1 | Page 

## Red Dog Aerial Media, LLC

June 10, 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re: Exemption Petition under Section 333 of th e FAA Modernization & Reform Act, and Title 14 Part 11 of the Code of Federal Regulations (CFR)

14 CFR 61.113,
14 CFR 91.7, 91.119, 91.121, 91.151 14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417)

Dear Sir or Madam,

Pursuant to Section 333 of the FAA Moderniza tion & Reform Act and 14 C.F.R. Part 11, Red Dog Aerial Media, LLC (Red Dog Aerial) her eby applies for the grant of exemption from certain Federal Aviation Regulations for Phantom II Vision+ (Phantom) and Inspire 1 (Inspire)
Unmanned Aircraft, both manufactured by DJI Co. ,Ltd. of China.

The requested exemption would support an applic ation for a commercial Certificate of Authorization (COA) to use the Phantom and Inspire to support real estate photography, videography, and aerial surveying for other commercial industries.

The Phantom Unmanned Aircraft System (UAS) consis ts of a lightweight (4 lb) battery operated quadcopter unmanned aircraft, onboard cameras, and associated communications equipment. The Inspire Unmanned Aircraft System (UAS) consis ts of a lightweight (6.5 lb) battery operated quadcopter unmanned aircraft, onboard cameras, and associated communications equipment.

The Phantom and Inspire Unmanned Aircraft (UA) have previously demonstrated to have successfully met the safety and operational requirem ents resulting in previous grants of section 333 exemption requests by other commercial UAS operators.

The Phantom and Inspire UA both carry an onboard ca mera system that allows them to perform aerial photography, videography, and surveying.

By approving the exemption, the Red Dog Aerial UAS operations will crea te benefits to both the economy and the environment which are ulti mately in the public interest.2 | Page 

### The aircraft will be operated with both a Pilot in Command and a Visual Observer in accordance with the following additional restrictions:

• All operations will occur at no more than 400' AGL

• The aircraft will be operated with t he permission of the property owner

• When necessary, applicable permits will be acquired from local authorities

• The aircraft will not be operated over urban or populated areas

• The aircraft will not be operated at air shows or over an open-air assembly of people

• The aircraft will not be operated over heavily trafficked roads

• Operations will be limited to day, visual meteorological conditions

• Aircraft will remain within Visual Line of Sight at no greater than 1/2 NM of the PIC at all

time

• While the aircraft is airborne, the VO will be positioned within voice distance to the PIC

• When necessary and applicable, Red Dog Aerial will file a NOTAM pr oviding radial/DME, radius, and a date/time group for each operation

For certain complex operations , Red Dog Aerial may assign one additional camera operator and spotters to assist the operations.

We submit that t he combination of:

• The Phantom and Inspire UAV’s light weight and historically demonstrated safe operation and receiving approvals of multiple section 333 petitions

• Fully qualified flight crew

• Restricted operations under the guidelines establis hed within the grant,

• The FAA can have confidence that Red Do g Aerial UAS the operations will have an equivalent or greater level of safety of manned aircraft performing the same mission.

We are prepared to modify or amend any part of th is request to satisfy the need for an equivalent level of safety. Additional documents supporting th is petition will be submitted following this
request.

We look forward to working with your office. Please contact us at any time if you require additional information or clarification.

Respectfully,

James Cloutier Red Dog Aerial Media, LLC

54 Haven Drive
Auburn, NH 03032 Tel: (603) 203-6037

Email: jcloutier@reddogaerial.com3 | Page 

## TABLE OF CONTENTS

NAME, ADDRESS CONTACT INFORMATI ON OF PETITIONER .............................Page 4

THE SPECIFIC SECTIONS OF 14 C.F. R. FROM WHICH RED DOG AERIAL SEEKS EXEMPTION.........................................................................................................Page 4

