January 25,2016
U. S. Departmentof Transportation Docket Management

Operations West Building GroundFloor, Room Wl2-140 1200 New Jersey

Ave, SE Washington,

DC 20590 RE: SEBlueprint

Group,-Inc.'s

Requests An Exemption

From TheRequirements

of Title 14

of The Code Of Federal

Regulations

14C.F.R.Part2t;14 C.F.R.45.2J(fi;taC.F.R. 6t.ll3 

### (a) & (b);14 c.F.R. 9r.7 ({; 14 c.F.R. el.e(b) (\; M c.F.R.

qr.rbi;r+c.F.R.

er.r09; 14 c.F.R.9l.rt9;14

c.F.R. 9r.r2ri 14

c.F.R. 91.1s1 (a); t4 c.F,.R.

sr.20} (a)& (b); 14 c.F.R.91.40s

(a);14 c.F.R. 407 (a)(\; M c.F.R.

409 (a) (z);M c.F.R.

afi @)& (b) DearSir orMadam: Pursuant to section

333of the FAA Modemization andReform

Act of 2012

(theReform

Act) and14C'F'R' Part 11,

SEBlueprint,

Inc. ("SEBlueprint"

herein after), anohio Corporation

that provides information

management

services for construction

sites since1990,

hereby applies for an exemption

from the listed Federal Aviation Regulations

("FARs") to allow commercial operation

of its Small Unmanned Aircraft Systerns

("sUASs")for aerial photography and videography,

so long assuch

operations

are concluctecl

within and under

the conditions

outlined herein or asmay be established by the FAA asrequired

by Section

333. As detailed

in this document

and the attached

Manual, the requested

exemption

wouldpermit

the operation of sUAS under controlled

conditions

in airspace

thatis 1)limited

2) predetermined 3) controlled

as to access

and 4) would provide safety enhancements

to thealready

best practices safety protocols followed by SE Blueprint at each one of its sUAS photographysites. Approval of this exemption would thereby enhance safety and fulfili the Secretary of Transportation's

(the FAA Adrninistrator's) responsibilities

to "...establish

requirements

for the safe operation

of such aircraft systems in the national

airspace system." Section 333(c) of the Reform Act,

Thenames

and address of theapplicants

are as follows: Mr. KevinR.Anderson,

President Mr. Craig

J. Dziak, Vice president

of Operations SEBlueprint,Inc. 2035 Hamilton Avenue Cleveland,

Ohio44114 Telephone

(21 6) 241 -2250
Email : KevinQ)seb

luenrint.corn Email : crerisdg)sebluelrr:int.com

SE Blueprint Inc.'s Petitionfor 333 Exemption

### TABLE OF CONTENTS Page

GLOSSARY

OF ABBREVIATIONS... ..........3 REGULATIONS

FROM WHICH EXEMPTIONS

AREREQUESTED... ............3 suMMARy............... ...................4 INTRODUCTION

AND INTERESTS

OFPETITIONER... ,.,,....,.....4 BACKGROI_rND......... .,................4 FAA UAS REGISTRATION INFORMATION.

.... ..5 BASIS FOR PETITION........ .......5 NAMEANDADDRESS OFPETITIONERS..... ............6 THE SPECIFIC

SECTIONS

OF 14C.F.R.

FROMWHICH SEBLUEPRINT. INC. SEEKS EXEMPTION............ .........,........7 THE EXTENT

OF RELIEF

SEBLUEPRINT,

INC. SEEKS

AND THE REASON SE BLUEPRINT,

INC. SEEKS THERELIEF ..............10 THE REASONS

WHY GRANTING

SEBLUEPRINT,

INC.'S REQUEST

WOULD BEIN THE

PUBLIC INTEREST............ ,,..,12 THE REASONS

WHY GRANTING

THE EXEMPTION

TO SEBLUEPRINT,

INC.WOULD NOT ADVERSELY

AFFECT

SAFETY... ......................14 SUMMARY

THAT CAN BE PUBLISHED IN THE FEDERAL

REGISTEIT,,,.,.....,,....,,,,.25 ANY ADDITIONAL INFORMATION, VIEWS, ORARGUMENTS

AVAILABLE TO suPPoRT

SEBLUEPRINT,

INC. ,S REQUEST ........,..25 CONCLUSION........... ..................26 EXHIBITS ,....,,.27

SEBlueprint

Inc.'sPetitionfor 333

Exemption

### AGL

AOI ATC ATO AV CFR COA FAA FAR GCS GPS LOL NAS NOTAM PIC Section 333 SO SOP UA UAS VFR VLOS VMC VTOL GLOSSARY OF ABBREVIATIONS AboveGround

Level Areaof Interest Air Traffic Control Air Traffi c Or ganization AerialVehicle Code of Federal

Regulations Certifi cate of Authorization Federal AviationAdministration Federal Aviation Regulation Ground ControlStation Global Positioning

System Loss of Link National Airspace System Notice to Airman PilotIn Command FAA Modemizationand Reform Actof 2012

(FMRA) Safety Observer Standard Operating

Procedures Unmanned

Aircraft Unmanned

Aircraft Svstem Visual FlightRules Visual Lineof Site Visual Meteorological

Conditions Vertical Takeoff andLandins
Regulations

from whichthe exemption is requested:

14 C.F.R.

Part?l 14 C.F.R.4s.23(b) 14c.F.R.61.113

(a)& (b) 14 C.F.R.91.7(a) 14C.F.R.

el.e (b) (2) 14C.F.R.91.103 14 C.F.R.91.109 14 c.F.R.91.119 14C.F.R.9l.l2l 14 C.F.R. 91.1s1(a) 14 C.F.R. 9r.203(a) & (b) 14C.F.R.91.40s

(a) 14C.F.R.

a07@) (r) 14C.F.R.a0e@)(2) 14C.F.R.4r7 (a) & (b)

SE Blueprint Inc.'s Petitionfor 333 ExemptionSUMMARY

SE Blueprint, Inc. hereafter referred to as SE Blueprint, seeks exemption :[romthe requirements of 14 c.F.R Part21, gg 45.23(b), 61.113(a) & (b), 9t.7(a),9r.t2r,91.151(b), 91.405(a), 91.a07@)Q),9I'409(aX1) & (a)(2), and 91.417(a) & (b), to operatean UnmannedAircraft System(DJI Phantom3, Professional) pursuant

to Section333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit SE Blueprint, Inc. ro operare an Unmanned Aircraft System (UAS) for the commercial purpose of condur;ting aerial video and photography

of construction

project sites,

demolition sites,

both residential

and commercial

real estate, over certain

areas of the United States. INTRODUCTION AND INTERESTS OF THE PETITIONER SE Blueprint, Inc. has provided their clients (which include private sectorbusinesses and nonprofits, along with local state and federal agencies)with expertise and knowledge in project information management services to the Northeast Ohio architectural, engineering and construction

communitiesusing advanced technologies

and solutions. SE Blueprint, Inc. has worked in all typesof locations with a perfectclient and employee safetyrecord. The objective of SE Blueprint, Inc. and our Unmanned Aircraft System (DJI Phantom 3 Professional) aerial operations is to provide a more affordable, high-quality, visual mapping for a variety of governmental,

commercial,

public, and residential

uses, specifically

targetirrg:

