**United States Department of Transportation**

**Docket Operations 1200 New Jersey** 

**A ve.SE**  **West Building Ground Floor Room W12 -**  **140 Washington DC 20590** 

**Re: Exemption Request Pursuant To Section 333 of the FAA Reform A**  **ct of 2012**

Dear Sir or Ma dam: I am writing pursuant to the FAA Modernization and Reform Act of2012 (the "Reform Act") and the procedures contained in 14 C.F . R. 11, to request that Patrick Cavanagh , owner and and operator of Front Range Aerial Solutions , be exempted from the Federal Aviation Regulations (FAR's) listed below. The exemption is necessary to operate a small unmanned aircraft system (UAS) comm ercially in airspace regulated by the Federal Aviation Administration (FAA). These operations will be conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333.§11.81. It is requested that the following aspects of Section 333 of the FAA Modernization and Reform Act of 2012 be considered:

**Petition for Exemption under Section #333 of the FAA**  **Modernizations and Reform A ct of 2012 and 14 CFR Part 11**  **(1) Name and Address** Patrick Cavanagh (Front Range Aerial Solutions ) 3078 S Vine St Denver, CO 80210

**(2) Specific Exemption Sections:** 45.22(d) Alternate Marking 61.113(a) and (b) 61.119 91.7(a) 91.103 91.119(c) 91.12191.151(a)(1) day

91.405(a) 91.407(a)(1) 91.409(a)(1) and (2) 91.417(a) and (b)UNITED STATES OF AMERI CA

DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

WASHI NGTON, D.C

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

**Front Range Aerial Solutions 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 COMMERCIAL**  **OPERATION OF DJI PHANTOM 3**  **AND DJI INSPIRE 1 UNMANNED AIRCRAFT SYSTEMS**  **PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012** 

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

Submitted 10/27/ 2015 Front Range Aerial Solutions 3078 S Vine St Denver, CO 80210 Tel: (770) 880

- 3770**TABLE OF CONTENTS** Page

GLOSSARY OF ABBREVIATIONS........................................................... ........................3
SUMMARY...................................................................................................................... .....4
IN TRODUCTION AND INTERESTS OF PETITIONER....................................................4
BACKGROUND................................................................................................................... .4
BASI S FOR PETITION.........................................................................................................5
NAME AND ADDRESS OF PETITIONER............................................................ .7
THE SPECI FI C SECTIONS OF 14 C.F.R. FROM WHI CH FRONT RANGE VI DEOGRAPHY SEEKS EXEMPTI ON.................................................................8
THE EXTENT OF RELIEF FRONT RANGE AERIAL SOLUTIONS SEEKS AND THE REASON FRONT RANGE AERIAL SOLUTIONS SEEKS THE RELIEF.................................................................................................................11
THE REAS ONS WHY GRANTING FRONT RANGE AERIAL SOLUTIONS ’S REQUEST WOUL D BE IN THE PUBLIC INTEREST ......................................15
THE REASONS WHY GRANTING THE EXEMPTI ON WOULD NOT ADVERSELY AFFECT SAFETY..........................................................................19
SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGI STER......34 ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT FRONT RANGE AERIAL SOLUTIONS ’S REQUEST...............................................................................................................34
CONCLUSION.............. ......................................................................................................35
APPENDI CES........................................................................................37

2**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 Sy stem LOL Loss of Link NAS National Airspace Sy stem NOTAM Notice to Airman PI C 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 Sy stem VFR Visual Flight Rules VLOS Visual L ine of Site VMC Visual Meteorological Conditions VTOL Vertical Takeoff and Landing

3**SUMMARY** Front Range Aerial Solutions seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft Sy stem pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Front Range Aerial Solutio ns to operate an Unmanned Aircraft Sy stem (UAS) for the commercial purpose of conducting aerial video and photograph y for wedding videograph y, real es tate photography , farm surveying , wind turbine inspections , and structural inspections

.

**INTRODUCTION AND INTERESTS OF THE PETITIONER** Front Range Aerial Solutions provides its clients with expertise and knowledge in advanced technologies and solutions to increase efficiency , productivity and effectiveness. Front Range Aerial Solutions also provides its clients with the highest quality digital content for use in their commercial, personal, and non

- profit multimedia projects. Front Range Aerial Solutions h as over 10 ye ars of professional experie nce in aviation and over 1 ye ar of recre ational/hobby experience in all type s of aerial video and photography

. The objective of Front Range Aerial Solutions aerial video and photography operations is to provide high quality imaging for a variety of , commercial, public, and residential uses, specificall y targeting:
 Wedding Videograph y and Photograph y
 Wind Turbine Blade Inspection

 Real Estate Photograph y
 In crease public knowledge of UAS and promote safe UAS operations. **BACKGROUND** Unmanned Aircraft Sy stems: DJIPhantom 3 , DJ I Inspire 1 UASs Front Range Aerial Solutions seeks an exemption to operate DJ I systems for compensation or hire w ithin the NAS. The DJ I Phantom 3 and DJ I Inspire 1 are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The DJ I Phantom 3 has a maximum gross wei ght of approximately 2 pounds 13 ounces, while having a length of 16 inches width of 16 inches, height of 8 inches, and a maximum speed of approximately 29 knots. The DJ I Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of approximately

