadly will use experienced personnel or technicians to perform maintenance, alter**  **ations, or preventive maintenance on the UASs using the methods, techniques, and practices prescr**  **ibed in the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 (Model T600)**  **Instruction Manual). Furthermore, Christian Nowosiadly will document and maintain all maintenance records**  **for the DJI Inspire 1 (Model T600) UASs.**  **Relief from certain requirements of Section 61.113(a) and (b), entitled** Private pilot privileges

and limitations: Pilot in command **, is requested by Christian Nowosiadly to the extent necessary to allow a Pilot in Command (PIC) not holding a certificate, or an airman medical certificate, and wh**  **o has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC**  **is able to safely operate the DJI Inspire 1 (Model T600) UASs in a manner consistent w**  **ith this exemption, including evasive and emergency maneuvers and maintaining appropriate distanc**  **es from people, vessels, vehicles and structures.**  **Christian Nowosiadly seeks relief from Section 91.7(a), entitled** Civil aircraft airworthiness **, because the DJI Inspire 1 (Model T600) UASs do not require an air**  **worthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Ch**  **ristian Nowosiadly submits that he will ensure that the DJI Inspire 1 (Model T600) UASs are in an airworthy c**  **ondition, prior to every flight, by determining that the UASs are in compliance with the operating documents (i.e**  **., Monthly Maintenance Log, and DJI Inspire 1 (Model T600) Instruction M**  **anual), and that the aircraft are in a condition for safe flight.** **Christian Nowosiadly also seeks an exemption from the requirements of Section 91 .121,** 

**entitled** Altimeter Settings

**, as the DJI Inspire 1 (Model T600) UAs will not have a typical barometric altimeter onboard. However, altitude information of the DJI Inspire 1 (M**  **odel T600) UAs will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications**  **telemetry data link, which own links from the UA to the GCS for active monitoring of the f light**  **path. This altitude information, combined with Christian Nowosiadly’s operation of th e DJI Inspire**  **1 (Model T600) UASs within visual line of sight, at or below 400 feet AGL, will ensure a level of**  **safety equivalent to Section 91.121. Additionally, Christian Nowosiadly seeks an exemption from the requirements of Sec**  **tion 91.151(b), entitled**  Fuel requirements for flight in VFR conditions **. Christian Nowosiadly submits that safety will not be affected by operation of the DJI Inspire 1 (Model T600)**  **UAs during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with e**  **nough battery power to fly for a total duration of approximately 13.5 minutes to the firs**  **t point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5**  **minutes.**

**In accordance with 14 C.F.R. § 11.81, Christian Nowosiadly provides the fo llowing**  **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: Christian Nowosiadly**  **45 Leyden St Boston, MA 02128**  **Email: christian@nowcitytours.com**

**B. The Specific Sections Of 14 C.F.R. From Which Christian Nowosiadly**  **Seeks Exemption.**

**1. Christian Nowosiadly Seeks Exemption From The Requirements Of Sect**  **ion 61.113(a) And (b).**  **Section 61.113, entitled Private pilot privileges and limitations:** Pilot in command **, subsections (a) and (b)**  **prescribe the following, in relevant part:**

**(a) No person who holds a private pilot certificate may act as a pilot in command (PIC)**  **of an aircraft that is carrying 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 aircraft in connection with any business or employment if—** 

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

**2. Christian Nowosiadly Seeks Exemption From The Requirements Of Sect**  **ion 91.7(a). Section 91.7, entitled**  Civil aircraft airworthiness **, subsection (a), states the following: (a)**  **No person may operate a civil aircraft unless it is in an airw orthy condition.** 

**3. Christian Nowosiadly Seeks Exemption From The Requirements Of Sect**  **ion 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 le vel**  **of that aircraft, as the case may be, by reference to an altimeter that is set, whe n**  **operating— (1)**  **Below 18,000 feet MSL, to-- (i)**  **The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft;**  **(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of**  **this section, the current reported altimeter setting of an appropriate available station; or**  **(iii) In the case of an aircraft not equipped with a radio, the elevation of**  **the departure airport or an appropriate altimeter setting available before departure.** 

**4. Christian Nowosiadly Seeks Exemption From The Requirements Of Sect**  **ion 91.151(b). Section 91.151, entitled**  Fuel requirements for flight in VFR conditions **, subsection (b), states the following:** (b) No person may begin a flight in a rotorcraft under VFR conditio ns 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. Christian Nowosiadly Seeks Exemption From The Requirement Of Sect**  **ion 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 sec tion, have**  **discrepancies repaired as prescribed in part 43 of this chapter[.]**

**6. Christian Nowosiadly Seeks Exemption From The Requirements Of Sect**  **ion 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 operate any aircraft that has undergone maintenance, preve ntive**  **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. Christian Nowosiadly Seeks Exemption From The Requirements Of Sect**  **ions 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 chap ter and has been approved**  **for return to service by a person authorized by § 43.7 of this chapter; or**  **(2) An inspection for the issuance of an airworthiness certificate in accordanc**  **e with part 21 of this chapter.** 