. Enhanced

Safety and Security

on Construction

Sites ' Obtaining

Aerial Visualsfor Construction ProjectDesign Development ' Utilizing sUAS Technology to ExpediteInformationDissemination to Project Managers

and Project Staff

. Accurate

Visual Inspection

of Construction

Sites

. Accurate

Visual Inspection

of Demolition

. EconomicDevelopment

. Civic landmarks

. Aerial photography

. Aerial videography

FLIGHT EXPERIENCE Mr. Craig

J. Dziak,Vice President of Operations,

hashoned

his flight skills bv utilizingthe Phoenix RC Pro Simulator,

for threeyears. In addition to flight simulator,

Mr. Dzialk

is a radio controlled helicopter

pilotwiththe

Academy

of Model

Aeronautics,

since 2013, Member Number#

1032038. BACKGROUND Unmanned

Aircraft Systems:

DJI Phantom

3 Professional.

UAS SE Blueprint, Inc. seeks an exemption to operate DJI Phantom 3 Professional system for compensation,

or hire, within the NAS. The DJI Phantom 3 Professionalis vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronictablet or smart phone systems. The DJI Phantom3 Professionalhas a maximum gross
SE Blueprint Inc.'s Petitionfor 333 Exemptionweight of approximately 2.8Ib. while having a diagonal dimension

of 23.2",a maximum speed of approximately 16 m/s and a maximum flying height of 400'. The DJI phantom 3 professional is equipped

with four main rotors;driven by Lithium Polymerbattery powered

electric motors. FAA UAS REGISTRATION INFORMATION The DJI Phantom 3 Professional that will be operated by SE Blueprint, is registered in accordance

with 49 U.S.C. 44103, Registration

of Aircraft, aswell as 14 C.F.R ParI 47, Aircraft Registration,andmarked in accordance with 14 C.F.R. Part 45, Identfficationand Registration Marking (Copy of FAA UAS Certificate is attached heretoand marked as Exhibit A). The UAS registration

and serial

numberis asfollows:

Model: Phantom3 Professional Serial Number: P76DCG0 6010449 FAA Registration: FA34MTPYT3 BASIS FOR PETITION Petitioner,

SE Blueprint, Inc., pursuant to the provisions

of the Federal

Aviation Regulations

(14 C.F.R. $ 11.61)

and the FAA Modemization and ReformAct of 2012 (FMRA), Section 333, Special Rulesfor Certain Llnmanned Aircraft Systems,

hereby petitions the Administrator to commerciallyoperate

the DJI Phantom3 Professional, UAS in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R $$ 61.113(a) & (b), 91.7(a), 

### 91.r2r,91.1s1(b),91.405(a), 9r.a07@)Q),9t.409(a)(1)

& (a)(2),and

91 .aw@) & (b). In consideration

of the speed,weight, size, and limited operating area associated with the unmannedairclaft"

and its operation, SE Blueprint, Inc. operation of DJI Phantom 3 Professional UAS meets

the conditions

of FMRA Section

333 andtherefore,

will not requirean airworthiness certificate

in accordance

with 14 C.F.R.PartZI, Subpart H. Accordingly, SE Blueprint, Inc. requests relief from Sections 9lzl05(a), 91.407(a)(I), 91.a09@)Q) e' @)(2), and 91.a17@)& (b), as these sections set forth requirements for maintenance

that only apply to aircraft with an airworthiness certificate. SE Blueprint, Inc. submits that the requested relief is proper since an equivalent level of safety will be ensured.

SE Blueprint, Inc. will use experienced personnel

or technicians

to perform maintenance,

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

prescribed

in the operating

documents

(i.e., Monthly Maintenance Log, and D.II Phantom 3 ProfessionalInstruction Manual). Furthermore,SE Blueprint, Inc. will documentand maintain all maintenance recordsfor the DJI Phantom3 professional UAS. Relief from certain requirements of Section61.113(a)

and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested

by SE Blueprint, Inc. to the extentnecessary to allow a Pilot in Command (PIC) holding a private pilot or higher level cert;ificate, and who has demonstrated,

by meeting minimum flight- hour and currency requirements, that the PIC is able to safely operatethe DJI Phantom UAS in a manner consistentwith this exemption, including
SE Blueprint Inc.'s Petitionfor 333 Exemption

### evasive

and'emergency

maneuvers

and maintaining

appropriate

distances from people,

vessels, vehicles andstructures. SEBlueprint

seeks relieffrom SectiottgI.T(a), entitled Civil aircraftairworthiness, because the DJI Phantom

3 Professional

UAS do not require

an airworthiness

certificate

in accordance

with 14 C.F.R.

Part 21, Subpart

H, As such,

SE Blueprint,Inc. submits thattheywill ensure

thatthe DJI Phantom3 Professional UAS is in an airworthy condition, prior to every flight, by determining

that the UAS is in compliance with the operatingdocuments (i.e., Monthly Maintenance

Log, and DJI Phantom

3 Professional

Instruction

Manual), and thatthe aircraft

arc in a condition

for safe flight. ThePhantom

3 Professional

manual is located

at: http://tinyurl"com/z28nuu6 SE Blueprint,

Inc. alsoseeks

an exemption

from the requirements

of Section

gl.l2l, entitled AltimeterSettings,

as the DJI Phantom

3 Professional

UAS will not have atypical barometric altimeter onboard. However,

altitude information

of the DJI Phantom

3 Professional

UAS will be provided to the PIC via GlobalPositioning System (GPS) equipment

andradiocommunications telemetry

data link, which downlinks

from the UA to the GCS for active

monitoring

of theflight path. This altitude

information,

combined

with SEBlueprint,

Inc. operation

of the DJI phantom

3 Professional

UAS within visual

line of sight,

at or below400 feetAGL, will ensure a levelof safety equivalent

to Section

9l.l2l. Additionally,

SEBlueprint,

Inc.seeks

anexemption

fromtherequirements

of Section

91 .151(b), entitledFuel requirements for flight in VFRconditions. SE Blueprint,Inc. submits that safety will not be affected

by operation

of the DJI Phantom

3 Professional

UAS duringdaylighthours in visualmeteorological

conditions

(VMC) under

visualflight rules(VFR),with enough battery power to fly for a total duration of approximately

23 minutes. Battery

povyer indicators

arealso ableto show exactlyhow much batterypower is left, as well as how muchtime is needed to retumsafely

back to point of take-off. In accordance

with 14 C.F.R.

$ 11.81, SE Blueprint,

Inc. provides

thefollowinginformation in support of its petition

for exemption:

A. Name,

Address,

Telephone

Numbers,

& Email of the petitioners. Thenames

and addresses

of the Petitioners

and point of contact

are: Mr. Kevin R. Anderson Mr. Craig

J.Dziak SEBlueprint,Inc. 2035Hamilton

Avenue Cleveland,

Ohio 44II4 Telephone

(21 6) 241 -2250
Email : I(ev inG)sebiueprinl."

com Email : LjraiS(pseblueprint.com
SE Blueprint Inc.'s Petitionfor 333 ExemptionB. The Specific Sections of 14 C.F.R. From Which SE Blueprint, Inc. Seeks Exemption. 1. SE BlueprintoInc. 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) IJxcept

as provided in paragraphs (b) through (h) of this section, no person

who holds a private pilot certifi catemay act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person,for compensation

or hire, act aspIC of an aircraft. (b) A private pilot may, for compensation or hire, act as t,IC of an aircraft in connection

with any business

or employment if_- (i) The flight is only incidental to that business

or emproyment;

and (2) The aitqaft doesnot caffy passengers or property for compensation or hire. 2. SE Blueprint, Inc. Seeks Exemption f,'rom The Requirements Of Sect:ion 91.7(a). Section 91.7

, entitled Civil aircraft airworthiness, subsection (a), states

the following: (a) No personmay operate a civil aircraftunlessit is in an airworthy condition. 3. SE Blueprint, Inc. Seeks Exemption From The Requirements Of Section gl.I2l. Section 9I.12I, entitled

Altimeter settings,

subsection

(a), states

the following, in part: (a) Each personoperatingan airqaft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating-, (1) Below 18,000

feetMSL, to-- (i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the airc.l:aft (ii) If there is no stationwithin the area prescribed

in paragraph

(a)(1)(i) of this section,the current reported altimeter setting of an appropriateavailable station; or (iii) In the caseof an aircraft not equippedwith a radio, the elevation of the depafiureairport or an appropriate altimeter setting availablebefore deparlure.