42 knots. The DJ I Phantom 3 and DJIInspire 1UAs are equipped with four ma in rotors; driven b y Li thium Poly mer battery

powered electric motors. The DJ I Phantom 3 and DJIInspire 1 UAS that will be operated b y Front Range Aerial Solutions 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** Petit ioner, Front Range Aerial Solutions , pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereb y petitions the Administrator to commerciall y operate the DJ I Phantom 3 Vision+, DJ I Inspire 1 UASs in the National Airspace S ys tem (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). In consideration of the speed, weight, size, and limited ope rating area associated with the unmanned aircraft and its operation, Front Range Aerial Solutions operation of DJIPhantom 3 and DJ I Inspire 1 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. Accordingl y, Front Range Aerial Solutions 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 onl y appl y to aircraft with an airworthiness certificate. Front Range Aerial Solutions submits that the requested relief i s proper since an equivalent level of safet y will be ensured. Front Range Aerial Solutions will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJ I Phantom 3 and DJIInspire 1 Instruction Manual). Furthermore, Front Range Aerial Solutions will document and maintain all maintenance records for the DJ I Phantom 3 and DJIInspire 1 UASs. Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot p rivileges and limitations: Pilot in command, is requested by Front Range Aerial Solutions to the extent necessary

to allow a Pilot in Command (PI C) holding a private pilot or higher level certificate, as well as an airman medical certificate, and who has demonstrated, b y meeting minimum flight

- hour and currency requirements, that the PI C is able to safel y operate the DJ I Phantom 3 and DJ I Inspire 1 UASs in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Front Range Aerial Soluti ons seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness , because the DJ I Phantom 3 and DJ I Inspire 1 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Front Range Aerial Solutions submits that he will ensure that the DJ I Phantom 3 and DJ I Inspire 1UASs are in an airworth y condition, prior to every flight, by determining that the UASs are in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJ I Phantom 3 and DJIInspire 1 Instruction Manual), and that the aircraft are in a condition for safe flight. Front Range Aerial Solutions also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , as the DJIPhantom 3 and DJ I Inspire 1 UAs will not have a ty

pical barometric altimeter onboard. However, altitude information of the DJIPhantom 3 and DJ I Inspire 1UAs will be provided to the PI C via Global Positioning Sy stem (GPS) equipment an d 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 Front Range Aerial Solutions ’s operation of the DJ I Ph antom 3 and DJ I

5Inspire 1 UASs within vis ual line of sight, at or below 4 00 feet AGL, will ensure a level of

safet y equivalent to Section 91.121. Additionally , Front Range Aerial Solutions seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions

. Front Range Aerial Solutions submits that safety will not be affected by

operation of the DJIPhantom 3 and DJ I Inspire 1 UAs during day light hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fl y for a total duration of approx imately 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fl y after that for at least 4.5 minutes. In accordance with 14 C.F.R. § 11.81, Front Range Aerial Solutions 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: Front Range Aerial Solutions Attn: Patrick Cavanagh 3078 S Vine St Denver, CO 80210 Tel: (770) 880

- 3770 Email: frontrangeaerialsolutions@gmail .com **B. The Specific Sections Of 14 C.F.R. from Which Front Range Aerial Solutions**  **Seeks Exemption.**
**1. Front Range Aerial Solutions**  **Seeks Exemption From The Requirements Of Section 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 cert ificate may act as a pilot in command (PI C) of an aircraft that is carrying passengers or propert y 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 an y business or emplo ym ent if

— (1) The flight is only

incidental to that business or employ ment; and (2) The aircraft does not carry passengers or property

for compensation or hire.
**2. Front Range Aerial Solutions**  **Seeks Exemption From The Require ments 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 airworth y condition. **3. Front Range Aerial Solutions**  **Seeks Exemption From The Requirements Of Section 91.121.** 

6Section 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 aircra ft, as the case may be, b y 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.
**4. Front Range Aerial Solutions**  **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. Front Range Aerial Solutions**  **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 inspe cted 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. Front Range Aerial Solutions**  **Seeks Exemption From The Requirements Of Section 91.407(a)(1)** 

7Section 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 b y a person authorized under § 43.7 of this chapter[.]
**7. Front Range Aerial Solutions**  **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 b y 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 chap ter.
**8. Front Range Aerial Solutions**  **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 i n paragraph (b) of this section: (1) Records of the maintenance, preventive maintenance, and alteration and records of the 100

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

8(2) Records containing the following information: (i) The total time in service of the airframe, each engine, each propeller, and each rotor. (ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance

. (iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, inc luding 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 safet y directive number and revision date. If the AD or safety directi ve involves recurring action, the time and date when the next action is required. (vi) Copies of the forms prescribed b y § 43.9(d) of this chapter for each major alteration to the airframe and currentl y 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 b y other work or for 1 ye ar after the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold. (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 Front Range Aerial Solutions**  **Seeks And The Reason Front Range Aerial Solutions**  **Seeks The Relief.**