**8. Christian Nowosiadly Seeks Exemption From The Requirements Of Sect**  **ions 91.417(a) And 91.417(b).**  **Section 91.417, entitled** Maintenance records **, subsections (a) and (b), state the following: (a)**  **Except for work performed in accordance with §§ 91.411 and 91.413, ea ch registered**  **owner or operator shall keep the following records for the periods specified in paragraph**  **(b) of this section:**  **(1) Records of the maintenance, preventive maintenance, and alterati**  **on and records of the 100-hour, annual, progressive, and other required or approved inspe**  **ctions, as appropriate, for each aircraft (including the airframe) and each engine, pr**  **opeller, rotor, and appliance of an aircraft. The records must include—** **(i) A description (or reference to data acceptable to the Administrator) of the**  **work performed; and (ii)**  **The date of completion of the work performed; and (iii)**  **The signature, and certificate number of the person approving the aircraf t**  **for return to service. (2)**  **Records containing the following information: (i)**  **The total time in service of the airframe, each engine, each p ropeller, 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 o**  **f this chapter shall be retained until the defects are repaired and the aircraft is appro**  **ved for return to service.** 

**C. The Extent Of Relief Christian Nowosiadly Seeks And The Reason Christ**  **ian Nowosiadly Seeks The Relief.** 

**1. Extent Of Relief Christian Nowosiadly Seeks And The Reason Christian N**  **owosiadly 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

command **, is requested to the extent necessary to allow a PIC not holding any pilot certificate, or a**  **current and valid airman medical certificate, but who has met certain flight-hour an d currency** **requirements, to conduct the proposed UAS flight operations f or compensation or hire.**  **This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a**  **private pilot may, for compensation or hire, act as PIC of an aircraft in conne ction 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, Christian Nowosiadly submits that an equivalent level of safety will**  **be maintained because no PIC will be allowed to operate the DJI Inspire 1 (Model T 600) UAS**  **unless that PIC has met certain flight-hour and currency requirements, demons trating that the PIC**  **is able to safely operate the DJI Inspire 1 (Model T600) in a manner consiste nt with the operations**  **specifications as described in this exemption, including evasive and emergency maneuvers, as well**  **as maintaining appropriate distances from people, vessels, vehicle s and structures.** 

**Further, Christian Nowosiadly submits that all flights of the DJI Inspire 1 (Model T6 00) UASs,**  **conducted by the PIC pursuant to the grant of this Petition: (1)**  **will be incidental to Christian Nowosiadly's business; and (2)**  **will not carry passengers or property for compensation or hire.**

**2. Extent Of Relief Christian Nowosiadly Seeks And The Reason Christian N**  **owosiadly 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 Christian Nowosiadly to determine that the DJI Inspire 1 (Model T600) UASs a**  **re in airworthy condition prior to every flight by ensuring that the UAS is in compliance w**  **ith the operating documents (i.e., the Christian Nowosiadly Aerial Operations Manual, Mo**  **nthly Maintenance Log, and DJI Inspire 1 (Model T600) Instruction Manual). C**  **hristian Nowosiadly seeks the requested relief because the DJI Inspire 1 (Model T600) UASs**  **do not require an airworthiness certificate in accordance with 14** 

**C.F.R. Part 21, Subpart H. Therefore, Christian Nowosiadly will ensure that the DJI Inspire 1**  **(Model T600) UASs are in airworthy condition based upon its compliance with the ope rating**  **documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 (Model T600) Instruction Manual)**  **prior to every flight, and further, determine that the aircraft are in condition for s afe flight, as stated**  **in the conditions and limitations below. Extent Of Relief Christian Nowosiadly, Seeks From Section 91.121.**  **Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight op erations of**  **the DJI Inspire 1 (Model T600)UASs, which utilize a barometric pressure sensor, GPS equipment,**  **and a radio communications telemetry data link to downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any altitude informa**  **tion concerning UAS operations be reported to air traffic control (ATC) in feet abo**  **ve ground level (AGL), Christian Nowosiadly seeks the requested relief because the DJI Insp**  **ire 1 (Model T600) UA’s altimeter may be set on the ground to zero feet AGL, rather than the local bar**  **ometric pressure or field altitude, before each flight.**  **Considering the limited altitude of the proposed operations, relief from 14 CFR 91.12 1 is sought to**  **the extent necessary to comply with the applicable conditions and limitations stated belo w. As more**  **fully set forth herein, an equivalent level of safety will be maintained since the DJI Inspire 1 (Model**  **T600) UAs are equipped with a barometric pressure sensor and GPS equipment, which**  **automatically ensures that a ground level pressure setting will be established prio r to each flight, and**  **provides the PIC with altitude information of the UA on the heads-up display of the GCS.**

**4. Extent Of Relief Christian Nowosiadly Seeks And The Reason Christian N**  **owosiadly Seeks Relief From Section 91.151(b).**  **Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is re quested**  **to the extent required to allow flights of the battery powered DJI Inspire 1 (Mode l T600) UAs**  **during daylight hours in visual meteorological conditions (VMC), un der visual flight rules (VFR), for** **a total duration of 13.5 minutes to the first point of intended la nding and, assuming normal cruising** 

