January 25,2016

U. S. Department of Transportation

Docket Management Operations

West Building Ground Floor, Room Wl2-140

1200 New Jersey Ave, SE Washington, DC 20590

RE: SE Blueprint Group,-Inc.'s Requests An Exemption From The Requirements of Title 14 of The Code Of Federal Regulations 14 C.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)

Dear Sir orMadam:

Pursuant to section 333 of the FAA Modemization and Reform Act of 2012 (the Reform Act) and 14 C'F'R' Part 11, SE Blueprint, Inc. ("SE Blueprint" herein after), an ohio Corporation that provides information management services for construction sites since 1990, 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 as such operations are concluctecl within and under the conditions outlined herein or as may be established by the FAA asrequired by Section 333.

As detailed in this document and the attached Manual, the requested exemption would permit the

operation of sUAS under controlled conditions in airspace that is 1) limited 2) predetermined

3) controlled as to access and 4) would provide safety enhancements to the already best practices

safety protocols followed by SE Blueprint at each one of its sUAS photography sites.

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,

The names and address of the applicants are as follows:

Mr. Kevin R. Anderson, President

Mr. Craig J. Dziak, Vice president of Operations

SE Blueprint,Inc.

2035 Hamilton Avenue

Cleveland, Ohio 44114

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 ARE REQUESTED... ............3

suMMARy............... ...................4

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

BACKGROI_rND......... .,................4

FAA UAS REGISTRATION INFORMATION. 

... . ..5

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

NAME AND ADDRESS OF PETITIONERS..... ............6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH SE BLUEPRINT. INC. SEEKS

EXEMPTION............ .........,........7

THE EXTENT OF RELIEF SE BLUEPRINT, INC. SEEKS AND THE REASON

SE BLUEPRINT, INC. SEEKS THE RELIEF ..............10

THE REASONS WHY GRANTING SE BLUEPRINT, INC.'S REQUEST WOULD

BE IN THE PUBLIC INTEREST............ ,,..,12

THE REASONS WHY GRANTING THE EXEMPTION TO SE BLUEPRINT, INC. WOULD

NOT ADVERSELY AFFECT SAFETY... ......................14

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTEIT,,,.,.....,,....,,,,.25

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO

suPPoRT SE BLUEPRINT, INC. ,S REQUEST ........,..25

CONCLUSION........... ..................26

EXHIBITS ,....,,.27

SE Blueprint Inc.'s Petitionfor 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

Above Ground Level

Area of Interest

Air Traffic Control

Air Traffi c Or ganization

Aerial Vehicle

Code of Federal Regulations

Certifi cate of Authorization

Federal Aviation Administration

Federal Aviation Regulation

Ground Control Station

Global Positioning System

Loss of Link

National Airspace System

Notice to Airman

Pilot In Command

FAA Modemizationand Reform Actof 2012 (FMRA)

Safety Observer

Standard Operating Procedures

Unmanned Aircraft

Unmanned Aircraft Svstem

Visual Flight Rules

Visual Line of Site

Visual Meteorological Conditions

Vertical Takeoff and Landins

Regulations from which the 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)

14 C.F.R. el.e (b) (2)

14 C.F.R.91.103

14 C.F.R.91.109

14 c.F.R.91.119

14 C.F.R.9l.l2l

14 C.F.R. 91.1s1(a)

14 C.F.R. 9r.203 (a) & (b)

14 C.F.R.91.40s (a)

14 C.F.R. a07 @) (r)

14 C.F.R. a0e @)(2)

14 C.F.R. 4r7 (a) & (b)

SE Blueprint Inc.'s Petitionfor 333 Exemption
SUMMARY

SE Blueprint, Inc. hereafter referred to as SE Blueprint, seeks exemption :[rom the requirements

of 14 c.F.R Part 21, 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 operate an Unmanned Aircraft

System (DJI Phantom 3, Professional) pursuant to Section 333 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 sector businesses 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 communities using advanced technologies and solutions. SE Blueprint, Inc. has

worked in all types of locations with a perfect client and employee safety record. 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 Visuals for Construction Project Design Development

' Utilizing sUAS Technology to Expedite Information Dissemination to Project

Managers and Project Staff

. Accurate Visual Inspection of Construction Sites

. Accurate Visual Inspection of Demolition

. Economic Development

. Civic landmarks

. Aerial photography

. Aerial videography

FLIGHT EXPERIENCE

Mr. Craig J. Dziak, Vice President of Operations, has honed his flight skills bv utilizing the Phoenix

RC Pro Simulator, for three years. In addition to flight simulator, Mr. Dzialk is a radio controlled

helicopter pilot with the 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 Professional is vertical takeoff and

landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing

electronic tablet or smart phone systems. The DJI Phantom 3 Professional has a maximum gross

SE Blueprint Inc.'s Petitionfor 333 Exemption
weight 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 Polymer battery 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, as well as 14 C.F.R ParI 47, Aircraft

Registration, and marked in accordance with 14 C.F.R. Part 45, Identffication and Registration

Marking (Copy of FAA UAS Certificate is attached hereto and marked as Exhibit A).

