March 10, 2016

Attn:

U. S. Department of Transportation Docket Operations

West Building Ground Floor, Room w12­140

1200 New Jersey Ave, SE Washington, DC 20590

RE: MEDIA FUSION, INC.

REQUEST AN EXEMPTION FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL

REGULATIONS

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND

91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF DJI Inspire UNMANNED AIRCRAFT

SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112­95)

Richard Williams

President

Media Fusion, Inc

4951 Century Street NW

Huntsville, AL 35816

richard@fusiononline.com

256­532­3874

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TABLE OF CONTENTS

GLOSSARY OF ABBREVIATIONS................................................................................... 3

SUMMARY........................................................................................................................... 4

INTRODUCTION AND INTERESTS OF PETITIONER.................................................... 4

BACKGROUND.................................................................................................................... 4

BASIS FOR PETITION......................................................................................................... 5

NAME AND ADDRESS OF PETITIONER......................................................................... 6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH MEDIA FUSION, INC. SEEKS

EXEMPTION............................................................................................................ 6

THE EXTENT OF RELIEF MEDIA FUSION, INC. SEEKS AND THE REASON MEDIA FUSION, INC.

SEEKS THE RELIEF.............................................................. 8

THE REASONS WHY GRANTING MEDIA FUSION, INC.’S REQUEST WOULD BE IN THE PUBLIC

INTEREST ............................................................................................ 10

THE REASONS WHY GRANTING THE EXEMPTION TO MEDIA FUSION, INC. WOULD NOT

ADVERSELY AFFECT SAFETY.............................................................. 12

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER................... 21

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT MEDIA

FUSION, INC.’S REQUEST.................................................. 21

CONCLUSION..................................................................................................................... 22

APPENDICES......................................................................................... 22

2
GLOSSARY OF ABBREVIATIONS

AGL ­ Above Ground Level Area of Interest

AOI ­ Area of Interest

ATC ­ Air Traffic Control

ATO ­ Air Traffic Organization

AV ­ Aerial Vehicle

CFR ­ Code of Federal Regulations

COA ­ Certificate of Authorization

FAA ­ Federal Aviation Administration

FAR ­ Federal Aviation Regulation

GCS ­ Ground Control Station

GPS ­ Global Positioning System

LOL ­ Loss of Link

NAS ­ National Airspace System

NOTAM ­ Notice to Airman

PIC ­ Pilot In Command

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

SO ­ Safety Observer

SOP ­ Standard 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

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SUMMARY

Media Fusion, Inc., hereafter referred to as MEDIA FUSION seeks exemption from the requirements of 14

C.F.R §§ 61.113, 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) &

(b), to operate an Unmanned Aircraft System (DJI Inspire) pursuant to Section 333 of the FAA

Modernization and Reform Act of 2012 (FMRA). This exemption will permit MEDIA FUSION to operate an

Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography of

client products, client facilities, residential and commercial real estate, civil landscapes and events over

certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

MEDIA FUSION has for over twenty­five years provided their clients (which include private sector

businesses and non­profits, along with federal agencies such as NASA and Army UAS) with expertise and

knowledge in video and multimedia development, advertising, public relations and strategic communication

using advanced technologies and solutions. MEDIA FUSION has worked on hundreds of productions in all

types of locations with a perfect client and employee safety record. The objective of MEDIA FUSION and our

Unmanned Aircraft System (DJI Inspire 1) aerial operations is to provide a more affordable, high­quality

production system for a variety of governmental, commercial, public, and residential uses, specifically

targeting:

● Capabilities overviews

● Client facilities

● Economic development

● Civic landmarks

● Special event coverage

MEDIA FUSION staff has safely flown small RC electric quadcopters recreationally for approximately 1 year

without incident.

BACKGROUND

Unmanned Aircraft Systems: DJI Inspire 1

MEDIA FUSION seeks an exemption to operate DJI Inspire 1 system for compensation or hire within the

NAS. The DJI Inspire 1 is vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control

Station (GCS) utilizing electronic tablet or smart phone systems. The DJI Inspire 1 has a maximum gross

weight of approximately 6.5 pound with battery, while having dimensions of 17.2 x 17.8 x 11.9", a maximum

speed of approximately 22 m/s and a maximum flying height of 400'. The DJI Inspire 1 is equipped with four

main rotors, driven by Lithium­ion batteries.

The DJI Inspire 1 that will be operated by MEDIA FUSION 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.