**speed, to fly after that for at least 4.5 minutes. Christian Nowosiadly seeks the re quested relief**  **because without an exemption from Section 91.151(b), the flight time duration of the battery**  **powered DJI Inspire 1 (Model T600) UAs will severely constrain the prac ticality of any aerial video**  **or still photo flight operations that Christian Nowosiadly proposes to conduct purs uant to this**  **Petition. Significantly, as set forth below, the technical specifications of the DJI Inspire 1 (Model**  **T600) UASs, the DJI Inspire 1 (Model T600) operating documents, and Chris tian Nowosiadly’s**  **proposed operating limitations, ensure that Christian Nowosiadly will safely opera te the battery**  **powered DJI Inspire 1 (Model T600) UAs during daylight hours in visual meteor ological conditions**  **(VMC), under visual flight rules (VFR), with enough battery power to fly for a total dur ation of**  **13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after** 

**that for at least 4.5 minutes.**

**5. Extent Of Relief Christian Nowosiadly Seeks And The Reason Christian N**  **owosiadly Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(**  **1) & (a)(2), And 91.417(a) & (b).**  **Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b ) only apply to**  **aircraft with an airworthiness certificate, Christian Nowosiadly requests relief from these Sections**  **because the DJI Inspire 1 (Model T600) UASs do not require airworthiness certificates. As set forth**  **more fully below, the DJI Inspire 1 (Model T600) UASs meet the conditions of FMR A Section 333**  **for operation without an airworthiness certificate. Accordingly, Christian No wosiadly will use**  **trained technicians to perform maintenance, alterations, or preventive main tenance on the UASs**  **using the methods, techniques, and practices prescribed in the UAS operating do cuments (i.e., the**  **Christian Nowosiadly Aerial Operations Manual, Monthly Maintenance Log, an d DJI Inspire 1**  **(Model T600) Professional Instruction Manual). Furthermore, Christian Nowosia dly will document** **and maintain all maintenance records for the DJI Inspire 1 (Model T600) UASs.**

**D. The Reasons Why Granting Christian Nowosiadly Request Would Be In Th**  **e Public Interest; That Is, How It Would Benefit The Public As A Whole.**  **Granting the present Petition will further the public interest by allowing Christian Now osiadly to**  **safely, efficiently, and economically perform aerial video and photography of construction sites, real**  **estate, and landscape over certain areas of the United States. Additionally, use of the DJI Inspire 1 (Model T600) UASs will decrease conges**  **tion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the be**  **nefits of Christian Nowosiadly's proposed operation of the DJI Inspire 1 (Model T600**  **) UASs will be realized without implicating any privacy issues.** 

**1. The Public Will Benefit From Decreased Congestion Of The NAS.**  **The DJI Inspire 1 (Model T600) UAs are battery powered and serve as a safe, efficient, and**  **economical alternative to the manned aircraft traditionally utilized to obtain aerial image ry. By**  **reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption**  **allowing the use of a DJI Inspire 1 (Model T600) UAS would reduce the amount of manned aircraft**  **in the NAS, reduce noise and air pollution, as well as increase the safety of life a nd property in the**  **air and on the ground. Furthermore, by reducing the number of manned aircraft operating in the NAS, con**  **gestion around airports caused by arriving and departing aircraft will be reduced. The DJI**  **Inspire 1 (Model T600) UAs do not require an airport to takeoff or land. Likewise, a reduction of mann**  **ed aircraft conducting aerial video and photography missions would result in fewer aircraf**  **t that must be handled by air traffic control during the ground, takeoff, departure, arrival,**  **and landing phases of flight operations.** **2. The Public Will Benefit From The Safety And Efficiency Of The D**  **JI Inspire 1 (Model T600) UASs.**  **Conducting aerial acquisitions with the DJI Inspire 1 (Model T600) UASs, inst ead of manned**  **aircraft, will greatly benefit the public by drastically reducing the levels of a ir and noise pollution**  **generated during traditional aerial video and still photography flight operations. By using battery**  **power and electric motors, the DJI Inspire 1 (Model T600) UASs produce no air pollution, and is**  **the most viable environmentally conscious alternative to the cabin class, six cy linder internal**  **combustion engine aircraft that are typically utilized for aerial video and photogr aphy, while burning**  **approximately 20-30 gallons per hour of leaded aviation fuel. The DJI Ins pire 1 (Model T600) UAs,**  **while reducing the carbon footprint of aerial acquisitions, also eliminates noise p ollution, as the UAs**  **are propelled by battery powered electric motors, rather than an internal co mbustion engine. By**  **using the DJI Inspire 1 (Model T600) UASs to perform aerial acquisitions, th e substantial risk to life**  **and property in the air and on the ground, which is usually associated with traditiona l manned**  **aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack**  **of flight crew members located onboard the aircraft, the DJI Inspire 1 (Mode l T600) UAs has less**  **physical potential for collateral damage to life and property on the ground, and in th e air, compared**  **to the manned aircraft that typically conduct similar operations (weighing approxima tely 6,000**  **pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a f uel capacity of 180**  **gallons).**

**3. Performing Aerial Video and Photography Operations With The DJI Inspi**  **re 1 (Model T600) UASs Will Benefit The Economy.**  **In addition to being safe and efficient, the DJI Inspire 1 (Model T600) UASs ar e also an**  **economical alternative to using manned aircraft to conduct similar aerial operatio ns. As such,**  **operation of the DJI Inspire 1 (Model T600) UASs will allow United States based co mpanies, like** **Christian Nowosiadly, to remain competitive and contribute to growth of the U.S. economy.** 