The UAS registration and serial number is as follows:

Model: Phantom 3 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 Reform Act of 2012 (FMRA), Section 333,

Special Rules for Certain Llnmanned Aircraft Systems, hereby petitions the Administrator to

commercially operate the DJI Phantom 3 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

unmanned airclaft" and its operation, SE Blueprint, Inc. operation of DJI Phantom 3 Professional

UAS meets the conditions of FMRA Section 333 and therefore, will not require an 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 Professional Instruction Manual). Furthermore, SE Blueprint, Inc. will document and

maintain all maintenance records for the DJI Phantom 3 professional UAS.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges

and limitations: Pilot in command, is requested by SE Blueprint, Inc. to the extent necessary 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 operate the DJI Phantom UAS in a manner consistent with this exemption, including

SE Blueprint Inc.'s Petitionfor 333 Exemption
evasive and'emergency maneuvers and maintaining appropriate distances from people, vessels,

vehicles and structures.

SE Blueprint seeks relief from SectiottgI.T(a), entitled Civil aircraft airworthiness, 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 that they will ensure that the

DJI Phantom 3 Professional UAS is in an airworthy condition, prior to every flight, by

determining that the UAS is in compliance with the operating documents (i.e., Monthly

Maintenance Log, and DJI Phantom 3 Professional Instruction Manual), and that the aircraft arc

in a condition for safe flight.

The Phantom 3 Professional manual is located at: http://tinyurl"com/z28nuu6

SE Blueprint, Inc. also seeks an exemption from the requirements of Section gl.l2l, entitled

Altimeter Settings, 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 Global Positioning System (GPS) equipment and radio communications

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

path. This altitude information, combined with SE Blueprint, Inc. operation of the DJI phantom 3

Professional UAS within visual line of sight, at or below 400 feet AGL, will ensure a level of

safety equivalent to Section 9l.l2l.

Additionally, SE Blueprint, Inc. seeks an exemption from the requirements of Section 91 .151(b),

entitled Fuel requirements for flight in VFR conditions. SE Blueprint, Inc. submits that safety

will not be affected by operation of the DJI Phantom 3 Professional UAS during daylight hours

in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery

power to fly for a total duration of approximately 23 minutes. Battery povyer indicators are also

able to show exactly how much battery power is left, as well as how much time is needed to

retum safely back to point of take-off.

In accordance with 14 C.F.R. $ 11.81, SE Blueprint, Inc. provides the following information in

support of its petition for exemption:

A. Name, Address, Telephone Numbers, & Email of the petitioners.

The names and addresses of the Petitioners and point of contact are:

Mr. Kevin R. Anderson

Mr. Craig J.Dziak

SE Blueprint,Inc.

2035 Hamilton Avenue

Cleveland, Ohio 44II4

Telephone (21 6) 241 -2250

Email : I(ev i nG)sebiueprinl." com

Email : LjraiS(pseblueprint.com

SE Blueprint Inc.'s Petitionfor 333 Exemption
B. The Specific Sections of 14 C.F.R. From Which SE Blueprint, Inc. Seeks Exemption.

1. SE Blueprinto Inc. 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 cate may act as a pilot in command (PIC) of an aircraft that

is carrying passengers or property for compensation or hire; nor may that person, for

compensation or hire, act as pIC of an aircraft.

(b) A private pilot may, for compensation or hire, act as 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 does not 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 person may operate a civil aircraftunless it 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 person operating an 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 feet MSL, 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 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

depafiure airport or an appropriate altimeter setting available before deparlure.

4. SE Blueprinto Inc. Seeks Exemption From The Requirements Of Section 91.151(b).

Section 91 .15 1, entitled Fuel requirements for flight in VFR conditlors, subsection

SE Blueprint Inc.'s P etition 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 and forecast weather conditions) there is enough fuet to fly to the

first point of intended landing and, assuming normal cruising speed, to fly after that

for at least 20 minutes.

5. SE Blueprint,Inc. Seeks Exemption From The Requirement Of Section 91.405(a).

Section 91,405, entitled Maintenance required, subsection (a), states the followins: Each

owner or operator of an aircraft-

(a) Shall have that aircraft inspected as prescribed in subpart E ofthis 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 chapterf.]

6. SE Blueprinto Inc. Seeks Exemption From The Requirements Of Section 91.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 undergone maintenance,

maintenance, rebuildin g, or alter ation unle s s- -

(1) It has been approved for retum to service by a person

of this chapter[.]

authorized under $ 43.7

7. SE Blueprint, Inc. Seeks Exemption X'rom The Requirements Of Sections 91.a09(a)(l)

And 91.409(a)Q).