4. SE Blueprinto

Inc. Seeks

Exemption From The Requirements Of Section

91.151(b). Section 91.15 1, entitledFuel requirements for flight in VFR conditlors, subsection
SE Blueprint Inc.'s Petition for .3.3 3 Exemption(b), states the following: (b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind andforecast weather conditions) there is enough fuet to fly to the first point of intended landing and, assumingnormal cruising speed,to fly after that for at least 20 minutes. 5. SE Blueprint,Inc. Seeks Exemption From The RequirementOf Section 91.405(a). Section91,405,

entitledMaintenance

required,subsection

(a), states

the followins: Each owner or operatorof an aircraft- (a) Shall have that aircraft inspectedas prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) of this section, havediscrepancies

repaired asprescribed

in part 43 of this chapterf.] 6. SE Blueprinto Inc. Seeks Exemption From The Requirements Of Section91.a07(a)(1) Section 9I.407, entitled Operation afier maintenance, preventive maintenance, rebuilding,or alteration,subsection (a)(1),states

the following: (a) No person may operate any airqaft that has undergonemaintenance, 

### maintenance,

rebuildin g, or alter ation unle s s- - (1) It has been approved for retumto service

by a person of thischapter[.] authorized under $ 43.7

7. SE Blueprint, Inc. Seeks Exemption

X'romThe Requirements Of Sections

91.a09(a)(l) And 91.409(a)Q). Section 9t.409, entitledInspections, subsection

(a), states

the following: (a) Except as provided in paragraph (c) of this section, no person may operate an arqaftunless, within the preceding 12 calendar months, it has had -- (1) An annual inspection in accordance with part 43 of this chapterand has been approved

for return to serviceby a person authorizedby $ a3.7 of this chapter;or (2) An inspection for the issuanceof an airworthiness certificate in accordance with part 21 of this chapter.

8. SE Blueprinto Inc. SeeksExemption from the Requirements of Sections91.417(a) And 

## 9r.4r7(b). Section 9L4I7, entitled Maintenance records, subsections(a) and (b), state the following: preventive

SE Blueprint Inc.'s Petitionfor 3.33 Exemption(a) Exceptfor work performedin accordance with $$ 91.41

1 and g14l3, eachregistered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Recordsof the maintenance. preventive maintenance, and alteration and recordsof the 100-hour,

annual,progressive,

and other required or approvedinspections, as appropriate, for each airqaft (including the airframe) and each engine,propeller, rotor, and appliance of an aircraft. The recordsmust include_

(i) A description (or referenceto data acceptable to the Administrator) of the work performed; and (ii) The dateof completion of the work performed; and (iii) The signature,and certificate number of the person approving the aircraft for return to service. (2) Recordscontainingthe following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor. (ii) The current statusof life-limited parts of each airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul of all items installed on the afuqaftwhich are required to be overhauled

on a specified

time basis. (iv) The current inspection statusof the afucraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances

are maintained. (v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action,the time and datewhen the next action is required. (vi) Copies of the forms prescribed by g a3.9(d) of this chapterfor each major alteration to the airframe and currently installed engines, rotors, propellers,and appliances. (b) The owner or operatorshall retain the following recordsfor the periods prescribed: (1) The records specified in parugraph(a)(1) of this section shall be retained until the work is repeated

or superseded

by other work or for I yearafter the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retained and transferred

with the ahcraft at the time the airqaftis sold.

SE Blueprint Inc.'s Petitionfor 333 Exemption(3) A list of defects furnishedto a registered owner or operatorunder $ 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved fbr return to service. C' The Extent of Relief SE Blueprint, Inc. Seeks And The Reason SE Blueprint, Inc. Seeks The Relief. 1' Extent of Relief SE Blueprint, Inc. SeeksAnd The Reason SE lllueprint, Inc. Seeks Relief From Section

61.113(a)

And (b;. Relief from Section61.113(a) and (b) entitled Private pilot privileges and limitations; pilot in command,

is requested

to the extent necessary to allow a PIC holding a private pilot or higher level certificate, as well as a cument and valid airman medical certificate, and who has met certain flight-hour and currency requirements, to conductthe proposedUAS flight operations for compensation

or hire. This relief is requested sincethe limitations set forth in Section61.113(a) and (b) state

that a private pilot may, for compensationor hire, act as PIC of an aircraft in connection with any business or employment

if: (1) The flight is only incidental to that business

or employment;

and (2) The aircraft

does not carrypassengers

or property

for compensation

or hire. As setforlh more fully below, SE Blueprint, Inc. submits that anequivalent level of safety

will be maintained

because no PIC will be allowed to operate the DJI Phantom3 profbssional UAS unless that PIC has met certain flight-hour and curency requirements,demonstrating that the PIC is ableto safely operate eitherthe DJI Phantom 3 Professional

UAS in a mannerconsistent with the operations specificationsas described in this exemption, including evasive and emergencymaneuvers,as well as maintaining appropriatedistancesfi:om people, vessels, vehicles and structures. Further, SE Blueprint, Inc. submits that all flights of the DJI Phantom 3 professional UAS, conducted

by the PIC pursuant

to the grantof this Petition:(1) will be incidental to SE Blueprint, Inc' business;

and (2) will not cary passengers or property

for compensation

or hire.

2' Extent Of Relief SE Blueprint, Inc. SeeksAnd The Reason SE Blueprint, Inc. Seeks Relief From Section 91.7(a). Relief from Section 91.7(a) entitled,Civil aircraft airworthiness, is requestedto the extent requiredto allow SE Blueprint, Inc. to determine that the DJI Phantom3 professionalUAS are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating

documents

(i.e', SE Blueprint, Inc. Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom3 Professional Instruction Manual). SE Blueprint' Inc' seeks the requested

relief because

the DJI Phantom

3 Prof'essional

UAS do not requirean airworthiness certificate

in accordance

with 14 C.F.R. Part2I, Subpart H. Therefore, SE Blueprint, Inc. will ensure that the DJI Phantom 3 Professional UAS are in airworthy condition basedupon its compliance with the operating documents (i.e., Monthly Maintenance
1 0 SE Blueprint Inc.'s Petitionfor 3:13 ExemptionLog, and DJI Phantom 3 Professional) prior to every flight, and further, determine that the

aitcraft are in condition for safeflight, as statedin the conditions and limitations below.