**Specifically, with the rising cost of aviation fuel and the Environmental Pro tection 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 the battery**  **powered DJI Inspire 1 (Model T600) UASs is one such technology that not on ly allows companies**  **greater operational flexibility compared to manned aircraft, but provides such flexibility without the**  **high operational cost of a traditional manned aircraft. By operating the DJI Inspire 1 (Model T600) UASs, companies such as Chr**  **istian Nowosiadly, can remain competitive and profitable, and therefore, provide greater job stability to**  **employees and contractors, which will ultimately contribute to growth of the U.S.**  **economy. Improved financial performance of U.S. companies, through commercial use of the DJI Ins**  **pire 1 (Model T600) UASs, provides a stable workforce that increases consumer spending; improves lo**  **cal, 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,**  **Christian Nowosiadly's proposed operation of the DJI Inspire 1 (Model T600 ) UASs will not**  **implicate any privacy issues. Specifically, the DJI Inspire 1 (Model T600) U ASs will be operated only**  **in compliance with operating documents (i.e., the Christian Nowosiadly Aerial Oper ations Manual,**  **Monthly Maintenance Log, and DJI Inspire 1 (Model T600) Instruction M anual) which requires**  **property owner involvement as well as local law enforcement notification, and in accordance with**  **the Federal Aviation Regulations, including the minimum altitude requirements of 14 C. F.R. §** 

**91.119. E.**  **The Reasons Why Granting The Exemption Would Not Adversely A ffect Safety, Or How** 

**The Exemption Would Provide A Level Of Safety At Least Equ al To That Provided By The**  **Rule From Which Christian Nowosiadly Seeks Exemption.**

**1. Reasons Why The**  **DJI Inspire 1 (Model T600) UAs Meet The Conditions Of The**  **FAA Modernization and Reform Act of 2012 (FMRA) Section 333. In consideration of the size, weight, speed, and limited operating area associat**  **ed with the unmanned aircraft and its operation, Christian Nowosiadly operation of the DJI Inspire**  **1 (Model T600) UASs meet the conditions of FMRA Section 333, and will not require an airworthiness certif**  **icate 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 otherwis**  **e pose a threat to national security. Specifically, FMRA Section 333 states the following, in part:**  (a) In General.--Notwithstanding any other requirement of this subtitle, and not later than 1 80 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 completio n of the plan and rulemaking required by section 332 of this Act or the guidance required by sectio n 334 of this Act. (b) Assessment of Unmanned Aircraft Systems.--In making the determination under subsection (a), the Secretary shall determine, at a minimum— (1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operatio n within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security; and (2) whether a certificate of waiver, certificate of authorization, or airworthiness certif ication under section 44704 of title 49, United States Code, is required for the operation of unmanned aircra ft 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 shal l establish requirements for the safe operation of such aircraft systems in the national airspace system.

**In seeking this exemption, Christian Nowosiadly submits that the DJI Inspire 1 (Mo del T600) UASs** **can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by : (a) the** 

**characteristics of the DJI Inspire 1 (Model T600) UASs; (b) the pilot certificatio n requirement; and**  **(c) the specific operating limitations.**

**a. The Specifications Of The DJI Inspire 1 (Model T600) UASs Dem**  **onstrate Its Safe**

**Characteristics. The DJI Inspire 1 (Model T600) UASs do not create a hazard to users of the**  **NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed,**  **and operational capability.** 

**i. Technical Specifications Of The DJI Inspire 1 (Model T600) UA**  **Ss. The technical specifications of the DJI Inspire 1 (Model T600) UASs are se**  **t forth by the DJI Inspire 1 (Model T600) Specifications, attached hereto as Exhibit A.** 

**ii. The DJI Inspire 1 (Model T600) UASs Autonomous Flight And Navi**  **gation Modes Enable The UASs To Remain Within A Defined Operational Area.**  **The DJI Inspire 1 (Model T600) UASs may be operated in both manual and fully a utonomous flight**  **modes. A complete description of the flight and navigational modes of the DJI Insp ire 1 (Model**  **T600) UASs is provided in the DJI Inspire 1 (Model T600) User Manual, attach ed hereto as** 

**Exhibit B.**

**iii. The DJI Inspire 1 (Model T600) UASs Are Designed For Automatic**  **Return To Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation.**  **When the Control Link is lost, the DJI Inspire 1 (Model T600) UAs will remain s tationary, in flight,**  **for 3 seconds or more. If, after 3 seconds, the DJI Inspire 1 (Model T6 00) UAs do not reacquire**  **control link data from the GCS, the UAs will assume that the Control Link is lost and the UAs w ill**  **return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position** 

**and shutdown. A complete description of the Failsafe Functions of the DJI Inspire 1 (Model T6**  **00) UAS are set**

**forth in the DJI Inspire 1 (Model T600) User Manual, attached hereto as Exhibit B.** 

**iv. The DJI Inspire 1 (Model T600) GCS And Its Operation.**  **A complete description of the operation and specifications of the DJI Inspire 1 (Model T600) GCS**  **and flight control software is provided in the DJI Inspire 1 (Model T600) User Manual.**  **DJI Inspire 1 (Model T600) User Manual is attached hereto as Exhibit B.**