9**1. Extent Of Relief Front Range Aerial Solutions**  **Seeks And The Reason Front Range Aerial Solutions**  **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 PI C holding a private pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met certain flight

- hour and currency requirements, to conduct the proposed UAS fli ght operations for compensation or hire. This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may , for compensation or hire, act as PI C of an aircraft in connection with an y business or emplo ym ent if: (1) The flight is only incidental to that business or employ

ment; and (2) The aircraft does not carry passengers or propert y for compensation or hire

. As set forth more full y below, Front Range Aerial Solutions submits that an equivalent level of safet y will be maintained because no PI C will be allowed to operate the DJIPhantom 3 UAS or DJIInspire 1 UAS unless that PI C has met certain flight

- hour and currency requirements, demonstrating that the PIC is able to safel y operate either the DJ I Phantom 3 or DJIInspire 1 UAS in a manner consistent with the o perations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures. Further, Front Range Aerial Solutions submits that all flights of the DJ I Phantom 3 and DJ I Inspire 1 UASs, conducted b y the PIC pursuant to the grant of this Petition: (1) will be incidental to Front Range Aerial So lutions ’s business; and (2) will not carry passengers or property

for compensation or hire. **2. Extent Of Relief Front Range Aerial Solutions**  **Seeks And The Reason Front Range Aerial Solutions**  **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 Front Range Aerial Solutions to determine that the DJIPhantom 3 and DJ I Inspire 1 UASs are in airworth y condition prior to every flight b y ensuring that the UAS is in compliance with the operating documents (i.e., the Front Range Aerial Solutions Aerial Operati ons Manual, Monthly Maintenance Log, and DJ I Phantom 3 and DJ I Inspire 1 Instruction Manual s ). Front Range Aerial Solutions seeks the requested relief because the DJ I Phantom 3 and DJ I Inspire 1 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Front Range Aerial Solutions will ensure that the DJIPhantom 3 and DJ I Inspire 1 UASs ar e in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJ I Phantom 3 and DJIInspire 1 Instruction Manual) prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated in the conditions and limitations below. **3. Extent Of Relief Front Range Aerial Solutions**  **Seeks And The Reason Front Range Aerial Solutions**  **Seeks Relief From Section 91.121.**

10Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the DJIPhantom 3 and DJ I Inspire 1 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 PI C at the ground control station (GCS). Since the FAA requires that an y altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), Front Range Videograph y seeks the requested relief because the DJ I Phantom 3 and DJ I In spire 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 full y set forth herein, an equivalent level of safet y will be maintained since the DJIPhantom 3 and DJ I Inspire 1 UAs are equipped with a barometric pressure sensor and GPS equipment, which automaticall y ensures that a ground level pressure setting will be established prior to each flight, and provides the PI C with altitude information of the UA on the heads

- up display of the GCS. **4. Extent Of Relief Front Range Aerial Solutions**  **Seeks And The Reason Front Range Aerial Solutions**  **Seeks Relief From Section 91.151(b).** Relief from Section 91.151(b) entitled Fuel requirements fo r flight in VFR conditions, is requested to the extent required to allow flights of the battery powered DJ I Phantom 3 and DJIInspire 1 UAs during daylight hours in visual meteorological condition s (VMC), under visual flight rules (VFR), for a total duration 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. Front Range Aeria l Solutions seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered DJ I Phantom 3 and DJ I Inspire 1 UAs will severel y constrain the practicalit y of any aerial video or still photo flight operations that Front Range Aerial Solutions proposes to conduct pursuant to this Petition. Significantl y, as set forth below, the technical specifications of the DJ I Phantom 3 and DJ I Inspire 1 UASs, the DJ I Phantom 3 and DJIInspire 1 operating documents, and Front Range Aerial Solutions ’s proposed operating limitations, ensure that Front Range Aerial Solutions will safely operate the battery

powered DJ I Phantom 3 and DJIInspire 1 UAs during daylight hours in visual meteorological conditio ns (VMC), under visual flight rules (VFR), with enough battery power to fl y for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fl y after that for at le ast 4.5 minutes.

**5. Extent Of Relief Front Range Aerial Solutions**  **Seeks And The Reason Front Range Aerial Solutions**  **Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b).** 

11Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b)