4
BASIS FOR PETITION

Petitioner, MEDIA FUSION, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. §

11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain

Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate the DJI Inspire 1,

UAS in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§

61.113, 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, MEDIA FUSION operation of DJI Inspire 1 UAS meets the conditions of FMRA Section

333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart

H.

Accordingly, MEDIA FUSION 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.

MEDIA FUSION submits that the requested relief is proper since an equivalent level of safety will be

ensured. MEDIA FUSION will use experienced personnel or technicians to perform maintenance,

alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed

in the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual).

Furthermore, MEDIA FUSION will document and maintain all maintenance records for the DJI Inspire 1

UAS.

Relief from requirements of Section 61.113, entitled Private pilot privileges and limitations: Pilot in

command, is requested by MEDIA FUSION to the extent necessary to allow a Pilot in Command (PIC) who

has demonstrated the ability to safely operate the DJI Inspire 1 UAS in a manner consistent with this

exemption, including evasive and emergency maneuvers and maintaining appropriate distances from

people, vessels, vehicles and structures.

MEDIA FUSION seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the DJI

Inspire 1 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

As such, MEDIA FUSION submits that they will ensure that the DJI Inspire 1 UAS is in an airworthy

condition, prior to every flight, by determining that the UAS are in compliance with the operating documents

(i.e., Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual), and that the aircraft are in a condition

for safe flight.

MEDIA FUSION also seeks an exemption from the requirements of Section 91.121, entitled Altimeter

Settings, as the DJI Inspire 1 UAS will not have a typical barometric altimeter onboard. However, altitude

information of the DJI Inspire 1 UAS will be provided to the PIC via Global Positioning System (GPS)

equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active

monitoring of the flight path. This altitude information, combined with MEDIA FUSION’s operation of the DJI

Inspire 1 UAS within visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to

Section 91.121.

Additionally, MEDIA FUSION seeks an exemption from the requirements of Section 91.151(b), entitled Fuel

requirements for flight in VFR conditions. MEDIA FUSION submits that safety will not be affected by

operation of the DJI Inspire 1 UAS during daylight hours in visual meteorological conditions (VMC) under

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visual flight rules (VFR), with enough battery power to fly for a total duration of approximately 22 minutes.

Battery power indicators are also able to show exactly how much battery power is left, as well as how much

time is needed to return safely back to point of take off.

In accordance with 14 C.F.R. § 11.81, MEDIA FUSION 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:

Richard Williams

President

Media Fusion, Inc.

4951 Century Street

Huntsville, AL 35816

256­532­3874

richard@fusiononline.com

B. The Specific Sections Of 14 C.F.R. From Which MEDIA FUSION Seeks Exemption.

1. MEDIA FUSION Seeks Exemption From The Requirements Of Section 61.113.

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

(1) The flight is only incidental to a business; and

(2) The aircraft does not carry passengers or property for compensation or hire.

2. MEDIA FUSION 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 civil aircraft unless it is in an airworthy condition.

3. MEDIA FUSION Seeks Exemption From The Requirements Of Section 91.121.

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

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft,

as the case may be, by reference to an altimeter that is set, when operating­­

(1) Below 18,000 feet MSL, to­­

(i) The current reported altimeter setting of a station along the route and within 100 nautical

miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the

current reported altimeter setting 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.

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4. MEDIA FUSION Seeks Exemption From The Requirements Of Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states the following:

(b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and

forecast weather conditions) there is enough fuel to fly to the first point of intended landing and,

assuming normal cruising speed, to fly after that for at least 20 minutes.

5. MEDIA FUSION 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. MEDIA FUSION Seeks 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 operate any aircraft that has undergone maintenance, preventive maintenance,

rebuilding, or alteration unless­­

(1) It has been approved for return to service by a person authorized under § 43.7 of this chapter[.]

7. MEDIA FUSION Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And

91.409(a)(2).

Section 91.409, entitled Inspections, subsection (a), states the following:

(a) Except as provided in paragraph (c) 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 by a person authorized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this

chapter.

8. MEDIA FUSION Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b).

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

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

operator shall keep the following records for the periods specified in paragraph (b) of this section:

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

100­hour, annual, progressive, and other required or approved inspections, as appropriate, for each

aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The

records must include­­

(i) A description (or reference to data acceptable to the Administrator) of the work

performed; and

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

(iii) The signature, and certificate number of the person approving the aircraft for return to

service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor.