**b. Flight Operations Of DJI Inspire 1 (Model T600) UASs Are Limi**  **ted To The Line Of Sight Of A Pilot in Command With A Safety Observer.**  **Christian Nowosiadly will only utilize pilots who have at least 20 hours flight time to act as a pilot in**  **command (PIC) of the DJI Inspire 1 (Model T600) UASs. Additionally, a s afety observer will assist**  **all pilots during flight time.**

**c. Flights Of DJI Inspire 1 (Model T600) UASs Will Be Conducted P**  **ursuant To Specific Operating Limitations.**  **In seeking this exemption, Christian Nowosiadly proposes to commercially operate DJI Inspire 1**  **(Model T600) UASs for the special purpose of conducting aerial video and pho tography over**  **certain areas of United States, pursuant to the following specific operating limitatio ns:** 

**1. Operations authorized by this grant of exemption will be limited to the following**  **aircraft described in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight:**  DJI Inspire 1 (Model T600) **Unmanned 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 photography.**

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

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

**5. The UAs must be operated within visual line of sight (VLOS) of the PIC at all** **times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA-issued airman medica**  **l 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 designated before the flight and**  **cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the SO can perform the functions**  **prescribed in the operating documents.**

**8. The SO must not perform any other duties beyond assisting the PIC with seeing and**  **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 exemption must be accessible during UAS**  **operations and made available to the Administrator upon request. If a discrepanc y**  **exists between the conditions and limitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations**  **contained in the grant of exemption take precedence and must be followed. Other wise,**  **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 pres ent 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 a ffect**  **the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS-80)**  **may be contacted if questions arise regarding updates or revisions to the oper ating**  **documents.**

**10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for**  **safe flight. If the inspection reveals a condition that affects the safe opera tion of the**  **UAS, the aircraft is prohibited from operating until the necessary maintenance ha s been**  **performed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and**  **alterations must be properly documented in the aircraft records.**

**11. Any UAS that has undergone maintenance or alterations that affect the UAS**  **operation or flight characteristics, e.g. replacement of a flight critical component,**  **must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraft records.** 

**12. The pre-flight inspection must account for all potential discrepanci**  **es, e.g. inoperable components, items, or equipment, not already covered in the rele**  **vant sections of the operating documents.** 

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

**14. The operator must carry out its maintenance, inspections, and record keeping**  **requirements, in accordance with the operating documents. Maintenance, insp ection,**  **alterations, and status of replacement/overhaul component parts must be note d in the**  **aircraft records, including total time in service, description of work accomplished, and**  **the signature of the authorized person returning the UAS to service.**

**15. Each 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 corre**  **ctive action taken against discrepancies discovered between inspections.** 

**17. The PIC must have completed at least 25 hours of flight time.** 

**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 UAS in a man**  **ner consistent with how the UAS will be operated under the exemption, including evasive**  **and emergency maneuvers and maintaining appropriate distances from person s, vessels,**  **vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the**  **operator’s PICs are permitted under the terms of the exemption. However, training operation**  **s may only be conducted during dedicated training sessions. During training, proficienc**  **y, and experience-building flights, all persons not essential for flight operations ar**  **e considered nonparticipants, and the PIC must operate the UA with appropriate distance from**  **nonparticipants in accordance with 14 C.F.R. § 91.119.**

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

**20. The UA may not operate within 2 nautical miles of an airport reference point as**  **denoted on a current FAA-published aeronautical chart unless a letter of agreement wi**  **th 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 th**  **e airport management must be made available to the Administrator upon request.** 

**21. The UA may not be operated less than 400 feet below or less than 2,000 feet**  **horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 22.**  **If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recove**  **red in accordance with the operating documents.** **23. The PIC must abort the flight in the event of unpredicted obstacles or emergencie**  **s in accordance with the operating documents.** 

**24. The PIC is prohibited from beginning a flight unless (considering wind and forecas**  **t 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 any operations under the g**  **rant 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 th e**  **operation. All operations shall be conducted in accordance with airspace req uirements in**  **the ATO issued COA including class of airspace, altitude level and potential trans ponder**  **requirements.**

**26. All aircraft operated in accordance with the exemption must be identified by serial**  **number, registered in accordance with 14 C.F.R. part 47, and have identifica tion (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 op eration and**  **control of the UA 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 ava**  **ilable to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These**  **documents must be made available to the Administrator or any law enforcement official upon request.** 

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

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

**31. Flight operations must be conducted at least 500 feet from all nonparticipating**  **persons (persons other than the PIC, SO, operator trainees or essential p ersons),**  **vessels, vehicles, and structures unless:**

**a. Barriers or structures are present that sufficiently protect nonparticip**  **ating 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 a re**  **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**  **permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue**  **hazard, and; c.**  **Operations nearer to the PIC, SO, operator trainees or essential persons do**  **not present an undue hazard to those persons per § 91.119(a).**

**32. All operations shall be conducted over private or controlled-access proper**  **ty with permission from the land owner/controller or authorized repres**  **entative. Permission from land owner/controller or authorized representative will be obtained for ea**  **ch flight to be conducted.** 

**33. Any incident, accident, or flight operation that transgresses the lateral or ver**  **tical boundaries 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. Acciden ts**  **must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site:**  **www.ntsb.gov**