only appl y to aircraft with an airworthiness certificate, Front Range Aerial Solutions requests relief from these Sections because the DJ I Phantom 3 and DJIInspire 1 UASs do not require airworthiness certificates. As set forth more fully below, the DJI Phantom 3 and DJ I Inspire 1 UASs meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingl y, Front Range Aerial Solutions will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the Front Range Aerial Solutions Ae rial Operations Manual, Monthly Maintenance Lo g, and DJ I Phantom 3 and DJ I Inspire 1 Instruction Manual). Furthermore, Front Range Aerial Solutions will document and maintain all maintenance records for the DJIPhantom 3 and DJ I Inspire 1 UASs. **D. The Reasons Why Granting Front Range Aerial Solutions**  **’s 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 b y allowing Front Range Aerial Solutions to safely , efficiently , and economically perform aerial video and photograph y for wedding fi lms, real estate, special events, film sets, and landscape over certain areas of the United States. Additionally , use of the DJIPhantom 3 and DJ I Inspire 1 UASs will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the econom y. Notably , the benefits of Front Range Aerial Solutions ’s proposed operation of the DJ I Phantom 3 and DJIInspire 1 UASs will be realized without implicating any privacy issues. **1. The Public Will Benefit From Decreased Congestion Of The NAS.** The DJ I Phantom 3 and DJIInspire 1 UAs are 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 acquisit ions, an exemption allowing the use of a DJIPhantom 3 or DJ I 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 propert y i n the air and on the ground. Furthermore, b y reducing the number of manned aircraft operating in the NAS, congestion around airports caused b y arriving and departing aircraft will be reduced. The DJIPhantom 3 and DJ I Inspire 1 UAs do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photograph y missions would result in fewer aircraft that must be handled b y 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 Phantom 3**  **and DJI Inspire 1 UASs.** Conducting aerial acquisitions with the DJIPhantom 3 and DJ I Inspire 1 UASs, instead of manned aircraft, will greatl y benefit the public by drasticall y reducing the levels

12of air and noise pollution generated during traditional aerial video and still photography

flight operations. By

using battery

power and electric motors, the DJ I Phantom 3 and DJ I Inspire 1 UASs produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are ty picall y utilized for aerial video and photograph y , while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The DJ I Phantom 3 and DJIInspire 1 UAs, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAs are propelled b y battery powered electric motors, rather than an internal combustion engine. By

using the DJ I Phantom 3 and DJ I Inspire 1 UASs to perform aerial acquisitions, the substantial risk to life and propert y in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completel y eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJ I Phantom 3 and DJ I Inspire 1 UAs (weighing approximately 2 pounds 11 ounces and 6 pounds 7.5 ounces respectivel y, at their m aximum gross weights with lengths of 16 inches and 17.3 inches respectively , widths of 16 inches and 17.7 inches respectivel y, and with no fuel on board), has less physical potential for collateral damage to life and propert y on the ground, and in the air, compared to the manned aircraft that ty picall y 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 Phantom 3**  **and DJI Inspire 1 UASs Will Benefit The Economy.**
In addition to being safe and efficient, the DJ I Phantom 3 and DJIInspire 1 UASs are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJ I Phantom 3 and DJ I Inspire 1 UASs will allow United States based companies, like Front Range Aerial Solutions , to remain competitive and contribute to growth of the U.S. econom y. Specificall y, 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 DJIPhantom 3 and DJ I Inspire 1 UASs is one such techno logy 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. B y operating the DJ I Phantom 3 and DJIInspire 1 UASs, companies such as Front Range Aerial Solutions , can remain competitive and profitable, and therefore, provide greater job stability to employ ees and contractors, which will ultimately contribute to growth of the U.S. economy . Improved financial performance of U.S. companies, through commercial use of the DJ I Phantom 3 and DJIInspire 1 UASs, 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.**

13Similar to the manned aerial acquisition flight operations that have been conducted for

decades, Front Range Aerial Solutions ’s proposed operation of the DJ I Phantom 3 and DJI Inspire 1 UASs will not implicate an y privacy issues. Specificall y, the DJ I Phantom 3 and DJIInspire 1 UASs will be operated only in compliance with operating docum ents (i.e., the Front Range Aerial Solutions Aerial Operations Manual, Monthly Maintenance Log, and DJ I Phantom 3 and DJIInspire 1 Instruction Manual) which requires propert y owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119. **E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety,**  **Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which**  **Front Range Aerial Solutions Seeks**  **Exemption. 1. Reasons Why The**  **DJI Phantom 3 and DJI Inspire 1 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 associated with the unmanned aircraft and its operation, Front Range Aerial Solutions ’s operation of the DJ I Phantom 3 and DJIInspire 1 UASs me et 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 securit y. Spe cificall y, 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 o f 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).

14(c) Requirements for Safe Operation.

--If the Secretary determines under this
s ection 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, Front Range Aerial Solutions submits that the DJI Phantom 3 and DJIInspire 1 UASs can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated b y: (a) the characteristics of the DJ I Phantom 3 and DJ I Inspire 1 UASs; (b) the pilot certification requirement; and (c) the specific operating limitations.

**a. The Specific ations Of The**  **DJI Phantom 3 and DJI Inspire 1 UASs**  **Demonstrate Its Safe Characteristics.** The DJ I Phantom 3 and DJIInspire 1 UASs do not create a hazard to users of the NAS or the public, or otherwise p ose a threat to national security considering its size, weight, speed, and operational capability

.

**i. Technical Specifications Of The DJI Phantom 3**  **and DJI Inspire 1 UASs.**  The technica l specifications of the DJ I Phantom 3 and DJ I Inspire 1 UASs are set forth by the DJ I Phantom 3 and DJ I Inspire 1 Specifications and Data Sheet, attached hereto as Exhibit A and B.