(ii) The current status of life­limited parts of each airframe, engine, propeller, rotor, and

appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are required to be

overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the last inspection

required by the inspection program under which the aircraft and its appliances are

maintained.

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

including, for each, the method of compliance, the AD or safety directive number and

revision date. If the AD or safety directive involves recurring action, the time and date when

the next action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to

the airframe and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is

repeated or superseded by other work or for 1 year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with

the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be

retained until the defects are repaired and the aircraft is approved for return to service.

C. The Extent Of Relief MEDIA FUSION Seeks And The Reason MEDIA FUSION Seeks The Relief.

1. Extent Of Relief MEDIA FUSION Seeks And The Reason MEDIA FUSION Seeks Relief From

Section 61.113.

Relief from Section 61.113 entitled Private pilot privileges and limitations: Pilot in command, is requested to

the extent necessary to allow a PIC who has demonstrated the ability to safely operate the DJI Inspire 1

UAS, including evasive and emergency maneuvers and maintaining appropriate distances from people,

vessels, vehicles and structures.

8
This relief is requested since the limitations set forth in Section 61.113 state that a private pilot may, for

compensation or hire, act as PIC of an aircraft in connection with any business or employment if: (1) The

flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or

property for compensation or hire.

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

because no PIC will be allowed to operate the DJI Inspire 1 UAS unless that PIC is able to safely operate

the DJI Inspire 1 UAS in a manner consistent with the operations specifications as described in this

exemption.

Further, MEDIA FUSION submits that all flights of the DJI Inspire 1 UAS, conducted by the PIC pursuant to

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

passengers or property for compensation or hire.

2. Extent Of Relief MEDIA FUSION Seeks And The Reason MEDIA FUSION 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

MEDIA FUSION to determine that the DJI Inspire 1 UAS is in airworthy condition prior to every flight by

ensuring that the UAS is in compliance with the operating documents (i.e., MEDIA FUSION Aerial

Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual).

MEDIA FUSION seeks the requested relief because the DJI Inspire 1 UAS do not require an airworthiness

certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, MEDIA FUSION will ensure that the

DJI Inspire 1 UAS is in airworthy condition based upon its compliance with the operating documents (i.e.,

Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual) prior to every flight, and further, determine

that the aircraft is in condition for safe flight, as stated in the conditions and limitations below.

3. Extent Of Relief MEDIA FUSION Seeks And The Reason MEDIA FUSION Seeks Relief From

Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the DJI

Inspire 1 UAS, which utilizes 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 information concerning UAS operations be reported to air

traffic control (ATC) in feet above ground level (AGL), MEDIA FUSION seeks the requested relief because

the DJI Inspire 1 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 fully set forth

herein, an equivalent level of safety will be maintained since the DJI Inspire 1 UAS is equipped with a

barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure

setting will be established prior to each flight, and provides the PIC with altitude information of the UA on the

heads­up display of the GCS.

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4. Extent Of Relief MEDIA FUSION Seeks And The Reason MEDIA FUSION 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 DJI Inspire 1 UAS during daylight hours in visual

meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 22 minutes. MEDIA

FUSION seeks the requested relief because without an exemption from Section 91.151(b), the flight time

duration of the battery powered DJI Inspire 1 UAS will severely constrain the practicality of any aerial video

or still photo flight operations that MEDIA FUSION proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the DJI Inspire 1 UAS, the DJI Inspire 1

operating documents, and MEDIA FUSION’s proposed operating limitations, ensure that MEDIA FUSION

will safely operate the battery powered DJI Inspire 1 UAS during daylight hours in visual meteorological

conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total duration of 22

minutes.

5. Extent Of Relief MEDIA FUSION Seeks And The Reason MEDIA FUSION 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, MEDIA FUSION requests relief from these Sections because the DJI Inspire 1

UAS does not require airworthiness certificates. As set forth more fully below, the DJI Inspire 1 UAS meets

the conditions of FMRA Section 333 for operation without an airworthiness certificate.

Accordingly, MEDIA FUSION will use trained technicians to perform maintenance, alterations, or preventive

maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS operating

documents (i.e., the MEDIA FUSION Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1

Instruction Manual). Furthermore, MEDIA FUSION will document and maintain all maintenance records for

the DJI Inspire 1 UAS.