**.**

**2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) A**  **nd (b) Would Not Adversely Affect Safety.**  **Christian Nowosiadly submits that the equivalent level of safety established by Section 6 1.113(a) and**  **(b) will be maintained because no PIC will be allowed to operate the DJI Inspire 1 (Mo del T600)**  **UASs unless that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the DJI Inspire 1 (Mode**  **l T600) UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and ma**  **intaining appropriate distances from people, vessels, vehicles and structures. Co**  **nsidering Christian Nowosiadly's proposed area of operations, and the operating limitations set for**  **th-above; the parallel nature of aeronautical knowledge requirements to those of commercial pilot re**  **quirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate**  **the DJI Inspire 1 (Model T600), Christian Nowosiadly submits that the additional manned airmanship experie**  **nce of a commercially certificated pilot would not correlate to the airmanship skills n**  **ecessary for Christian Nowosiadly's specific proposed flight operations.**  **The FAA has previously granted relief from Section 61.113(a) and (b) specific to U AS, in**  **circumstances similar, in all material respects, to those presented herein (e.g. E xemption Nos. 11062,**  **11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 1 1112, 11136, 11138, 11150, 11153,** **11156, 11158, 11159, 11160, 11161).**

**Christian Nowosiadly will not allow any PIC to operate the DJI Inspire 1 (Model T6 00) UAS unless**  **that PIC has demonstrated, by meeting minimum flight-hour requirements or the DJI I nspire 1**  **(Model T600) UAS training and currency requirements, that the PIC is able to safe ly operate the DJI**  **Inspire 1 (Model T600) UAS in a manner consistent with this exemption, including e vasive and**  **emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and** 

**structures. Specifically, the PIC must have accumulated and logged, in a manner consistent with 1**  **4 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 u**  **nder the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs a**  **nd landings in the preceding 90 days (for currency purposes).**  **As in Exemption Nos. 11062, 11138, and 11153, prior documented flight exper ience that was**  **obtained in compliance with applicable regulations will ensure an equivalent lev el of safety during**  **Christian Nowosiadly's proposed operations. The Administrator has held that prio r documented**  **flight experience that was obtained in compliance with applicable regulations w ould ensure safe**  **operations, stating as follows: In Exemption No. 11062, the FAA required that prior to conducting operations for**  **the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged,**  **in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcra**  **ft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor UAS. Prior to operations unde**  **r Exemption No. 11062, the PIC must also have accumulated and logged a minimum of 5 hour**  **s as a**

**UAS pilot operating the same make and model of UAS to be used for operations under the**  **exemption. For clarification, the FAA considers these minimum hour requirements to b e inclusive**  **rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of mu lti**  **rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time . In**  **addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the f**  **light-hour requirements in Exemption No. 11062 are appropriate to practice**  **and build proficiency in the skills necessary to safely conduct the petitioner’s proposed operations. Th**  **e FAA also finds that prior documented flight experience that was obtained in compliance with applicable regu**  **lations would satisfy this requirement. Training, proficiency, and experience-building f**  **lights can also be conducted under the grant of exemption to accomplish the required flight time. During training, pr**  **oficiency, and experience-building flights the PIC is required to operate the UA with app**  **ropriate distances in accordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15.**  **Accordingly, Christian Nowosiadly will ensure safe operations by not allowing any PIC to operate**  **the DJI Inspire 1 (Model T600) UAS unless that PIC has demonstrated, by meeting minimum**  **flight-hour and currency requirements, that the PIC is able to safely operate the DJI Inspire 1**  **(Model T600) UAS in a manner consistent with the exemption, including evasive and emer gency**  **maneuvers and maintaining appropriate distances from people, vesse ls, vehicles and structures.** 

**3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Woul**  **d Not Adversely Affect Safety.**  **The equivalent level of safety established by Section 91.7(a) will be maintained be cause prior to**  **every flight, Christian Nowosiadly will ensure that the DJI Inspire 1 (Model T60 0) UAS is in an**  **airworthy condition based upon the UAS’s compliance with its operatin g documents and as** **stated in the conditions and limitations herein. Additionally, the FAA has previously granted**  **relief from Section 91.7(a) specific to UAS, in circumstances similar, in all material res pects, to**  **those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 110 65, 11066, 11067, 11080,**  **11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 1**  **1160, 11161).**

**4. Reasons Why An Exemption From The Requirements Of Section 91.121 Woul**  **d Not Adversely Affect Safety.**  **The equivalent level of safety established by Section 91.121 will be maintained b ecause the altitude**  **information of the DJI Inspire 1 (Model T600) UAs will be provided to the PIC via GPS equipment and a radio communications telemetry data link, which downlinks from the U**  **A to the GCS for active monitoring of the flight path and altitude. This altitude information, combin**  **ed with Christian Nowosiadly's operation of the DJI Inspire 1 (Model T600) UAs with**  **in visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Sectio**  **n 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 established by**  **the UASs at ground level. The FAA has previously granted relief from Section 91.121 specific to UAS, in cir**  **cumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 110**  **62, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 1**  **1150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).** 