3' Extent Of Relief SE Blueprint, Inc. SeeksAnd The Reason SE Blueprint, Inc. Seeks Relief From Section 9l.l}l. Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations

of the DJI Phantom

3 Professional

UAS, which utilize abarometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PIC at the ground control station (GCS). Sincethe FAA requires that any altitude information concerning UAS operations be reportedto air traffic control (ATC) in feet abovegroundlevel (AGL), SE Blueprint, Inc. seeks the requested

relief because

the DJI Phantom 3 ProfessionalUA's altimeter may be set on the ground to zerofeet AGL, rather than the local barometricpressure or field altitude, before eachflight. considering

the limited altitudeof the proposed operations,

relief from 14 (lFlt 91.121is sought to the extent necessary to comply with the applicableconditions and limitations stated below. As more fully set forth herein, an equivalent level of safety will be maintained since the D;I Phantom 3 Professional UAS are equipped with a barometric pressu,resensor and GpS equipment,which automatically ensuresthat a ground level pressuresetting will be established prior to each flight, and provides the PIC with altitude information of the UA on the heads-up displayof the GCS.

4. Extent Of Relief SE Blueprint, Inc. SeeksAnd The Reason SE Blueprint, Inc. Seeks Relief From Section

91.151(b). Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to allow flights of the battery powered DJI phantom 3 Professional

UAS during daylight hoursin visual meteorological conditions

(VMC), under

visual flight rules (VFR), for a total durati on of 23 minutes.

SE Blueprint, Inc. seeks the requested

relief because without an exemptionfrom Section91.151(b), the flight time duration of the battery powered DJI Phantom 3 ProfessionalUAS will severely constrain the practicality of any aerial video or still photo flight operations that SE Blueprint, Inc. proposes to conLduct

pursuantto this Petition. Significantly,

as set forth below, the technical specifications

of the DJI Phantom

3 professional UAS, the DJI Phantom3 Professional operatingdocuments,

and SE Blueprint, Inc. proposed operating limitations, ensure that SE Blueprint, Inc. will safely operatethe battery powered DJI Phantom

3 Professional

UAS during daylight hours in visual meteorologica.l conditions(VMC), under visual flight rules (VFR), with enough battery power to fly for a total duration of 23 minutes.

l l SE Blueprint Inc.'s Petitionfor 333 Exemption5' Extent of Relief SE Blueprint, Inc. SeeksAnd The Reason SE lllueprinto Inc. Seeks

Relief From sections

91.405(a),

91.a07@)(r),91.409(aX1) & (a)(2),And 91.417(a) & (b). since Sections

9r.405(a),9r.a07@)(r),9r.409(a)(1) & (a)(2), and.9r.afi@) & (b) only apply

to aircraft with an airworthiness ceftificate, SE Blueprint, Inc. requestsrelief from these Sections because the DJI Phantom3 Professional UAS do not require airworthiness certificates.

As set forth more fully below, the DJI Phantom 3 Professional UAS meets the conditions of FMRA Section 333 for operation without an airworlhiness certificate. Accordingly, SE Blueprint, Inc. will use trained techniciansto perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques,and practices prescribed in the UAS operating documents

(i'e., the SE Blueprint, Inc. Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Professional Instruction Manual). Furthermore, SEi Blueprint, Inc. will documentand maintain all maintenance recordsfor the DJI Phantom3 prof'essional UAS.

D' The Reasons Why Granting SE Blueprint, Inc. Request Woulcl Be In The public Interest; That Is, How It would Benefit The public As A whole. Granting the present Petition will further the public interest by allowing SE Blueprint, Inc. to safely, efficiently, and economically perform aerialvideo and photography of construction

sites, real estate,

events andcivic landscape

over ceftainareas

of the United States. Additionally, useof the DJI Phantom 3 Professional

UAS will decrease

congestion

of the NAS, reducepollution, and provide significant benefitsto the economy.Notably, the benefitsof SE Blueprint, Inc.'s proposed operation

of the DJI Phantom3 Professional UAS will be realized without implicating any privacy issues.

1.The Public will Benefit From Decreased congestionof rhe NAS. The DJI Phantom 3 Professional UAS is battery powered and serves as a safe, efficient, and economical alternative to the manned atcraft traditionally utilized to obtain aerialimagery. By reducing the amount of manned aircraft needed to perform aeial acquisitions, an exemption allowing the use of a DJI Phantom 3 Professional UAS would reduce the amount of manned aitctaft in the NAS, reduce noise and air pollution, as well as increasethe safety of life and property in the air and on the ground. Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports causedby arriving and departing aircraft will be reduced. The DJI phantom 3 ProfessionalUAS do not require an airport to takeoff or land. Likewise, a reduction of manned aitcraft conducting aerial video and photography missions would result in fewer air*aft that must be handled by air traffrc control during the ground, takeoff, departure, arrlal, and landing phases of flight operations.

I 2 SE Blueprint Inc.'s Petitionfor 3.33 Exemption2' The Public Will Benefit From The Safety And Efficiency Of The DJI phantom 3

ProfessionalUAS. Conducting aerial acquisitions with the DJI Phantom 3 Professional UAS, instead of manned aircraft,will greatly benefit the public by drastically reducingthe levels of air and noise pollution generated

during traditional aerialvideo and still photographyflight operations. By using battery power and electric motors, the DJI Phantom3 Professional UAS producesno air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder intemal combustion engine ahcraft that are typically utilized for aerial video and photography, while burning approximately20-30 gallons per hour of leaded aviation fuel. The DJI phantom 3 Professional

UAS, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAS are propelled by battery powered electric motors, rather than an internal combustion

engine. By using the DJI Phantom 3 Professional UAS to perform aerial acquisitiorLs,

the substantial

risk to life and property in the at and on the ground, which is usually associated with traditional mannedaircraft

flight operations,

will be substantially

reduced or completelyeliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI phantom 3 Professional

UAS (weighing approximately 2.8 pounds at their maximun gross weight with diagonaldimensionof 23.2 inches, and with no fuel on board), has less physical potentialfor collateral damageto life and property on the ground, and in the air, comparedto the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan

of approximately

42 feet, alengthof 34 feet, and, afuel capacity

of 180gallons). 3. Performing Aerial Video and Photography Operations With The DJI phantom 3 Professional

UAS Will Benefit The Economy. In addition to being safe and efficient, the DJI Phantom 3 Professional UAS are also an economical alternative to using manned aftcraft to conduct similar aerraloperations.As such, operation

of the DJI Phantom

3 Professional

UAS will allow United States based companies,

like SE Blueprint, Inc., to remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency ("EPA") regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies

must adopt new and altemative technology in order to remain competitive. Operating the battery powered DJI Phantom 3 Professional UAS is one such techrrology that not only allows companies

greateroperationalflexibility compared to manned aircraft,but provides such flexibility without the high operationalcost of a traditional manned aftcraft. By operating

the DJI Phantom3 Professional UAS, companies

such as SE Blueprint, Inc., can remain competitive and profitable, and therefore, provide greaterjob stability to employees and contractors,

which will ultimately contribute to growth of the U.S. economy. Improved financial performance

of U.S. companies,

through commercial use of the DJI Phantom 3 professional UAS, providesa stable workforce that increases consumer

spending;

improveslocal, state,

and federal tax revenues;and allows companiesto invest in researchand development in order to remain competitive both in the United States and abroad.