Section 9t.409, entitled Inspections, 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 chapter and has been

approved for return to service by a person authorizedby $ a3.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance

with part 21 of this chapter.

8. SE Blueprinto Inc. Seeks Exemption from the Requirements of Sections 91.417(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) Except for work performed in accordance with $$ 91.41 1 and g14l3, each registered owner

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

(1) Records of the maintenance. preventive maintenance, and alteration and records of the 100-hour, annual, progressive, and other required or approved inspections, as appropriate,

for each airqaft (including the airframe) and each engine, propeller, rotor, and appliance

of an aircraft. The records must include_

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

work performed; and

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

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

for return to service.

(2) Records containing the following information:

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

each rotor.

(ii) The current status of 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 status of 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 date when the next action is required.

(vi) Copies of the forms prescribed by g a3.9(d) of this chapter for each

major alteration to the airframe and currently installed engines, rotors,

propellers, and appliances.

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

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

work is repeated or superseded by other work or for I year after 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 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 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. Seeks And The Reason SE lllueprint, Inc. Seeks Relief From Section 61.113(a) And (b;.

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations; pilot in command, is requested to the extent necessary to allow a PIC 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 conduct the proposed UAS flight 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 PIC of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire.

As set forlh 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 Phantom 3 profbssional UAS

unless that PIC has met certain flight-hour and curency requirements, demonstrating that the

PIC is able to safely operate either the DJI Phantom 3 Professional UAS in a manner consistent

with the operations specifications as described in this exemption, including evasive and

emergency maneuvers, as well as maintaining appropriate distances fi: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 grant of 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. Seeks And The Reason SE Blueprint, Inc. 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 SE Blueprint, Inc. to determine that the DJI Phantom 3 professional UAS 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 Phantom 3 Professional Instruction Manual).

SE Blueprint' Inc' seeks the requested relief because the DJI Phantom 3 Prof'essional UAS do not

require an 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 based upon its compliance with the operating documents (i.e., Monthly Maintenance

1 0 SE Blueprint Inc.'s Petitionfor 3:13 Exemption
Log, and DJI Phantom 3 Professional) prior to every flight, and further, determine that the aitcraft are in condition for safe flight, as stated in the conditions and limitations below.

3' Extent Of Relief SE Blueprint, Inc. Seeks And 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). Since the FAA requires

that any altitude information concerning UAS operations be reported to air traffic control (ATC)

in feet above ground level (AGL), SE Blueprint, Inc. seeks the requested relief because the DJI

Phantom 3 Professional 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 (lFlt 91.121 is sought

to the extent necessary to comply with the applicable conditions and limitations stated below. As

more fully set forth herein, an equivalent level of safety will be maintained since the D;I

Phantom 3 Professional UAS are equipped with a barometric pressu,re sensor and GpS

equipment, which automatically ensures that a ground level pressure setting will be established

prior to each flight, and provides the PIC with altitude information of the UA on the heads-up

display of the GCS.

4. Extent Of Relief SE Blueprint, Inc. Seeks And 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 hours in 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 exemption from Section 91.151(b), the flight time duration of the battery

powered DJI Phantom 3 Professional UAS will severely constrain the practicality of any aerial

video or still photo flight operations that SE Blueprint, Inc. proposes to conLduct pursuant to this

Petition.

Significantly, as set forth below, the technical specifications of the DJI Phantom 3 professional

UAS, the DJI Phantom 3 Professional operating documents, and SE Blueprint, Inc. proposed

operating limitations, ensure that SE Blueprint, Inc. will safely operate the 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 Exemption
5' Extent of Relief SE Blueprint, Inc. Seeks And 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. requests relief from these Sections

because the DJI Phantom 3 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 technicians to perform maintenance, alterations, or preventive maintenance on

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

documents (i'e., the SE Blueprint, Inc. Aerial Operations Manual, Monthly Maintenance Log,

and DJI Phantom 3 Professional Instruction Manual). Furthermore, SEi Blueprint, Inc. will

document and maintain all maintenance records for the DJI Phantom 3 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 aerial video and photography of construction sites,

real estate, events and civic landscape over ceftain areas of the United States.

Additionally, use of the DJI Phantom 3 Professional UAS will decrease congestion of the NAS,

reduce pollution, and provide significant benefits to the economy. Notably, the benefits of SE

Blueprint, Inc.'s proposed operation of the DJI Phantom 3 Professional UAS will be realized

without implicating any privacy issues.

1. The Public will Benefit From Decreased congestion of 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 aerial imagery. 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 increase the 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 caused by arriving and departing aircraft will be reduced. The DJI phantom 3

Professional UAS 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 Exemption
2' The Public Will Benefit From The Safety And Efficiency Of The DJI phantom 3

Professional UAS.