**5. Reasons Why An Exemption From The Requirements Of Section 91.151(b)**  **Would Not Adversely Affect Safety.**  **A grant of this exemption would ensure an equivalent level of safety established b y 14 C.F.R.**  **Section 91.151(b) as a result of (1) the technical specifications of the DJI Insp ire 1 (Model T600)**  **UASs; (2) the limitations on the proposed flight operations; and (3 ) the location of the proposed**  **flight operations. Accordingly, Christian Nowosiadly will ensure tha t it will safely operate the battery** **powered DJI Inspire 1 (Model T600) UAs during daylight hours in VFR condition s, with enough** 

**battery power to fly for a total duration of 13.5 minutes to the first point of intended la nding and,**  **assuming normal cruising speed, to fly after that for at least 4.5 minutes. Here, as in Exemption No. 11109, the technical specifications of the DJI In**  **spire 1 (Model T600) UASs; the limitations on the proposed flight operations; and the location of the propo**  **sed operations, will ensure an equivalent level of safety estab**  **lished by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Inspire 1 (Model T600) UASs**  **provide audible and visual warnings to the PIC at the GCS when the UAs experiences low battery voltag**  **e, the first warning occurring at approximately 33% remaining battery power, and again**  **at approximately 10% remaining battery power. At the critically low battery level, the DJI Inspire 1**  **(Model T600) UASs will descend and land automatically.**  **Significantly, previous exemptions granted by the FAA concerning Section 91.1 51 establish that**  **safety is not adversely affected when the technical charac teristics and operating limitations of the**  **UAS are considered. Relief has been granted for manned aircraft to operate at less than the**  **minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, a nd 10650.**  **Moreover, the FAA has previously granted relief from Section 91.151 specif ic to UAS, in**  **circumstances similar, in all material respects, to those presented herein (e.g. Ex emption Nos. 8811,**  **10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 1 1067, 11080, 11109, 11110, 11136,**  **11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).** 

**6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a)**  **, 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Aff**  **ect Safety. In seeking this exemption, Christian Nowosiadly submits that the equivalent level of sa**  **fety with regard to the regulatory maintenance and alteration requirements establishe**  **d 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 Christian Nowosiadly will use trained technicians to perform maintenance, alterations, or**  **preventive maintenance on the UASs using the methods, techniques, and practices prescrib**  **ed in the operating documents (i.e., the Christian Nowosiadly Aerial Operations Manual, Mo**  **nthly Maintenance Log, and DJI Inspire 1 (Model T600) Instruction Manual). Fu**  **rthermore, Christian Nowosiadly will document and maintain all maintenance records for the DJI Inspire 1**  **(Model T600) UASs.**  **Since the DJI Inspire 1 (Model T600) UASs will be inspected as prescribed by the operating**  **documents, Christian Nowosiadly will maintain the equivalent level of safety establis hed by**  **Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI Insp ire 1 (Model T600) User**  **Manual is attached hereto as Exhibit B; a copy of the DJI Inspire 1 (Model T60 0) UAS** 

**Maintenance LOG is attached hereto as Exhibit C. Likewise, the exemption sought will not adversely affect safety because Ch**  **ristian Nowosiadly will use trained technicians to perform maintenance, alterations or preventive ma**  **intenance on the UAS using the methods, techniques, and practices prescribed by the operating doc**  **uments. Furthermore, the exemption sought would maintain an equivalent level of safety e**  **stablished by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the**  **DJI Inspire 1 (Model T600) UASs will be performed by trained technicians. Maintenance will be docu**  **mented and maintained utilizing the monthly maintenance log.**  **Significantly, previous exemptions granted by the FAA concerning Sections 91.4 05(a), 91.407(a)(1),**  **91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely aff ected when the**  **technical characteristics and operating limitations of the UAS are considered. In consideration of Christian Nowosiadly's proposed operating limitations, the op**  **erating documents, and the technical aspects of the DJI Inspire 1 (Model T600) UASs,**  **Christian Nowosiadly submits that safety will not be adversely affected by granting**  **exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) a**  **nd (b). The FAA has previously granted relief specific to UAS in circumstances similar, in all material res**  **pects, to those**

**presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11 066, 11067, 11080, 11109,**  **11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).** 

**7. The FAA May Prescribe Any Other Conditions For Safe Operation.** 

**In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14**  **C.F.R. § 21.16 entitled Special Conditions, Christian Nowosiadly requests that the FA A prescribe**  **special conditions for the intended operation of the DJI Inspire 1 (Model T600 ) UASs, 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 §§ 6 1.113(a) & (b), 91.7**  **(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 9 1.417(a) & (b). Such special**  **conditions will permit safe operation of the UAs for the limited purpose of conducting a erial video**  **and photography over certain areas of the United States for compensation or hire. FMRA Section**  **333 sets forth the requirements for considering whether a UAS will create a hazard to users of the**  **NAS or the public, or otherwise pose a threat to national security; and further, provides the**  **authority for such UAS to operate without airworthiness certification in accor dance with any**  **requirements that must be established for the safe operation of the UAS in the NAS. Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.**  **R. § 21.16, for operation of the DJI Inspire 1 (Model T600) UASs, since the airworthines**  **s regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the nove**  **l or unusual design features of the aircraft. Section 21.16, entitled Special Condition**  **s, states the following: If the FAA finds that the airworthiness regulations of this subchapter do not c**  **ontain 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 p**  **rescribes special conditions and amendments thereto for the product.**  **The special conditions are issued in accordance with Part 11 of th is chapter and contain such safety standards for**  **the aircraft, aircraft engine or propeller as the FAA finds necessary to es tablish a level of 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 Christian Nowosiadly’s intended operation of the DJI Inspire**  **1 (Model T600) UASs, 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 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 Christian Nowosiadly Seeks Exemption:**  Christian Nowosiadly 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 Christian Nowosiad ly Seeks:**  This exemption will permit Christian Nowosiadly to commercially operate an Unmanned A ircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United St ates.