D. The Reasons Why Granting MEDIA FUSION Request Would Be In The Public Interest; That Is,

How It Would Benefit The Public As A Whole.

Granting the present Petition will further the public interest by allowing MEDIA FUSION to safely, efficiently,

and economically perform aerial video and photography of client facilities, events and civic landscapes and

landmarks over certain areas of the United States in service of private sector businesses, non­profits, and

federal agencies such as NASA and Army UAS.

Additionally, use of the DJI Inspire 1 UAS will decrease congestion of the NAS, reduce pollution, and provide

significant benefits to the economy. Notably, the benefits of MEDIA FUSION’s proposed operation of the DJI

Inspire 1 UAS will be realized without implicating any privacy issues.

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

The DJI Inspire 1 UAS is battery powered and serve as a safe, efficient, and economical alternative to the

manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft

needed to perform aerial acquisitions, an exemption allowing the use of a DJI Inspire 1 UAS would reduce

the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of

life and property in the air and on the ground.

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

caused by arriving and departing aircraft will be reduced. The DJI Inspire 1 UAS does not require an airport

to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography

missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff,

departure, arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The DJI Inspire 1 UAS.

Conducting aerial acquisitions with the DJI Inspire 1 UAS, instead of manned aircraft, will greatly benefit the

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

and still photography flight operations. By using battery power and electric motors, the DJI Inspire 1 UAS

produces no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six

cylinder internal combustion engine aircraft that are typically utilized for aerial video and photography, while

burning approximately 20­30 gallons per hour of leaded aviation fuel. The DJI Inspire 1 UAS, while reducing

the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAS are propelled by

battery powered electric motors, rather than an internal combustion engine.

By using the DJI Inspire 1 UAS to perform aerial acquisitions, the substantial risk to life and property in the

air and on the ground, which is usually associated with traditional 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 UAS (weighing approximately 6.5 pounds at its maximum gross weight with

dimensions of 17.2 x 17.8 x 11.9 inches, and with no fuel on board), has less physical potential for collateral

damage to life and property on the ground, and in the air, compared to the manned aircraft that typically

conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet,

a length of 34 feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations With The DJI Inspire 1 UAS Will Benefit

The Economy.

In addition to being safe and efficient, the DJI Inspire 1 UAS is also an economical alternative to using

manned aircraft to conduct similar aerial operations. As such, operation of the DJI Inspire 1 UAS will allow

United States based companies, like MEDIA FUSION, 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 the battery powered DJI

Inspire 1 UAS is one such technology that not only allows companies greater operational flexibility compared

to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned

aircraft.

By operating the DJI Inspire 1 UAS, companies such as MEDIA FUSION, 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 Inspire 1 UAS, provides a stable workforce that increases consumer spending;

improves local, state, and federal tax revenues; and allows companies to invest in research and

development in order to remain competitive both in the United States and abroad.

4. There Are No Privacy Issues.

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

FUSION’s proposed operation of the DJI Inspire 1 UAS will not implicate any privacy issues. Specifically, the

DJI Inspire 1 UAS will be operated only in compliance with operating documents (i.e., MEDIA FUSION Aerial

Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual) which requires

property owner involvement as well as local law enforcement notification, and in accordance with the

Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The

Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From

Which MEDIA FUSION Seeks Exemption.

1. Reasons Why The DJI Inspire 1 UAS Meets The Conditions Of The FAA Modernization and

Reform Act of 2012 (FMRA) Section 333.

In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft

and its operation, MEDIA FUSION’s operation of the DJI Inspire 1 UAS meets the conditions of FMRA

Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart

H.

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

requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or

otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part:

(a) In General.­­Notwithstanding any other requirement of this subtitle, and not later than 180

days after the date of enactment of this Act, the Secretary of Transportation shall determine if

certain unmanned aircraft systems may operate safely in the national airspace system before

completion of the plan and rulemaking required by section 332 of this Act or the guidance

required by section 334 of this Act.

(b) Assessment of Unmanned 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 operation

within visual line of sight do not create a hazard to users of the national airspace system

or the public or pose a threat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or airworthiness

certification under section 44704 of title 49, United States Code, is required for the

operation of unmanned aircraft systems identified under paragraph (1).

(c) Requirements for Safe Operation.­­If the Secretary determines under this section that certain

unmanned aircraft systems may operate safely in the national airspace system, the Secretary

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

airspace system.