13 SE Blueprint Inc.'s Petitionfor 3J3Exemption4. There Are No Privacy Issues.

Similar to the manned aerialacquisition flight operations that have been conclucted fbr decades, SE Blueprint, Inc. proposed operation

of the DJI Phantom

3 Professional

UAS will not implicate any privacy issues'

Specifically,

the DJI Phantom3 Professional UAS wi.tl be operated only in compliance with operating documents (i.e., SE Blueprint, Inc. Aerial Operations Mamral, Monthly MaintenanceLog, and DJI Phantom 3 ProfessionalInstruction Manual) which requires property owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 

### c.F.R. $91.119.

E' The ReasonsWhy Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Level of Safety At Least Equ:rl To That provided By The Rule From which sE Brueprint,Inc. seeks Exemption. 1' Reasons

Why The DJI Phantom 3 ProfessionalUAS Meet The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) section 333. In consideration

of the size, weight, speed,and limited operatin g areaassociated

with the unmanned aituaft and its operation, SE Blueprint, Inc. operation of the DJI phantom 3 Professional UAS meet the conditions of FMRA Section 333, and will not require an airworthiness

cefiificatein accordance with 14 c.F.R. part2l, Subparl H. Section 333 providesauthorityfor a UAS to operate without airworlhiness

cefiification and sets forth requirements

for consideringwhether a UAS will create ahazard,tousers of the NAS or the public, or otherwise

posea threat

to national

security.

Specifically,

FMRA Section

333 states

the following, in part:

(a) In General.--Notwithstanding any other requirement of this subtitle, and not later than 180days after the date of enactment of this Act, the Secretoryof Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace systembefore completion of the plan and rulemaking required by section 332 of thisAct or theguidance requiredby section

334 of thisAct. (b) Assessment

of (Jnmanned

Aircraft Systems.--In

making the determination under subsection

(a), the Secretary

shall determine,

at a minimum-- (l) which types of unmanned aircraft systems,

tf any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areqs,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 certfficate of waiver, certificate of authorization, or airworthiness certffication under section 44704 of title 49, United States



### t 4 SE Blueprint Inc.'s Petitionfor 3J3Exemption

## lXlf;f"ii{i![,i3r the operation of unmanned

air*aftsvstems

identffied
(c) Requirements

for Safe Operation.--If the Secretary determinesunder this section that certain unmannedaircraft 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 airspacesystem. In seekingthis exemption, SE Blueprint, Inc. submits that the DJI phantom 3 profbssional UAS can operatesafely in the NAS pursuantto FMRA Section 333, as demonstrated by: (a) the characteristics

of the DJI Phantom3 Professional uAS; (b) the pilot certificationrequirement; and (c) the specific

operating

limitations. a' The Specifications

Of The DJI Phantom 3 ProfessionalUAS Demonstrate Its Safe Characteristics. The DJI Phantom3 Professional UAS doesnot create ahazafi.to usersof the NAS or the public, or otherwise

pose atbreatto national security considering

its size, weight, speed,

and operational capability. i. Technical Specifications Of The DJI Phantom 3 ProfessionalUAS. The technical specifications of the DJI Phantom 3 Professional UAS are set forth by the DJI Phantom3 Professional User Manual, attached hereto asAppendix A. ii. The DJI Phantom 3 ProfessionalUAS Global Positioning Modes Enable The UAS To Remain Within A Defined Operational Area. The DJI Phantom

3 Professional

UAS may be operated in both manual and global positioning flight modes.

A complete

description

of the flight and navigational modesof the DJI phantom3 Professional

UAS is provided at pages 11 of the DJI Phantom 3 Professional User Manual attached hereto asAppendixA. iii. The DJI Phantom 3 ProfessionalUAS Is DesignedFor Automatic Return To Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation. When the Control Link is lost, the DJI Phantom 3 ProfessionalUAS will remain stationary, in flight, for 3 seconds

or more. If, after 3 seconds, the DJI Phantom

3 professional

UAS doesnot reacquirecontrol link data from the GCS, the UAS will assume that the Control Link is lost and the will retum to the home position (i.e.,failsafemode)via GPS,and will descend to the takeoff position and shutdown. A complete

description

of the Failsafe

Functions

of the DJI Phantom

3 profbssional

UAS are set forth at pages 12 through 14 of the DJI Phantom 3 ProfessionalUser Manual, attached hereto as Appendix A.

l 5 SE Blueprint Inc.'s Petitionfor 333 Exemptioniv. The DJr phantom 3 professionarGCS And rts operation.

A complete description of the operation and specifications of the DJI phantom 3 professional UAS and flight control software is provided at pages 23 through 29 of the DJI phantom 3 Professional User Manual. DJI Phantom 3 Professional User Manual is attached hereto as AppendixA. b' Flight Operations of DJI Phantom 3 ProfessionalUAS Is Limited To The Line Of Sight of A certificated Pilot in command with A safety observer. SE Blueprint, Inc. video productionstaff will be the only persons ro act as a pilot in command (PIC) of the DJI Phantom 3 Professional

uAS. Additionally, a safbtyobserver will assist

him at all timesduringflight time. c' Flights of DJI Phantom 3 ProfessionalUAS Witl Be Conducted pursuant To Specific Operating Limitations. In seeking

this exemption,

SE Blueprint, Inc. proposes to commerciallyoperate DJI phantom 3 Professional UAS for the special purpose of conducting aerial video and photography over certain areas

of United States,

pursuant to the following specific operating limitations. 1' operationsauthorized by this grant of exemption will be limited to the following aircraft described

in the operating

documents,

rotorcraft UAS weighing lessthan 55 pounds maximum gross weight: DJI Phantom 3 Professional Unmanned Aircraft Systems.

Proposed

operations

of any other aircraft will require a new petition or a petition to amend

this grant. 2' UAS operations

under this exemption

will be limited to conducting operations

for the purposeof aerial video ancl photography. 3' The UAS may not be flown at an indicated airspeed exceeding

20 knots. 4' The UA must be operated at an altitude of no more than 400 feet above ground level (AGL), as indicatedby the procedures specifiedin the operating documents

unlessa special request is madeand approved by ATC. All altitude, ,.port.d to ATC must be in feetAGL. 5' The UAS must be operated within visual line of sight (vLoS) of the pIC at all times' This requires

the PIC to be able to use human vision unaidedby any device other than corrective lenses, as specifiedon the PIC's FAA-issued airman medical certificate. 6' The use of first person view (FPV) by the PIC or safety observer(SO) is not permitted.
7' AII operations

must utilize a safetyobserver (SO). The SO may be usedto satisfy the VLoS requirement as long asthe PIC alwaysmaintains VLOS capability.

The SO and PIC must be able to communicate verbally at all times. Electronicmessaging or texting is not permitted during flight operations.The PIC must be designated before T6 SE Blueprint Inc.'s Petitionfor 333 Exemptionthe flight and cannot transfer his or her designationfor the duration of the flight. The PIC must ensurethat the SO can perform the functions prescribed in the operating documents. 8' The SO must not perform any other duties beyond assisting the PIC with seeing

and avoiding other air traffic and other ground based obstacles/obstructions and is not permittedto operate

the camera

or other instruments. 9. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations containedin the grant of exemptiontake precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator's responsibility to track such revisions and present updated and revised documents

to the Administrator upon request. The operator must also presentupdated 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 grantedthe exemption,then the operator must petition for amendment

to its grant of exemption. The FAA's UAS IntegrationOffice (AFS-80) may be contacted if questions arise regarding updates or revisions to the operating documents. 10. Prior to each

flight the PIC must inspect the UAS to ensure

that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operatinguntil the necessary maintenance

has beenperformed and the UAS is found to be in a condition for safeflight. The Ground Control Station must be included in the preflight inspection. All maintenanceand alterations

must be properly documented in the aircraftrecords. 11. Any UAS that has undergone maintenanceor alterations that affect the UAS operation or flight characteristics,e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conductsthe functional test flisht must make an entry in the afuqaftrecords. 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 operatingdocuments. 13. The operator must follow the UAS manufacturer's aircraftlcomponent, 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 statusof replacement/overhaul componentparts must be noted in the

l 7 SE Blueprint Inc.'s Petitionfor 333 Exemption

### afuctaft ecords, includingtotal time in service, description

of work accomplished, and thesignature

of the authorized

person returning the UAS to service. ---:
15' Each UAS operated underthis exemption

must comply with all manufacturer Safety Bulletins. 16' The authorized

person mustmake

an entryin the airqaftrecord of the corrective action taken against discrepancies

discovered

between inspections. 17'ThePIC 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 pIC meets

the operator's

qualificationcriteria and demonstrates the ability to safely operate the UAS in a manner

consistent

with howthe UAS will be operated under the exemption, includingevasive

and emergency

maneuvers

and maintaining

appropriate

distances from persons,

vessels, vehicles andstructures.