**ii. The DJI Phantom 3**  **and DJI Inspire 1 UASs Autonomous Flight And Navigation Modes Enable The UASs To Remain Within A Defined**  **Operational Area.** The DJ I Phantom 3 and DJIInspire 1 UASs may be operated in both manual and fully autonomous flight modes. A complete description of the flight and navigational modes of the DJ I Phantom 3 and DJ I Inspire 1 UASs is provided at pages 25

- 35 of the DJ I Phantom 3 and pages 12

- 16 and 45

- 50 of the DJ I Inspire 1 User Manuals, attached hereto as Exhibit C and D.

**iii. The DJI Phantom 3**  **and DJI Inspire 1 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 L ink is lost, the DJIPhantom 3 and DJ I Inspire 1 UAs will remain stationary , in flight, for 3 seconds or more. If, after 3 seconds, the DJIPhantom 3 and DJ I Inspire 1 UAs do not reacquire control link data from the GCS, the UAs will assume that the Control Link is lost and the UAs will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown. A complete description of the Failsafe Functions of the DJ I Phantom 3 UAS are set forth at pages 27 through 29 and for the DJ I Inspire 1 at p ages 13 through 15 of the DJ I P hantom 3 and DJIInspire 1 User Manuals, attached hereto as Exhibit C and D.

**iv. The DJI Phantom 3**  **and DJI Inspire 1 GCS And Its Operation.**

15A complete description of the operation and specifications of the DJ I Phantom 3

and DJ I Inspire 1 GCS and flight control software is provided at pages 32 through 43 of the DJ I Phantom 3 User Manual and pages 40 through 47 of the DJ I Inspire 1 User Manual. DJ I Phantom 3 and DJ I Inspire 1 User Manuals are attached hereto as Exhibits C and D. **b. Flight Operations Of DJI Phantom 3**  **an d DJI Inspire 1 UASs Are** 

**Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer.**  Front Range Aerial Solutions will only utilize certificated pilots who possess a current and valid airman medical certificate to act as a pilot in command (PIC) of the DJ I Phantom 3 and DJIInspire 1 UASs. Additionally , a safet y observer will assist all pilots during flight ti me.

**c. Flights Of DJI Phantom 3**  **and DJI Inspire 1 UASs Will Be Conducted Pursuant To Specific Operating Limitations.**  In seeking this exemption, Front Range Aerial Solutions proposes to commerciall y operate DJ I Phantom 3 and DJIInspire 1 UASs for the special purpose of conducting aerial video and photograph y over certain areas of United States, pursuant to the following specific operating limitations: 1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: DJ I Phantom 3 and DJIInspire 1 Unmanned Aircraft Sy stems. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant. 2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photograph y. 3. The 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 4 00 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a specia l request is made and approved b y ATC. All altitudes reported to ATC must be in feet AGL. 5. The UAs must be operated within visual line of sight (VLOS) of the PI C at all times. This requires the PIC to be able to use human vision unaided by an y device other than corrective lenses, as specified on the PI C’s FAA

- issued airman medical certificate. 6. The use of first person view (FPV) b y the PI C or safet y observer (SO) is not permitted. 7. All operations must utilize a safet y observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC alway s maintains VL OS capability

. The SO and PI C must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be

16designated before the flight and cannot transfer his or her designation for the duration of the flight. The PI C must ensure that the SO can perform the functions prescribed in the operating documents. 8. The SO must not perform any other duties bey ond assisting the PI C 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

ex ists 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 preceden ce 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 (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operating do cuments. 10. Prior to each flight the PI C 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 UA S, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properl y documented in the aircraft records. 11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PI C who conducts the functional test flight must make an entry in the aircraft records. 12. The pre

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

17of 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 corr ective action taken against discrepancies discovered between inspections. 17. The PI C must possess at least a private pilot certificate and at least a current third

- class medical certificate. 18. The operator may

not permit any

PIC to operate unless the PI C meets the operator’s qualification criteria and demonstrates the ability to safel y operate the UAS in a manner consistent with how the UAS will be ope rated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be lo gged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator’s PICs are permitted under the terms of the exemption. However, training operations may onl y be conducted during dedicated training sessions. During training, proficiency , and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PI C 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 flight at night is required, a special request will be made at the FAA office closest to proposed area of operations. Flights un der special visual flight rules (SVFR) are not authorized. 20. The UA may

not operate within 5 nautical miles of an airport reference point as denoted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request. 21. The UA may

not be operated less than 500 feet below or less than 2,000 feet horizontally

from a cloud or when visibility is less than 3 statute miles from the PI C. 22. If the UA loses communications or loses its GPS signal, it must return to a pre

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

1823. The PI C must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents. 24. The PI C is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 25% battery power remaining. 25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting an y operations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requirements. 26. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (N

- Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable. 27. Before conductin g 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 re quirements. 28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS an y time the UAS is operating. These documents must be made available to the Administrator or an y law enforcement official upon request. 29. The UA must remain clear and yi eld the right of way to all manned aviation operations and activities at all times. 30. The UAS may

not be operated b y the PIC from any moving device or vehicle. 31. Flight operations must be conducted at least 500 feet from all nonpartici pating persons (persons other than the PI C, 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 non participating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately

and/or;

19b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PI C has made a safet y assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, and; c. Operations nearer to the PI C, SO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a). 32. All operations shall be conducted over private or controlled