In seeking this exemption, MEDIA FUSION submits that the DJI Inspire 1 UAS can operate safely in the

NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI Inspire 1 UAS;

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

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a. The Specifications Of The DJI Inspire 1 UAS Demonstrate Its Safe Characteristics.

The DJI Inspire 1 UAS does not create a hazard to users of the NAS or the public, or otherwise

pose a threat to national security considering its size, weight, speed, and operational capability.

i. Technical Specifications Of The DJI Inspire 1 UAS.

The technical specifications of the DJI Inspire 1 UAS are set forth by the DJI Inspire 1 User

Manual, attached hereto as Appendix A.

ii. The DJI Inspire 1 UAS Global Positioning Modes Enable The UAS To Remain

Within A Defined Operational Area.

The DJI Inspire 1 UAS may be operated in both manual and global positioning flight modes.

A complete description of the flight and navigational modes of the DJI Inspire 1 UAS is

provided at pages 46 of the DJI Inspire 1 User Manual attached hereto as Appendix A.

iii. The DJI Inspire 1 UAS Are Designed For Automatic Return To Home Point Or

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

When the Control Link is lost, the DJI Inspire 1 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 the Failsafe Functions of the DJI Inspire 1 UAS are set forth at page 15 of the

DJI Inspire 1 User Manual, attached hereto as Appendix A.

iv. The DJI Inspire 1 GCS And Its Operation.

A complete description of the operation and specifications of the DJI Inspire 1 GCS and

flight control software is provided beginning on page 24 of the DJI Inspire 1 User Manual.

DJI Inspire 1 User Manual is attached hereto as Appendix A.

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

Pilot in Command With A Safety Observer.

MEDIA FUSION video production staff will be the only persons to act as a pilot in command (PIC) of

the DJI Inspire 1 UAS. Additionally, a safety observer will assist him at all times during flight time.

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

Limitations.

In seeking this exemption, MEDIA FUSION proposes to commercially operate DJI Inspire 1 UAS for

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

pursuant to the following specific operating limitations.

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

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

maximum gross weight: DJI Inspire 1 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.

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

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

(AGL), as indicated by the procedures specified in the operating documents unless a

special request is made and approved by ATC. All altitudes reported to ATC must be in feet

AGL.

5. The UAS must be operated within visual line of sight (VLOS) of the PIC at all times. This

requires the PIC to be able to use human vision unaided by any device other than

corrective lenses.

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 discrepancy exists

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

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

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

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

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

revisions and present updated and revised documents to the Administrator upon request.

The operator must also present updated and revised documents if it petitions for extension

or amendment to the grant of exemption. If the operator determines that any update or

revision would affect the basis upon which the FAA granted the exemption, then the

operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration

Office (AFS­80) may be contacted if questions arise regarding updates or revisions to the

operating documents.

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

safe flight. If the inspection reveals a condition that affects the safe operation of the UAS,

the aircraft is prohibited from operating until the necessary maintenance has been

performed and the UAS is found to be in a condition for safe flight. The Ground Control

Station must be included in the preflight inspection. All maintenance and alterations must

be properly documented in the aircraft records.

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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 pre­flight inspection must account for all potential discrepancies, e.g. inoperable

components, items, or equipment, not already covered in the relevant 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, inspection,

alterations, and status of replacement/overhaul component parts must be noted in the

aircraft records, including total time in service, description of work accomplished, and the

signature of the authorized person returning the UAS to service.

15. Each UAS operated under this exemption must comply with all manufacturer Safety

Bulletins.

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

taken against discrepancies discovered between inspections.

17. 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 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. Flights for the purposes of training the operator’s PICs are

permitted under the terms of the exemption. However, training operations may only be

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

experience­building flights, all persons not essential for flight operations are considered

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

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

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

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

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

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

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

on a current FAA­published 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.

20. The UA may not be operated less than 500 feet below or less than 2,000 feet

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

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21. 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 recovered in

accordance with the operating documents.

22. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in

accordance with the operating documents.

23. The PIC is prohibited from beginning a flight unless (considering wind and forecast

weather conditions) there is enough power to fly at normal cruising speed to the intended

landing point and land the UA with 25% battery power remaining.

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

number, registered in accordance with 14 C.F.R. part 47, and have identification (NNumber) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as

large as practicable.

25. 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 requirements.

26. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the

PIC at the Ground Control Station of the UAS any time the UAS is operating. These

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

upon request.

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

and activities at all times.