PIC qualificatio" nignt hoursmustbe logged in a manner

consistent

with 14 C.F.R.

$ 61.51(b).

Flights for thepurposes

of training the operator's pICs are permitted under tlr" trr-, of the exemption. However, training operations may only 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 pIC must operate the UA with appropriate distance from nonparlicipants

in accordance

with 14 c.F.R. g 91.119. 19. UAS operations

maynot beconducted

uring night, as defined in 14c.F.R.$ 1.1. All operations

mustbe conducted

under visual meteorological

conditions

(VMC). If flight at night is required, a special request will be made

at theIrAA office closesr to proposed area of operations.

Flights under special visual flight rules

(SVFR) arenot authorized. 20' The UA may not operate within 5 nautical

miles of an airportreference point as denoted on a curent FAA-published aeronautical

chart unless

a letter of agreement with that airport's management is obtained,and the operationis conducted in accordance

with a NorAM as required by the operator,s

coA. The letter of agreement

with the airportmanagement mustbe made

available to theAdministrator uponrequest. 21' The UA may not be operated less than 500 feet belowor less than2,000

feet horizontally

from a cloudor when

visibility is less

than3 statute

milesfrom thepIC. 22'If theUA loses

communications

or loses its GPS signal, itrnustreturn

to apredetermined

locationwithin the planned operatingareaand,land or be recovered

in accordance

with the operating

documents. 23 ' ThePIC mustabort

theflight in the event

of unpredicted

obstacles or emergencies in accordance

with the operating

documents.

l 8 SE Blueprint Inc.'s Petitionfor 333 Exemption24' The PIC is prohibited from beginning a flight unless (considering wind and forecastweather conditions) there is enoughpower to fly at nomal cruising speed to the intendedlanding point and land the UA with 25yobatterypower remaining. 25' The operatormust obtain an Air Traffic Organization(ATOr) issuedCertificate of Waiver or Authorization (COA) prior to conducting anyoperations under the grant of exemption'This COA will also require the operator to request

a Notice to Airman G\IOTAM) not more than72 hours in advance, but not lessthan 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 lwel anj 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. pafi 47,and have identification(NNumber) markings in accordance with 14 C.F.R. part 45,SubparlC. Markings must be aslargeaspracticable. 27' Prior to conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the FederalCommunications Commission (FCC) or other appropriate government

oversight agencyrequirements. 28. The documents

required fewer than 14 C.F.R. 91.9 and 91.203 must be avallable to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made available to the Administrator or anv law enforcement

official upon request. 29. The UA must remain clear and yield the right of way to all manned aviation operations

andactivities

at all times. 30. The UAS may not be operated by the PIC from any moving device or vehicle. 31. Flight operations

must be conducted

at least 500 feet frorn all nonparticipating persons (persons

other than the PIC, SO, operatortrainees or essential persons), vessels, vehicles,

and structures

unless:

a. Barriers or structures are present that sufficiently protect nonparticipating personsfrom the UA and/or debris in the event of an accident. The operator must ensurethat nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such proiection and are within 500 feet of the UA, flight operations must cease

imrnediatelyand,lor; b. The airuaft is operated near vessels, vehicles or structures where the owner/controller

of suchvessels,

vehicles or structures

has granted

permission and the PIC has made a safety assessment of the risk of operating closer to thoseobjectsand determined that it doesnot presentan un<lue hazard, and;
c. Operations

nearer to the PIC, SO, operator trainees or essential

persons do not present

an undue

hazard to those persons per $ 91.1

19(a).
I 9 SE Blueprint Inc.'s Petitionfor 333 Exemption32' All operations shall be conducted

over private or controlled-access properly with permission from the land owner/controller or authorizedrepresentative. 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 lateralor vertical boundaries

of the operationalareaas defined by the applicable COA must be reported to the FAA's UAS IntegrationOffice (AFS-80) within 24 hours. Accidentsmust be reported to the National Transportation Safety Board (NTSB) per instructions contained

on the NTSB Web site:www.ntsb.sov.

2' Reasons

Why An Exemption From The RequirementsOf Section dl.fl3(a) And (b) Would Not Adversely Affect Safety. SE Blueprint, Inc. submitsthat the equivalentlevel of safety established by Section 61.113(a) and (b) will be maintained becauseno PIC will be allowed to operate i6. ol phantom 3 Professional UAS unless that PIC has demonstrated,by meeting minirnum flight-hour and cuffency requirements,that the PIC is able to safely operate the DJI phantom 3 professional UAS in a manner consistentwith the exemption, including evasive and emergencymaneuvers andmaintaining

appropriate

distances

from people,

vessels, vehicles and structures. ConsideringSE Blueprint, Inc. proposed area of operations,

and the operatinglimitations set forth-above; the parallel nature of private pilot aeron auticalknowledge requirements to those of commercial

pilot requirements

(SeeExemptionNo. 1 1062); and the airmanship

skills necessary to safely operatethe DJI Phantom 3 Professional UAS, SE Blueprint, l.nc. submits that the additional manned airmanship experienceof a commercially certifical.ed pilot would not coffelate to the airmanship skills necessary for SE Blueprint, Inc. sper:ific proposedflight 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 thosepresented

herein (e.g. Exemption Nos. 11062,11063,

11064,11065,11066,11067,110g0,1110t,11110, tr112,11t36,1113g,11150, 11153, 11156, 11159, 11159, 11160, 11161). SE Blueprint, Inc. will not allow any PIC to operate the DJI Phantom

3 professional

UAS unless that PIC has demonstrated, by meeting minimum flight-hour requirements or the DJI phantom 3 ProfessionalUAS training and curency requirements, that the PIC is able to safely operatethe DJI Phantom 3 ProfessionalUAS in a manner consistent with this exemption, including evasive and emergencymaneuvers and maintaining appropriatedistances from people, vessels,

vehicles and structures. Specifically,

the PIC must haveaccumulated and logged,

in a marmer

consistent

with 14 C.F.R.$ 61'51(b),25 hours of total time as a UAS rotorcraftpilot (with a minimurn of 5 hours of those hours as a UAS pilot operating the same

make and model of uAS to be usedfor operations under

20 SE Blueprint Inc.'s Petitionfor 333 Exemptionthe exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding

90 days(for currency

purposes). As in ExemptionNos. 11062, 11138, and 11153,

prior documented

flight experience

that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during SE Blueprint, Inc. proposed operations.