**G. Any Additional Information, Views, Or Arguments Available T**  **o Support Christian Nowosiadly's Request.**  **This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Sectio n 333, which**  **directs the Secretary of Transportation to determine if certain UAS may operate saf ely in the NAS. As such,**  **Christian Nowosiadly's request for exemption may be granted pursuant to the auth ority 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 c**  **reate a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and furthe**  **r, provides the authority for such UAS to operate without airworthiness certification.**  **As discussed in detail above, Christian Nowosiadly will operate the DJI Inspire 1 (Model T600) UASs 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, Christian Nowosiadly 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 operatio**  **n of the DJI Inspire 1 (Model T600) UASs commercially, without an airworthiness certificate, for the limite**  **d purpose of conducting aerial video and photography over certain areas of the United States. By gran**  **ting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and R**  **eform Act of 2012, while also advancing the interests of the public, by allowing Christian Nowosi**  **adly to safely, efficiently, and economically operate the DJI Inspire 1 (Model T600) UASs commercially with**  **in the NAS.**

**WHEREFORE , in accordance with the Federal Aviation Regulations and the FAA Modernization and**  **Reform Act of 2012, Section 333, Christian Nowosiadly respectfully requests that the A**  **dministrator 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 Christian Nowosiadly to operate the DJI Inspire 1 (Model T600) UASs commer cially for the purpose of**  **conducting aerial video and photography over certain areas of the United States.** 

**Dated: September 22** nd **, 2015 Respectfully submitted, Christian Nowosiadly**  **45 Leyden St Boston, MA 02128**  **Email: christian@nowcitytours.com** **Appendices:**

**A – DJI Inspire 1 (Model T600) Specifications Data Sheet B – DJI Inspire 1 (Model T600) Manufacturer’s User Manual Link**  **C – Monthly Maintenance Log**

**APPENDIX – A DJI Inspire 1 (Model T600) TECHNICAL SPECIFICATIONS**  **Christian Nowosiadly only utilizes safe and reliable UASs. DJI is an industry leade r in small UAS**  **production. DJI UASs are loaded with ground breaking software enabling the u ser to set parameters**  **which will not allow flight into controlled airspace. Parameters can also be set to limit f light to no**  **higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJI software provides real-time altitude and location information**  **to the PIC via the linked monitor (smart phone/tablet devices)** 

**1.1.1** DJI Inspire 1 (Model T600) **1.1.2 Aircraft**  **1.1.2.1 Supported Battery – DJI 4500mAH LiPo Battery**  **1.1.2.2 Weight (Battery & Propellers Included) – 1.25 pounds**  **1.1.2.3 Hover Accuracy (Ready to Fly) – Vertical: 0.5m; Horizontal: 2..5m**  **1.1.2.4 Max Flight time - Approximately 18 minutes**  **1.1.2.5 Max Tilt Angel - 35**  0 **1.1.2.6 Max Ascent Speed – 5m/s**  **1.1.2.7 Max Descent Speed – 4m/s**  **1.1.2.8 Max Flight Speed – 22m/s (NOT RECOMMENDED)**  **1.1.2.9 Operating Temperature - 10oC - 40oC**  **1.1.2.10 Max Flight Altitude - 4500m**  **1.1.2.11 GPS Mode - GPS/GLONASS**  **1.1.2 Gimbal**  1.1.2.1 **Controllable Range – Pitch: -90** 0 **+30** 0 **1.1.3 Camera**  1.1.3.1 **Sensor - Sony EXMOR 1/2.3"** 1.1.3.2 **Lens - FOV 94o 20mm (35mm format equivalent) f/2.8** 1.1.3.3 **Effective Pixels – 12.4M** 1.1.3.4 **Resolution – 4384x3288 4.1.3.5**  **HD Video Recording – 4K, 1080p & 720p 4.1.3.6**  **Image Max Size - 4000 x 3000 1.1.4**  **Remote Controller 1.1.4.1**  **Operating Frequency – 2.400GHz – 2.483GHz 1.1.4.2**  **Communication Distance (unobstructed)**

– **2km 1.1.4.3**  **Battery - 5700 mAh LiPo 2s 1.1.4.4**  **Transmitter Power – FCC: 20dbm CE: 16 dbm 1.1.4.5**  **Working Voltage – 1.2 A @7.4 V APPENDIX – B** 

**DJI Inspire 1 (Model T600) Manufacturer’s User Manual is too large to su bmit, however a link to**  **this information is: http://download.dji**  **innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.4_en.pdf APPENDIX – C** 

**Maintenance Log: Date:** 

**UAS # Date Issue** 

**Discovered Date Issue** 

**Addressed Issue Description**  **Peron Competed**