THE EXTENT OF RELIEF RED DOG AERIAL SEEKS AND THE REASONS

RED DOG AERIAL SEEKS THE RELIEF .....................................................................Pages 4 to 6

THE REASONS WHY GRANTING RED DO G AERIAL’S REQUEST WOULD BE IN THE PUBLIC INTEREST ......................................................................................Pages 6 to 7

THE REASONS WHY GRANTING RED DO G AERIAL THE EXEMPTION WOULD

NOT ADVERSELY AFFECT SAFETY ...........................................................................Page 7

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER................Page 8

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS

AVAILABLE TO SUPPOR T RED DOG AERIAL’S REQUEST....................................Page 9

GLOSSARY OF ABBREVIA TIONS................................................................Pages 12 & 134 | Page 

### NAME, ADDRESS AND CONTACT INFORMATION OF PETITIONER

James Cloutier Red Dog Aerial Media LLC

54 Haven Drive
Auburn, NH 03032 Tel: (603) 203-6037

Email: jcloutier@reddogaerial.com

THE SPECIFIC SECTIONS OF 14 CFR TO BE RELIEVED FROM

14 CFR 61.113,
14 CFR 91.7, 91.119, 91.121, 91.151 14 CFR 91 Subpart E (91. 405, 91.407, 91.409, 91.417)

THE EXTENT OF RELIEF RED DOG AERIAL SEEKS AND THE REASONS RED DOG AERIAL

SEEKS THE RELIEF 14 CFR 61.113 Private pilot privileges and limitations:

Part 61.113 provides that no person that holds a private pilot certificate may act as pilot in command of an aircraft for compensat ion or hire. Subparagraph (b) allows a private pilot to act as pilot in command of an aircraft in conn ection with any business or employment if;

(1) flight is only incidental to that business or employment; and

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



### .

Since the aircraft cannot carry passengers or pr operty, we request to be relieved from this regulation if our pilo ts at minimum, (1) hold at least a current pr ivate pilot certificate and, (2) hold a current third cl ass medical certificate. By meeting conditions (1) and (2), we believe that equivalent level of safety can be achieved by complying with 61.113 Subparagr aph (b) even though the intent of this application is to conduct a business.

14 CFR 91.7 Civil Aircraft Airworthiness.

14CFR 91.7 (a) states,

“ No person may operate a civil aircraft unless it is in an airworthy condition 

### .”

This rule prohibits the operation of an airc raft without an airworthin ess certificate. Since there is no such existing certificate that is applicable for the P hantom or Inspire UAS’ to properly comply with the FARs, we request t hat Red Dog Aerial to be relieved from this regulation.

To provide equivalent level of safety, we will ensure that the Phantom and Inspire UAS’ are in airworthy condition prior to every flight by following safety procedures described in our operating documents.5 | Page 

### 14 CFR 91.119 Minimum safe altitud es: General

This regulation provides that over sparsely populated areas t he aircraft cannot be operated closer than 500 feet to any person, vessel, vehi cle, or structure. Since the aircraft will be operating at a maximum of 400 feet AGL, we cannot comply with this requirement.

To provide an equivalent level of safety we will only fly over priv ate property with the permission of the land owner. The land owner will be briefed of the expect ed route of flight and the associated risks to persons and property on the ground. We maintain that due to
the small size of the Phantom, the hazard to persons, vessels, vehicles, and structures is not comparable to manned aircraft and should be co nsidered in granting the exemption.

14 CFR 91.121 Altimeter Settings

This regulation provides that aircraft shall ma intain cruising altitudes by reference to an altimeter setting available within 100 nautical miles of the aircraft. The Phantom and Inspire aircraft will fly bel ow 400 feet AGL and will not need to maintain hemispherical cruising altitudes in order to de-conflict with other aircraft.

To provide an equivalent level of safety, the PIC will check and c onfirm the Phantom and Inspire’s GPS altitude read out before each flight.