The Administrator has held that prior documented flight experience

that was obtained in compliancewith applicable regulationswould ensuresafe operations,

stating asfollows: In Exemption No' 11062,the FAA required that prior to conducting operationsfor the purposeof motion picture filming (or similar operations), the PIC must have accumulated and logged,

in a manner

consistent

with 14 cFR 61.51(b),25 hoursof total time as a UAS rotorcraftpilot including at least 10 hours loggedas a UAS pilot with a multi-rotor UAS. Prior to operations under Exemption No. 71062, the I,IC must also have accumulated

and logged a minimum of 5 hours as a UAS pilot operatingthe samemake and model of UAS to be used for operationsunder the exemption. For clarification, the FAA considers

these minimum hour requirements to be inclusiveral;her

than additive;i.e. 5 hoursmakeand modeltime may be includedin the 10 hoursof multi-rotor time andthe 10 hoursmay be includedin the total25 hoursof UAS rotorcrafttirne. In additionto the hour requirements,

the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for cumency purposes). The FAA finds that at a minimum, the flight-hour requirements

in Exemption No. 11062 are appropriate

to practice anrJ

build proficiency in the skills necessary

to safelyconduct

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 grzrntof exemption to accomplish

the required

flight time. During training,proficiency,ancl experience-tuilding flights the PIC is required to operatethe UA with appropriate distancesin accordance with 14 C.F.R 91.1i9. ExemptionNo.

11138 atpage 15. Accordingly, SE Blueprint, Inc. will ensure safe operations

by not allowin

g anypIC to operate the DJI Phantom3 Professional UAS unless

that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely operatethe DJI phantom 3 ProfessionalUAS in a manner consistent with the exemption, including evasive and emergency maneuvers

and maintaining appropriate distances

from people,vessels,

vehiolesand structures.

3' ReasonsWhy An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety. The equivalent

level of safetyestablished by Section

9L7(a) will be maintained because prior to every flight, SE Blueprint, Inc. will ensurethat the DJI Phantom 3 Professional UAS is in an airworthy condition based upon the UAS's compliance with its operating documents and as statedin the conditions and limitations herein. 21 SE Blueprint Inc.'s Petitionfor 333 ExemptionAdditionally, the FAA has previously grantedrelief from Section 91.7(a) specificto UAS, in

circumstances

similar, in all material respects, to thosepresented

herein (e.g. Exemption Nos. 11062,11063,

11064,11065,

17066, 11067,110g0,

1i10-g, 11110, 1r1r2, tti:0, 1113g,

11150, 11153, 11156, 71157,11159,

11159, 11160, 11161).

4' Reasons

Why An Exemption From The RequirementsOf Sectiorrgl.I2l Would Not Advers ely Affect Safefy. The equivalentlevel of safety established by Section gI.I2l will be maintainedbecause the altitude information of the DJI Phantom3 Professional UAS will be provided to the pIC via GpS equipment and aradio 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 sE Blueprint, Inc. operation of the DJI Phantom

3 Professional

UAS within visual line of sight, at or below 500 feet AGL, will ensure a level of safetyequivalent to Section 91.121.

The altitude information will be generated by GPS equipment installed onboar6the aircraft. prior to each flight, a zero altitude initiation point is attomatically establishedby the uAS at ground level. The FAA has previously granted relief from Section91.121 specificto UAS, in circumstances similar, in all material respects, to thosepresented

herein (e.g. Exemption Nos. 11062, 11063, 11064,11065,

11066,11067,110g0,

11109, 11112,11136,1113g,

11150, 11153, 11156, rrr57, 11159, 11159, 11160, 11161).

5' Reasons

Why An Exemption From The Requirements Of Section

gl.lsl(b) Would Not Adversely Affect Safefy. A grant of this exemption would ensure

an equivalent

level of safety established by 14 C.F.R.. Section 91'151(b)

asa resultof (1) the technical specifications

of the DJI phantom3 professional UAS; (2) the limitations on the proposed flight operations;

and (3) the location of the proposed flight operations. Accordingly, SE Blueprint, Inc. will ensure that it will safely operate the battery powered DJI Phantom3 Professional UAS during daylight hours in VFR conditions,with enoughbattery power to fly for a total duration of 23 minutes. Here,as in Exemption No. 11109,

the technical

specif,rcations

of the DJI phantom3 professional UAS; the limitations on the proposed flight operations;and the location of the proposed operations,

will ensure

an equivalent

level of safetyestablished by 14 C.F.R. Section

91.11116). Furthermore,

safetywill be ensured

as the DJI Phantom3 ProfessionalUAS provide audible and visual warnings to the PIC at the GCS when the UAS experiences low battery voltage, the first waming occuffing at approximately 33Yoremaining battery power, and again at approximately ljYo rcmaining battery power. At the critically low battery level, the DJI phantom 3 professional UAS will descend

and land automatically. Significantly,

previousexemptions

granted by the FAA concerning Section 91

. 15 1 establish

that safety is not adversely

affectedwhen the technical characteristics and operating limitations of the 22 SE Blueprint Inc.'s Petitionfor 333 ExemptionUAS are considered. Relief has been granted for manned aircraft to operate at less than the

minimums

prescribed

in Section

91.151, including

Exemption

Nos.26gg,5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in circumstances

similar, in all material respects, to those presented

herein (eg. Exemption Nos. 

### 8811, 10909, 10673, rr042, 11062,11063,

11064,11065,

11065, 1106r, ttoso, 1110g, 11110, 11136,1 1 39, 1 1 150, 1 1 153, lll56, rrr57,1

1 15g, 1rr5g,1 1 160, 1 1 161).

6' Reasons Why An Exemption From The Requirements of Sections 91'405(a)'

9l'a07@)(l),91.409(axl) & (a)Q), And 91.417(a) & (b) Would Not Adversely Affect Safety. In seeking this exemption, SE Blueprint, Inc. submits that the equivalent level of safety with regard to the regulatory maintenance and alteration requirements established by Sections 91'405(a),

91.a07@)(l),

9t.409(ax1) & (a)(2), and 9r.a17@) & (b) wilr be met because SE Blueprint, Inc. will use trained technicians to perform maintenance,altelations, or preventive maintenance

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

documents

(i'e., SE Blueprint, Inc. Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 ProfessionalInstruction Manual). Furthermore, SE Blueprint, Inc. will documentand maintain all maintenance recordsfor the DJI Phantom3 profi:ssional UAS. Since the DJI Phantom 3 Professional UAS will be inspected as prescribed

by the operating documents,

SE Blueprint,Inc. will maintain the equivaleni

level of safety

established

by Sections 91'405(a),91.a09(a)(1), and 91.a09@)(2).

A copy of the DJI Phantom3 prof'essional User Manuals are attachedhereto as Appendix A and B; a copy of the DJI phantom 3 professional UAS Maintenance

LOG is attached

hereto asAppendix C. Likewise,the exemption sought will not adversely

affect safetybecause

SIJ Blueprint, Inc. will use trained technicians to perform maintenance,alterations or preventive maintenanceon the UAS usingthe methods, techniques,

andpractices

prescribed

by the operating

documents. Furthermore'the exemption sought would maintain an equivalent level of safety established by Sections 91.407, 9L417(a) and, 9I.4I7(b), because

all maintenance

of the DJI phantom 3 Professional

UAS will be performedby trained technicians. Maintenance

will be documented and maintainedutilizing the monthly maintenance log. Significantly, previous exemptions granted by the FAA concerning Sections 9L405(a), 9l'407(a)(I),91.409(a)(1) & (a)(2),and 91

.aI7@) & (b) establish that satety

is not adversely affectedwhen the technical characteristics and operating limitations of the UAS are considered. In considerationof SE Blueprint, Inc. proposedoperating limitations, the operating documents, andthe technical aspects of the DJI Phantom3 Professional UAS, SE Blueprint, Inc. submitsthat safety will not be adversely

affected by grantingexemption from 14 C.F.R. Sections91.405(a), 9l'a07@)(l) and (a)(2),91.a09@)(2), and 9l.aI7@) and (b). The FAA haspreviously granted relief specific

to UAS in circumstances similar, in all materialrespects, to those presented

herein

SE Blueprint Inc.'s Petitionfor 333 Exemption(e'g.