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

29. Flight operations must be conducted at least 500 feet from all nonparticipating persons

(persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles,

and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating

persons from the UA and/or debris in the event of an accident. The operator must

ensure that nonparticipating persons remain under such protection. If a situation

arises where 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 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).

30. All operations shall be conducted over private or controlled­access property with

permission from the land owner/controller or authorized representative. Permission from

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land owner/controller or authorized representative will be obtained for each flight to be

conducted.

31. 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 (AFS­80) within 24 hours. Accidents must be reported to

the National Transportation Safety Board (NTSB) per instructions contained on the NTSB

Web site: www.ntsb.gov.

2. Reasons Why An Exemption From The Requirements Of Section 61.113 Would Not Adversely

Affect Safety.

MEDIA FUSION submits that the equivalent level of safety established by Section 61.113 will be maintained

because no PIC will be allowed to operate the DJI Inspire 1 UAS unless that PIC has demonstrated the

ability to safely operate the DJI Inspire 1 UAS in a manner consistent with the exemption, including evasive

and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and

structures.

Considering MEDIA FUSION’s proposed area of operations, and the operating limitations set forth­above;

the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot

requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI

Inspire 1 UAS, MEDIA FUSION submits that the additional manned airmanship experience of a

commercially certificated pilot would not correlate to the airmanship skills necessary for MEDIA FUSION’s

specific proposed flight operations.

The FAA has previously granted relief from Section 61.113 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).

MEDIA FUSION will not allow any PIC to operate the DJI Inspire 1 UAS unless that PIC has demonstrate

the ability to safely operate the DJI Inspire 1 UAS in a manner consistent with this exemption, including

evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles

and structures.

Specifically, the PIC must have accumulated and logged, in a 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, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for

currency purposes).

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in

compliance with applicable regulations will ensure an equivalent level of safety during MEDIA FUSION’s

proposed operations. The Administrator has held that prior documented flight experience that was obtained

in compliance with applicable regulations would ensure safe operations, stating as follows:

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

motion picture filming (or similar operations), the PIC must have accumulated and logged, in a

manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at

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least 10 hours logged as a UAS pilot with a multi­rotor UAS. Prior to operations under Exemption

No. 11062, the PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot

operating the same make and model of UAS to be used for operations under the exemption. For

clarification, the FAA considers these minimum hour requirements to be inclusive rather than

additive; i.e. 5 hours make and model time may be included in the 10 hours of multi­rotor 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 flight­hour requirements in Exemption

No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct

the petitioner’s proposed operations. The FAA also finds that prior documented flight experience

that was obtained in compliance with applicable regulations would satisfy this requirement. Training,

proficiency, and experience­building flights can also be conducted under the grant of exemption to

accomplish the required flight time. During training, proficiency, and experience­building flights the

PIC is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119.

Exemption No. 11138 at page 15.

Accordingly, MEDIA FUSION will ensure safe operations by not allowing any PIC to operate the DJI Inspire

1 UAS unless that PIC has demonstrated, by meeting minimum flight­hour and currency requirements, that

the PIC is able to safely operate the DJI Inspire 1 UAS in a manner consistent with the exemption, including

evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles

and structures.

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

Affect Safety.

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

MEDIA FUSION will ensure that the DJI Inspire 1 UAS is in an airworthy condition based upon the UAS’s

compliance with its operating documents and as stated in the conditions and limitations herein.

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064,

11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158,

11159, 11160, 11161).

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

Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained because the altitude

information of the DJI Inspire 1 UAS will be provided to the PIC via GPS equipment and a radio

communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the

flight path and altitude. This altitude information, combined with MEDIA FUSION’s operation of the DJI

Inspire 1 UAS within visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to

Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft.

Prior to each flight, a zero altitude initiation point is automatically established by the UAS at ground level.

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

material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066,

11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely

Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section

91.151(b) as a result of (1) the technical specifications of the DJI Inspire 1 UAS; (2) the limitations on the

proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, MEDIA

FUSION will ensure that it will safely operate the battery powered DJI Inspire 1 UAS during daylight hours in

VFR conditions, with enough battery power to fly for a total duration of 22 minutes.