14 CFR 91.151 Fuel requirements fo r flight in VFR conditions.

The regulation provides that no person may begi n a flight in an airplane under day-VFR conditions unless there is enough fuel to fly to the first point of in tended landing and to fly

after that for at least 30 minutes . We believe the intention of this rule is to provide a reserve of energy as a safety bu ffer for go-arounds and other delays to landing. The Phantom UAS is battery operated and the maxi mum duration of flight with full payload, from a single battery charge is approximately 25 minutes. The Inspire UAS is battery operated and the ma ximum duration of flight with full payload, from a single battery charge is approximately 18 minutes. We believe that equivalent level of safety can be achieved by limiting our flight with reserve energy 20 % ( ~5 minutes) on the battery.

14 CFR 91 Subpart E ( 91.405, 91.407, 91. 409, 91.417 ) Maintenance, Preventive
Maintenance, and Alterations

The regulation provides that the operator is primarily res ponsible for maintaining the aircraft in an airworthy condition, includi ng compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "appr oved for return to service by a person

authorized under 43.7" after main tenance and inspection. It is our intention that the PIC, VO or authorized personnel to perform maint enance and inspection of the aircraft and "be authorized to approve the aircraft for return to service."6 | Page 

### Red Dog Aerial requests that exemptions to the regulations under conditions below;

(1) Red Dog Aerial will follow DJI’s manufactu rer maintenance instructions, techniques and procedures

(2) Red Dog Aerial will designate, trai n, and document the per sonnel who will be authorized to perform Inspecti on, Maintenance and Alterations by means of above stated maintenance instructions. Such designated personnel may include PIC, VO or other equivalent trained persons

(3) To ensure equivalent level of safety, PIC wil l inspect the UA before each flight looking for any structural or mechanical malfunctions

Due to the small size, light weight and simpli city of the Phantom and Inspire UAS’, we believe that the equivalent sa fety will be achieved by permitti ng any of the PIC, VO or equivalent trained personnel, to perform maint enance, inspection and alterations of the aircraft and " be authorized to approve the aircraft for return to service. "

THE REASONS WHY GRANTING RED DOG AERIAL’S REQUEST WOULD BE IN THE PUBLIC

INTEREST



### We believe that granting our exemption request from,

14 CFR Part 21.191
14 CFR Part 45.23, 45.29
14 CFR 61.113, 61.133
14 CFR 91.9, 91.119, 91.121, 91.151 14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417), is in the pub lic’s interest and will benefit the public as a whole for the following reasons.

1- Phantom and Inspire are battery oper ated and free from the harmful emissions

associated with the manned airc raft that are currently us ed for aerial photography and videography.

As recently proven by several gr ants of section 333 petitions, UASs offer equivalent level of safety while reducing environmental impacts, which is in the public interest.

2- Red Dog Aerial’ UAS oper ations will contribute to a positive aggregate economic impact resulting in creation of jobs both direct and indirectly. Econom ic Research estimates that the UAS market will grow from $6 billion to $ 94 billion over the next decade resulting in a new workforce development.

Because Red Dog Aerial operations will create new jobs such as pilots, flight operation staff, and administrative supporting staff, it will directly cause positive economic impact , hence granting Red Dog Aerial’ petition will benef it the public as a whole.7 | Page 

### 3- Congress has already proclaimed that it is in the public ’s interest to integrate commercially flown UAS(s) into the national airspace system, hence the passing of the FAA

Modernization and Reform Act of 2012.

Granting Red Dog Aerial’s petitio n furthers the public’s interest as a demonstrat ed progression of integrating Unmanned Aircraft Syst ems into National Air Space, thus it will benefit public as a

whole.

THE REASONS WHY GRANTING RED DOG AERIAL THE EXEMPTION WOULD

NOT ADVERSELY AFFECT SAFETY

Red Dog Aerial believes that t he grant of exem ption from, 14 CFR 61.113,
14 CFR 91.7, 91.119, 91.121, 91.151 14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417), will not adverse ly affect safety by a

combination of the r easons listed below.