Exemption

Nos.71062,11063,

11064,1 1065, 11066, 11067,110g0,

1 1 10g, 11110, lrll2, 17136, 1 I 139, 1 1 150, 1 1 153, 11156, rrr57, 1 1 15g,rr159,1

1 160, 1 1 161). 7. The FAA May PrescribeAny other conditions For Safeoperation. In accordance

with Section333 of the FAA Modemization and Reform Act of 2012 (FMRA) and 14 C'F'R' $ 21.16 entitled SpecialConditions, SE Blueprint, Inc. requests that the FAA prescribe

special conditions

for the intended

operation

of the DJI phantomj professional UAS, which contain such safety standards that the Administrator finds necessary to establish

a level of safety equivalent

to that established

by 14 c.F.R. Part

2r, Subpart

H, and 14 c.F.R $

$ 61

. I 13(a) & (b),91.7

(a),97.r21,91.15r(b), 9r.405(a),9r.a07@)(r),9r.409(a)(1) & (a)(z),

and,9r.a17@) & (b)' Such special

conditions

will permit safeoperation of the uAS for the limited purpose of conducting aetial video and photography over ceftain areas of the United States for compensation

or hire. FMRA Section 333 sets forth the requirements for considering

whethera UAS will create

ahazard to users of the NAS or the public, or otherwise pose athreatto national security; and fuither, provides the authority for such UAS to operate without airworthiness certification in accordance with any requirements that must be established for the safe operation of the UAS in the NAS. Likewise' the Administrator may prescribe special conditions pursuant to 14 C.F.R. $ 2i'16, for operation of the DJI Phantom 3 ProfessionalUAS, since the airworthiness regulations

of 14 C.F.R. Part2l do not containadequate or appropriate

safetystandards,

due to the novel or unusualdesignfeatures of the aircraft.

Section 21.16,

entitled SpecialConditions, states the following: If the FAA finds that the airworthiness regulations of this subchapterdo not contain adequate or appropriate safety standardsfor an aircraft., aircraft engine, or propeller because of a novel or unusual design feature of the aircraft, airqaft engine or propeller, he prescribes

special conditions and amendments thereto for the'product. The special conditionsare issued

in accordance

with Part 11 of this chapter and contain suchsafety standardsfor the aircraft, aircraft engine or propeller as the FAA finds necessary to establish

a level ofsafety equivalent to that established

in the resulations. See 14 C.F.R. $ 21.16. Therefore, in accordance with FMRA Section 333 and 14 C.F.R. S 21.16,the FAA may prescribespecial conditionsfor SE Blueprint, Inc. intendedoperationof the DJI phantom 3 Professional

UAS, which contain such safety standards that the Administrator finds necessary to establish

a level of safetyequivalent to that established

by 14 C.F.R. part 21,Subparl H, and. 14 

### c.F.R sections

61.113(a)

&. (b), 9r.7(a),

9r.r2r, 91.15r(b),

9r.405(a),

9r.407(a)(r), eI.a09@)Q)

& @)(2), and9r.4r7(a)

& (b).

r d Summary That Can Be published in the Federal Rules from Which SE Blueprint, fnc. Seeks Exemption: Register, stating: The

1 A SE Blueprint Inc.'s Petitionfor 333 ExemptionSE Blueprint, Inc' seelrs exemption from the requirements of 14 C.F.R Sections 61'II3(a)&ft), 9t.T(a), 9I.l2l, 9I.r5I(b), 9L405(a), gr.407(a)(I), 9r.409(a)(I) & (a)(2), and9L417(a) & (b). A Brief Description Of The Nature Of The Exemption SE Blueprint,Inc. Seeks: This exemption will permit SE Blueprint, Inc. to commercially operate an (Jnmanned Aircraft System(UAS) for the purpose of conducting aerial video and photography over certain areqs of the United States. ' Any Additional Information, Views, Or Arguments Available To Support SE Blueprint, Inc.os

Request. This Petition is madepursuant to the FAA Modernizationand Reform Act of 2012 (FMRA) Section

333,which directs

the Secretary

of Transportation

to determine

if certainUAS may operate safely in the NAS. As such, SE Blueprint, Inc. request for exemption may be granted pursuant to the authority

of FMRA Section

333 and 14 C.F.R.part 11,assetforth above. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to usersof the NAS or the public, or otherwise poses athreatto national security;and further, provides the authority for such UAS to operate without airworthinesscertification. 

### As discussed

in detail above,

SE Blueprint, Inc. will operate the UAS safely in the NAS, without creating a hazafi,to usersof otherwise

pose a threat to national

security. DJI Phantom 3 Professional the N,{S, or the public, or

25 SE Blueprint Inc.'s Petitionfor 333 Exemption

### CONCLUSION

As setforth herein,

SE Blueprint,

Inc. seeks

an exemption

pursuant to 14 C.F.R.

$ 11 .6I and Section 333of the FAA Modernization andReform Aciof 2012 (FMRA),whichwill permitsafe operation

of the DJI Phantom

3 Professional

UAS commercially,

without an airworthiness certificate,

for the limited putpose

of conducting

aerial videoandphotography

overcertain

areas of the United States.

By granting

this Petition,the FAA Administrato.*ill be fulfilling the congressional

mandateof the FAA Mod ernization and Reform Act of 2012,while also advancing

the interests

of the public, by allowing SE Blueprint, Inc. to safely, efficiently,and economically

operate the DJI Phantom

3 Professional

UAS commercially

within theNAS. WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization

and Reform

Act of 2072,

Section 333,SE Blueprint,

Inc. respectfully

requests that the Administrator

grantthis Petition

for an exemption

from the requirements

of 14 C.F.R Sections 61.113(a)

& (b),9r.7(a),

gr.r2r, 91.r51(b),

91 .405(a),9r.a07@)(r),9r.409(ax1) & (a)(2), and 9r'a17@)

& (b), and permit SE Blueprint, Inc. ro operate

it" ul phantom

3 Professional

UAS commercially

for thepurpose

of conducting

aerial videoand

photography

over certain areas of theUnitedStates.

Dated: January 25,2016

Very truly yours, 

# nlr

WilliamF. Attorney at Law Counsel for SE Blueprint, Inc.

26 SE Blueprint Inc.'s Petitionfor 333 Exemption

### Appendices:

A - Link to DJI Phantom 3 professional

Manual: click on link below http ://clownhad.c{

iiinnovations.com/downloadslphzurtonl.-3len/llhantom,,3,,,I,r:rofessional,,-,{-lsel,,Manual,.Jl.2-.err"odfB - Copy of the Small UAS Certificate of Registration

to Austin price Certificate Number: FA34KRWY9E

27 

### SEBlueprint Inc.'sPetitionfor 333

Exemption