- access property with permission from the land owner/controller or authorized representat ive. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted. 33. Any incident, accident, or flight operation that transgresses the lateral or vertical 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. Accidents must be reported to the National Transportation Safet y Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

. **2. Reasons Why An Exemption From The Requirements Of Section 61.113(a)**  **And (b) Would Not Adversely Affect Safety.** Front Range Aerial Solutions submits that the equivalent level of safet y established by Section 61.113(a) and (b) w ill be maintained because no PIC will be allowed to operate the DJ I Phantom 3 and DJIInspire 1 UASs unless that PI C has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PI C is able to safely operate the DJIPhantom 3 or DJIInspire 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 Front Range Aerial Solutions ’s proposed area of operations, and the operating limitations set forth

- above; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the DJ I Phantom 3 or DJ I Inspire 1 UAS, Front Rang e Aerial Solutions submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for Front Range Aerial Solutions ’s specific prop osed flight operations. The FAA has previously

granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). Front Range Aerial Solutions will not allow any PIC to operate the DJ I Phantom 3 or DJ I Inspire 1 UAS unless that PI C has demonstrated, by meeting minimum flight

- hour requirements or the DJ I Phantom 3 or DJIInspire 1 UAS training and currency requirements, that the PIC is able to safel y operate the DJ I Phantom 3 or DJIInspire 1 UAS in a manner consistent with this exemption, including evasive and emergency

20maneuvers and maintaining appropriate distances from people, vessels, vehicles and

structures. Specificall y, the PI C 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 exempt ion). In addition to the hour requirements, the PI C must accomplish 3 takeoffs and landings in the preceding 90 day s (for currency purposes). As in Exemption Nos. 11062, 11138, and 11153, prior do cumented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safet y during Front Range Aerial Solutions ’s proposed operations. The Admi nistrator 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 p rior 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 least 10 hours logged as a UAS pilot with a multi

- rotor UAS. Prior to operations under Exemption No. 11062, the PI C 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 multi

- rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requi rements, the PI C must accomplish 3 takeoffs and landings in the preceding 90 day s (for currency purposes). The FAA finds that at a minimum, the flight

- hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary

to safely conduct the petitioner’s 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 experience

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

- building flights the PI C is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15. Accordingl y, Front Range Aerial Solutions will ensure safe operations by not allowing an y P IC to operate the DJ I Phantom 3 or DJIInspire 1 UAS unless that PI C has demonstrated, b y meeting minimum flight

- hour and currency requirements, that the PI C is able to safel y operate the DJIPhantom 3 or DJIInspire 1 UAS in a manner consistent with the exemption, inc luding 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) Wou**  **ld Not Adversely Affect Safety.** The equivalent level of safet y established b y Section 91.7(a) will be maintained because prior to every

flight, Front Range Aerial Solutions will ensure that the DJ I

21Phantom 3 or DJIInspire 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 safet y established b y Section 91.121 will be maintained because the altitude information of the DJ I Phantom 3 and DJ I Inspire 1 UAs will be provided to the PI C 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 Front Range Aerial Solutions ’s operation of the DJ I Phantom 3 and DJIInspire 1 UAs within visual line of sight, at or below 500 feet AGL, will ensure a level of saf et y equivalent to Section 91.121. The altitude information will be generated b y 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 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 Sect ion 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 sp ecifications of the DJ I Phantom 3 and DJIInspire 1 UASs; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingl y, Front Range Vi deograph y will ensure that it will safely operate the battery

powered DJ I Phantom 3 and DJIInspire 1 UAs during day light hours in VFR conditions, with enough battery power to fly for a total duration 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. Here, as in Exemption No. 11109, the technical specifications of the DJ I Phantom 3 and DJ I Inspire 1 UASs; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safet y established by 14 C.F.R. Section 9 1.151(b). Furthermore, safet y will be ensured as the DJ I Phantom 3 and DJIInspire 1 UASs provide audible and visual warnings to the PI C at the GCS when the UAs experiences low battery voltage, the first warning occurring at approximately 33% remaining battery

power, and again at approximately 10% remaining battery

power. At the critically low battery

level, the DJ I Phantom and DJIInspire 1 UASs will descend and land automatically

. Significantl y, previous exemptions granted b y the FAA concerning Section 91.151 establish that safet y is not adversel y affected when the technical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned

22aircraft 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 here in (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, Front Range Aer ial Solutions 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 Front Range Aerial Solutions will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., the Front Range Videograph y Aerial Operations Manual, Monthly Maintenance Lo g, and DJIPhantom 3 and DJ I Inspire 1 Instruction Manual). Furthermo re, Front Range Aerial Solutions will document and maintain all maintenance records for the DJ I Phantom 3 and DJIInspire 1 UASs. Since the DJ I Phantom 3 and DJ I Inspire 1 UASs will be inspected a s prescribed by the operating documents, Front Range Aerial Solutions will maintain the equivalent level of safet y established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A cop y of the DJIPhantom 3 and DJ I Inspire 1 User Manuals are attached hereto as Exhibit C and D; a copy of the DJ I Phantom 3 and DJ I Inspire 1 UAS Maintenance LOG is attached hereto as Exhibit E. Likewise, th e exemption sought will not adversel y affect safety because Front Range Aerial Solutions will use trained technicians to perform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed b y the operating documents. Furthermore, the exemption sought would maintain an equivalent level of safet y established by

Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJIPhantom 3 and DJ I Inspire 1 UASs will be performed b y trained technicians. Maintenance will be documente d and maintained utilizing the monthly maintenance log. Significantl y, previous exemptions granted b y the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that saf et y is not adversel y affected when the technical characteristics and operating limitations of the UAS are considered. In consideration of Front Range Aerial Solutions ’s proposed operating limitations, the operating documents, and the technical aspects of the DJ I Phantom 3 and DJIInspire 1 UASs, Front Range Aerial Solutions submits that safet y 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.**

23In accordance with Section 333 of the FAA Modernization and Reform Act of 2012

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Front Range Aerial Solutions requests that the FAA prescribe special conditions for the intended operation of the DJ I Phantom 3 and DJIInspire 1 UASs, which contain such safet y standards that the Administrator finds necessary to establish a level of safet y equivalent to that established b y 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.11 3(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 photograph y over certain areas of the United States for compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a h azard 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 require ments 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 DJ I Phantom 3 and DJIInspire 1 UASs, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safet y 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 safet y standards for an aircra ft, 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 L eading Edge’s intended operation of the DJ I Phantom 3 and DJIInspire 1 UASs, which contain such safet y standards that the Administrator finds necessary to establish a level of safet y equivalent to that established b y 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

**F. A Summary That Can Be Published In The Federal Register, stating: The Rules**  **From Which Front Range Aerial Solutions**  **Seeks Exemption:**
Front Range Aerial Solutions 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).

24**A Brief Description Of The Nature Of The Exemption Front Range**  **Aerial Solutions Seeks:**  This exemption will permit Front Range Aerial Solutions to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States. **G. Any Additional Information, Views, Or Arguments Available To Support Front Range Aerial Solutions**  **’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, Front Range Aerial Solutions ’s request for exemption may

be granted pursuant to th e 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 th e public, or otherwise pose a threat to national securit y; and further, provides the authority for such UAS to operate without airworthiness certification. As discussed in detail above, Front Rang e Aerial Solutions will operate the DJ I Phantom 3 and DJIInspire 1 UASs safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national securit y. **CONCLUSION** As set forth herein, Front Range Aerial Solutions seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (F MRA), which will permit safe operation of the DJIPhantom 3 and DJ I Inspire 1 UASs commerciall y, 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, whi le also advancing the interests of the public, by allowing Front Range Aerial Solutions to safely, efficientl y, and economically operate the DJ I Phantom 3 and DJIInspire 1 UASs commerciall y within the NAS. **WHEREFORE** , in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, Front Range Aerial Solutions respectfull y requests that the Administrat or 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 Leading Edge to operate the DJ I Phantom 3 and DJ I Inspire 1 UASs commerciall y for the purpose of conducting aerial video and photograph y over certain areas of the United States. Dated: March 31, 2015 Respectfully

submitted, Patrick Cavanagh Front Range Aerial Solutions, Owner 3078 S Vine St Denver, CO 80210 Tel: (770) 880

- 3770
25_________________________

Appendices:
A

– DJ I Phantom 3 Specifications Data Sheet B

– DJ I Inspire 1 Specifications Data Sheet C

– DJIPhantom 3 Manufacturer’s User Manual D

– DJ I Inspire 1 Manufacturer’s User Manual E

– Monthly

Maintenance L og

APPENDIX

– A
**DJI PHANTOM 3 TECHNICAL SPECIFICATIONS**  Front Range Aerial Solutions only utilizes safe and reliable UASs. DJ I is an industry leader in small UAS production. DJIUASs are loaded with ground breaking software enabling the user to set parameter s which will not allow flight into controlled airspace.

26Parameters can also be set to limit flight to no higher than a predetermined and set altitude

as well as limit flight to a predetermined and set distance. In addition, DJIsoftware provides real

- time altitude and location information to the PI C via the linked monitor (smart phone/tablet devices)
1.1 DJIPhantom 3 1.1.1 Aircraft 1. 1.1.1 Supported Battery

– DJ I 60 00mAH LiPo Battery 1.1.1.2 Weight (Battery & Propellers Included)

– 2lbs 13 .150oz (1280 g) 1 .1.1.3 Hover Accuracy

(Ready to Fl y)

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

- 35 0 1.1.1.6 Max Ascent Speed

– 5 m/s 1.1.1. 7 Max Descent Speed

– 3 m/s 1.1.1.8 Max Flight Speed

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

– Static: 750mA; Dy namic: 900mA 1.1.2.2 Control Accuracy

- ±0.03 0 1.1.2.3 Controllable Range

– Pitch:

- 90 0 to + 30 0 1.1.2.4 Maximum Angular Speed

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

- 32 0 F

- 104 0 F (0 0 C

- 40 0 C) 1.1.3.2 Sensor Size

– 1/2.3” 1.1.3.3 Effective Pixels

– 12.4 M 1.1.3.4 Resolution

– 4384x3288 4.1.3.5 HD Video Recording

– 1080p30 & 720p 4.1. 3.6 Recording Field of View

- 94 0
1.1.4 Transmitter 1.1.4.1 Operating Frequency

– 4.00GHz

– 4.83 GHz 1.1.4.2 Communication Distance (unobstructed)

– FCC Compliance: 20 00m 1.1.4.3 Receiver Sensitivity (1%PER)

- - 93dBm 1.1.4.4 Transmitter Power

– FCC Compliance: 100mW 1.1 .4.5 Working Voltage

– 120mA@7.4 V
1.1.5 Range Extender 1.1.5.1 Operating Frequency

– 2412

- 2462MHz 1.1.5.2 Communication Distance (unobstructed)

– 500

- 700m 1.1.5.3 Transmitter Power

– 20dBm 1.1.5.4 Power Consumption

– 2W

27APPENDIX

– B
**DJI INSPIRE 1 TECHNICAL SPECIFICATIONS** Front Range Aerial Solutions only utilizes safe and reliable UASs. DJ I is an industry leader in small UAS production. DJIUASs are loa ded with ground breaking software

28enabling the user to set parameters which will not allow flight into controlled airspace.

Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJIsoftware provides real

- time altitude and loc ation information to the PI C via the linked monitor (smart phone/tablet devices) 2.2 DJI Inspire 1
2.2.1 Aircraft 2.2.1.1 Model

– T600 2.2.1.2 Weight (Battery Included)

– 6lbs 7.5291oz (2935g) 2.2.1.3 Hovering Accuracy (GPS Mode)

– Vertical: 0.5m; Horizontal: 2.5m 2.2.1.4 Max Angular Velocity

– Pitch: 300 0/s; Yaw: 1500/s 2.2.1.5 Max Tilt Angle

- 35 0 2.2.1.6 Max Ascent Speed

– 5m/s 2.2.1.7 Max Descent Speed

– 4m/s 2.2.1.8 Max Speed

– 22m/s (ATTI mode, no wind

– NOT RECOMMENDED) 2.2.1.9 Max Flight Altitude

– 4500m 2.2.1.10 Max Wind Resistance

– 10m/s 2.2.1.11 Max Flight Time

– Approximately 18 minutes 2.2.1.12 Motor Model

– DJI 3510 2.2.1.13 Propeller Model

– DJI 1345 2.2 .1.14 Operating Temperature Range

– 14 0F to 1040F (

- 10 0C to 400C) 2.2.1.15 Dimensions

– 17 1⁄4” x 17 3⁄4” x 12”
2.2.2 Gimbal 2.2.2.1 Model

– ZENMUSE X3 2.2.2.2 Output Power (with came ra)

– Static: 9W; In Motion: 11W 2.2.2.3 Operating Current

– Static: 750mA; In Motion: 900mA 2.2.2.4 Angular Vibration Range

- ±0.03 0 2.2.2.5 Mounting

– Detachable 2.2.2.6 Controll able Range

– Pitch:

- 90 0 to +300; Pan: ±3200 2.2.2.7 Mechanical Range

– Pitch:

- 125 0 to 450; Pan: ±3300 2.2.2.8 Max Controllable Speed

– Pitch: 120 0/s; Pan: 1800/s
2.2.3 Camera 2. 2.3.1 Name

– X3 2.2.3.2 Model

– FC350 2.2.3.3 Total Pixels

– 12.76M 2.2.3.4 Effective Pixels

– 12.4M 2.2.3.5 Image Max Size

– 4000x3000 2.2.3.6 ISO Range

– 100

- 3200 2.2.3.7 Field of View

- 94 0 2.2.3.8 CMOS

– Sony EXMOR 1/2.3”

292.2.3.9 HD Video Recording

– UHD(4K): 4096x2160p24/25, 3840x2160p24/25/30; FHD: 1920x1080p24/25/30/48/50/60; HD: 1280x720p24/25/30/48/50/60 2.2.3.10 Operating Temperature Range

- 32 0F

- 104 0F (00C

- 40 0C)
2.2.4 Transmitter 2.2.4.1 Na me – C1 2.2.4.2 Operating Frequency

– 5.728

- 5.850GHz; 2.400

- 2.483GHz 2.2.4.3 Communicating Distance (unobstructed)

– 2000m 2.2.4.4 Output Power

– 9W 2.2.4.5 Operating Temperature Range

- 14 0F to 1040F (

- 10 0C to 400C) 2.2.4.6 Battery

– 600mAh LiPo 2S

30APPENDIX

– C
DJIPhantom 3 Manufacturer’s User Manual

31APPENDIX

– D
DJIInspire 1 Manufacturer’s User Manual

APPENDIX

– E

32**MONTHLY$MAINTENANCE$LOG** month:_________(year:________ Date(Issue( Date(Issue( **UAS$#:$___________**

Discovered Addressed Issue(Description(&(Maintenance(Conduct ed Maintenance(Performed(By:((( Print(&(Sign
Software(Updates Airframe( Engines Propellers Camera(Gimbal Landing(Gear Vibration(Dampening
Other:

33