(a) We have stated in the above section “ THE EXTENT OF RELIEF RED DOG AERIAL

SEEKS AND THE REASONS RED D OG AERIAL SEEKS THE RELIEF” by describing how we intend to mitigate risk and accomplish FAA equival ent and acceptable level of safety for each 14 CFR part.

(b) As a result of Phantom and Inspire unm anned aircraft’s size, weight, speed, operational capability, proximity to airports and populated areas, operation withi n visual line of sight combined with the implementation R ed Dog Aerial of safety procedures, we believe that granting Red Dog Aerial’s exemption request will not adversely affect safety.

(c) DJI Phantom and Inspire have demonstrated to satisfy necessary safety risk mitigation by FAA thus resulting in multiple grants of section 333 petitions.

Because of the combination of Phantom and t he Inspire’s proven success and the conditions and limitations of our operations, we believe granting Red Dog Aerial’s request will not adversely safety.

.8 | Page 

### SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER

Department of Transportation

Federal Aviation Administration

Petitioner: Red Dog Aerial Media, LLC

Petition of exemption fr om sections of ;

14 CFR 61.113,
14 CFR 91.7, 91.119, 91.121, 91.151 14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417)

Description of relief sought;

Red Dog Aerial seeks an exemption for commer cial operation of the Phantom and Inspire unmanned aircraft manufactured by DJ I Co, Ltd. of China. The Phantom and Inspire unmanned aircraft system have an onboard camera system capable of acquiring high resolution data. Proposed operations will offer real estate aer ial photography, videography and aerial surveying

services for other commercial industries.

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT

RED DOG AERIAL’S REQUEST9 | Page DJI PHANTOM 2 VISION+ TECHNICAL SPECIFICATIONS

Red Dog Aerial only utilizes safe and reliable UASs. DJI is an industry leader in small UAS production. DJI UASs

are loaded with ground breaking software enabling the user to set parameters which will not allow flight into

controlled airspace. Parameters can also be set to limit f light to no higher than a predetermined and set altitude as

well as limit flight to a predetermined and set distance. In addition, DJI software provides real-time altitude and

location information to the PIC via the linked monitor (smart phone/tablet devices)

1.1 DJI Phantom 2 Vision+

1.1.1 Aircraft

1.1.1.1 Supported Battery

– DJI 5200mAH LiPo Battery

1.1.1.2 Weight (Battery & Propellers Included)

– 2lbs 11.810oz (1242g)

1.1.1.3 Hover Accuracy (Ready to Fly)

– Vertical: .8m; Horizontal: 2.5m

1.1.1.4 Max Yaw Angular Velocity
‐ 200 0 /s

1.1.1.5 Max Tilt Angel
‐ 35 0

1.1.1.6 Max Ascent Speed

– 6m/s

1.1.1.7 Max Descent Speed

– 2m/s

1.1.1.8 Max Flight Speed

– 15m/s (NOT RECOMMENDED)

1.1.2 Gimbal

1.1.2.1 Working Current

– Static: 750mA; Dynamic: 900mA

1.1.2.2 Control Accuracy ‐ ±0.03 0

1.1.2.3 Controllable Range

– Pitch:
‐ 90 0
‐ 0 0

1.1.2.4 Maximum Angular Speed

– Pitch: 90 0 /s

1.1.3 Camera

1.1.3.1 Operating Temperature Range ‐ 32 0 F ‐ 104 0 F (0 0 C ‐ 40 0 C)

1.1.3.2 Sensor Size

– 1/2.3”