Here, as in Exemption No. 11109, the technical specifications of the DJI Inspire 1 UAS; the limitations on the

proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of

safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Inspire 1

UAS provide audible and visual warnings to the PIC at the GCS when the UAS experiences low battery

voltage, the first warning occurring at approximately 33% remaining battery power, and again at

approximately 22% remaining battery power. At the critically low battery level, the DJI Inspire 1 UAS will

descend and land automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not

adversely affected when the technical characteristics and operating limitations of the UAS are considered.

Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section

91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief

from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those presented

herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067,

11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety.

In seeking this exemption, MEDIA FUSION submits that the equivalent level of safety with regard to the

regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because MEDIA FUSION will use trained technicians

to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques,

and practices prescribed in the operating documents (i.e., MEDIA FUSION Aerial Operations Manual,

Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, MEDIA FUSION will

document and maintain all maintenance records for the DJI Inspire 1 UAS.

Since the DJI Inspire 1 UAS will be inspected as prescribed by the operating documents, MEDIA FUSION

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

91.409(a)(2). A copy of the DJI Inspire 1 User Manuals are attached hereto as Appendix A and B; a copy of

the DJI Inspire 1 UAS Maintenance LOG is attached hereto as Appendix C.

Likewise, the exemption sought will not adversely affect safety because MEDIA FUSION will use trained

technicians to perform maintenance, alterations or preventive maintenance on the UAS using the methods,

techniques, and practices prescribed by the operating documents.

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

91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI Inspire 1 UAS will be performed by

trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log.

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the technical

characteristics and operating limitations of the UAS are considered.

In consideration of MEDIA FUSION’s proposed operating limitations, the operating documents, and the

technical aspects of the DJI Inspire 1 UAS, MEDIA FUSION submits that safety will not be adversely

affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2),

and 91.417(a) and (b). The FAA has previously granted relief specific to UAS in circumstances similar, in all

material respects, to those 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.

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, MEDIA FUSION requests that the FAA prescribe special conditions for the

intended operation of the DJI Inspire 1 UAS, which contain such safety standards that the Administrator

finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H,

and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2),

and 91.417(a) & (b). Such special conditions will permit safe operation of the UAS for the limited purpose of

conducting aerial video and photography over certain areas of the United States for compensation or hire.

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users

of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority

for such UAS to operate without airworthiness certification in accordance 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 UAS, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or

appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 21.16,

entitled Special Conditions, states the following:

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

appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or

unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions

and amendments thereto for the product. The special conditions are issued in accordance with Part

11 of this chapter and contain such safety standards for the aircraft, aircraft engine or propeller as

the FAA finds necessary to establish a level of safety equivalent to that established in the

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 MEDIA FUSION’s intended operation of the DJI Inspire 1 UAS, which contain such safety

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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).

● A Summary That Can Be Published In The Federal Register, stating: The Rules From

Which MEDIA FUSION Seeks Exemption:

○ MEDIA FUSION seeks exemption from the requirements of 14 C.F.R Sections 61.113,

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 MEDIA FUSION Seeks:

○ This exemption will permit MEDIA FUSION to commercially operate an Unmanned

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

certain areas of the United States.

● Any Additional Information, Views, Or Arguments Available To Support MEDIA FUSION’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, MEDIA FUSION’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 security; and further, provides the authority

for such UAS to operate without airworthiness certification.

As discussed in detail above, MEDIA FUSION will operate the DJI Inspire 1 UAS safely in the NAS, without

creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.

CONCLUSION

As set forth herein, MEDIA FUSION seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of

the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI Inspire 1

UAS commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video

and photography over certain areas of the United States. By granting this Petition, the FAA Administrator will

be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also

advancing the interests of the public, by allowing MEDIA FUSION to safely, efficiently, and economically

operate the DJI Inspire 1 UAS commercially within the NAS.

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

Reform Act of 2012, Section 333, MEDIA FUSION respectfully requests that the Administrator grant this

Petition for an exemption from the requirements of 14 C.F.R Sections 61.113, 91.7(a), 91.121, 91.151(b),

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91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit MEDIA FUSION to operate

the DJI Inspire 1 UAS commercially for the purpose of conducting aerial video and photography over certain

areas of the United States.

Dated: March 10, 2016

Respectfully submitted,

Richard Williams

President

Media Fusion, Inc

4951 Century Street NW

Huntsville, AL 35816

richard@fusiononline.com / www.fusiononline.com

256­532­3874

Appendices:

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

https://dl.djicdn.com/downloads/inspire_1/en/Inspire_1_User_Manual_en_v2.0_1218.pdf

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