1.1.3.3 Effective Pixels

– 14M

1.1.3.4 Resolution

– 4384x3288

4.1.3.5 HD Video Recording

– 1080p30 & 720p

4.1.3.6 Recording Field of View ‐ 110 0 /85 0

1.1.4 Transmitter

1.1.4.1 Operating Frequency

– 5.728GHz

– 5.85GHz

1.1.4.2 Communication Distance (unobstructed)

– FCC Compliance: 800m

1.1.4.3 Receiver Sensitivity (1%PER)

‐ ‐ 93dBm

1.1.4.4 Transmitter Power

– FCC Compliance: 100mW

1.1.4.5 Working Voltage

– 120mA@3.7V

1.1.5 Range Extender

1.1.5.1 Operating Frequency

– 2412

‐ 2462MHz

1.1.5.2 Communication Distance (unobstructed)

– 500

‐ 700m

1.1.5.3 Transmitter Power

– 20dBm

1.1.5.4 Power Consumption

– 2W10 | Page DJI INSPIRE 1 TECHNI CAL SPECIFICATIONS

Red Dog Aerial only utilizes safe and reliable UASs. DJI is an industry leader in small UAS production. DJI UASs

are loaded with ground breaking software enabling the user to set parameters which will not allow flight into

controlled airspace. Parameters can also be set to limit f light to no higher than a predetermined and set altitude as

well as limit flight to a predetermined and set distance. In addition, DJI software provides real-time altitude and

location information to the PIC via the linked monitor (smart phone/tablet devices)

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: 150 0 /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 0 F to 104 0 F (

‐ 10 0 C to 40 0 C)

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 camera)

– 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 Controllable Range

– Pitch:
‐ 90 0 to +30 0 ; Pan: ±320 0

2.2.2.7 Mechanical Range

– Pitch:
‐ 125 0 to 45 0 ; Pan: ±330 0

2.2.2.8 Max Controllable Speed

– Pitch: 120 0 /s; Pan: 180 0 /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”

2.2.3.9 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 0 F ‐ 104 0 F (0 0 C ‐ 40 0 C)11 | Page 2.2.4 Transmitter

2.2.4.1 Name

– 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 0 F to 104 0 F (

‐ 10 0 C to 40 0 C)

2.2.4.6 Battery

– 600mAh LiPo 2S



## No Privacy Issues

Red Dog Aerial’s proposed operations will creat e no privacy issues because the Phantom and Inspire UAS’s will be operating in rural areas within the boundaries of the properties with the land owner’s permission.

Red Dog Aerial will also obtain any permits or authorizations from local authorities when

necessary.12 | Page 

### Glossary of abbreviations

AGL Above Ground Level ALoS Acceptable Level of Safety

AMOC Alternative Me thod of Compliance
ASI Aviation Safety Inspector

ATC Air Traffic Control
ATCAA Air Traffic Control Assigned Airspace

ATS Air Traffic Service
AVS Aviation Safety
CFR Code of Federal Regulations

COA Certificate of Waiv er or Authorization
CRM Crew Resource Management

CS Control Station

CRS Certified Repair Station
DCP Divert/Contingency Point
DHS Department of Homeland Security

DME Distance Meas uring Equipment
DOD Department of Defense
DSA Detect, Sense, and Avoid System

FAA Federal Aviation Administration

FCC Federal Communications Commission
FARs Federal Aviation Regulations
FIR Flight Information Region
FL Flight Level
FSIMS Flight Standards In formation Management System

FTP Flight Termination Point
FTS Flight Termination System
Red Dog Aerial Red Dog Aerial Video Partners LLC
GHz Gigahertz

GCS Ground Control Station
MHz Megahertz
MTOW Maximum Takeoff Weight
NAS National Airspace System

NM Nautical Mile

NOTAM Notice To Airman
OPA Optionally Piloted Aircraft

PIC Pilot in Command
Phantom Phantom Unmanned Aircraft System

Phantom Phantom Unmanned Aircraft
R&D Research and Development
RF Radio Frequency13 | Page 

### RM Risk Management RNAV Area Navigation

RTB Return to Base
RVSM Reduced Vertical Separation Minimum
TAS Traffic Advisory Systems
TC Type Certificate

UA Unmanned Aircraft
UAS Unmanned Aircraft System(s)

UAV Unmanned Aerial Vehicle
VFR Visual Flight Rules

VMC Visual Meteorol ogical Conditions

VO Visual Observer