Conducting aerial acquisitions with the DJI Phantom 3 Professional UAS, instead of manned

aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution

generated during traditional aerialvideo and still photography flight operations. By using battery

power and electric motors, the DJI Phantom 3 Professional UAS produces no 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 approximately 20-30 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

manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside

from the lack of flight crew members located onboard the aircraft, the DJI phantom 3

Professional UAS (weighing approximately 2.8 pounds at their maximun gross weight with

diagonal dimension of 23.2 inches, and with no fuel on board), has less physical potential for

collateral damage to life and property on the ground, and in the air, compared to the manned

aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a

wingspan of approximately 42 feet, alength of 34 feet, and, afuel capacity of 180 gallons).

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 aerral operations. 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 greater operational flexibility compared to manned aircraft, but provides such

flexibility without the high operational cost of a traditional manned aftcraft.

By operating the DJI Phantom 3 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, 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.

13 SE Blueprint Inc.'s Petition for 3J3 Exemption
4. There Are No Privacy Issues.

Similar to the manned aerial acquisition 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 Phantom 3 Professional UAS wi.tl be operated only in

compliance with operating documents (i.e., SE Blueprint, Inc. Aerial Operations Mamral,

Monthly Maintenance Log, and DJI Phantom 3 Professional Instruction Manual) which requires

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

with the Federal Aviation Regulations, including the minimum altitude requirements of 14 c.F.R. $ 91.119.

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

How The Exemption Would Provide A Level of Safety At Least Equ:rl To That provided

By The Rule From which sE Brueprint,Inc. seeks Exemption.

1' Reasons Why The DJI Phantom 3 Professional 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 operatin g area associated 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 cefiificate in accordance with 14 c.F.R. part2l, Subparl H.

Section 333 provides authority for a UAS to operate without airworlhiness cefiification and sets

forth requirements for considering whether a UAS will create ahazard,to users of the NAS or the

public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the

following, in part:

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

than 180 days after the date of enactment of this Act, the Secretory of Transportation

shall determine if certain unmanned aircraft systems may operate safely in the

national airspace system before completion of the plan and rulemaking required by

section 332 of this Act or the guidance required by section 334 of this Act.

(b) Assessment of (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 3J3 Exemption
lXlf;f"ii{i![,i3r 

the operation ofunmanned air*aft svstems identffied

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

that certain unmanned aircraft systems may operate safely in the national airspace

system, the Secretary shall establish requirements for the safe operation of such

aircraft systems in the national airspace system.

In seeking this exemption, SE Blueprint, Inc. submits that the DJI phantom 3 profbssional UAS

can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the

characteristics of the DJI Phantom 3 Professional uAS; (b) the pilot certification requirement;

and (c) the specific operating limitations.

a' The Specifications Of The DJI Phantom 3 Professional UAS Demonstrate Its Safe

Characteristics.

The DJI Phantom 3 Professional UAS does not create ahazafi.to users of 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 Professional UAS.

The technical specifications of the DJI Phantom 3 Professional UAS are set forth by the DJI

Phantom 3 Professional User Manual, attached hereto as Appendix A.

ii. The DJI Phantom 3 Professional UAS 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 modes of the DJI phantom 3

Professional UAS is provided at pages 11 of the DJI Phantom 3 Professional User Manual

attached hereto as Appendix A.

iii. The DJI Phantom 3 Professional UAS Is Designed For Automatic Return To

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

When the Control Link is lost, the DJI Phantom 3 Professional UAS will remain stationary, in

flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 3 professional UAS does not

reacquire control 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., failsafe mode) 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 Professional User Manual, attached hereto as

Appendix A.

l 5 SE Blueprint Inc.'s Petition for 333 Exemption
iv. The DJr phantom 3 professionar GCS 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 Appendix A.

b' Flight Operations of DJI Phantom 3 Professional UAS Is Limited To The Line Of Sight of A certificated Pilot in command with A safety observer.

SE Blueprint, Inc. video production staff will be the only persons ro act as a pilot in command (PIC) of the DJI Phantom 3 Professional uAS. Additionally, a safbty observer will assist him at all times during flight time.

c' Flights of DJI Phantom 3 Professional UAS Witl Be Conducted pursuant To Specific Operating Limitations.

In seeking this exemption, SE Blueprint, Inc. proposes to commercially operate 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' operations authorized by this grant of exemption will be limited to the following

aircraft described in the operating documents, rotorcraft UAS weighing less than 55 pounds maximum gross weight: DJI 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 purpose of 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 indicated by the procedures specified in the operating documents unless a

special request is made and approved by ATC. All altitude, ,.port.d to ATC must be in feet AGL.

5' The UAS must be operated within visual line of sight (vLoS) of the pIC at all times' This requires the PIC to be able to use human vision unaided by any device

other than corrective lenses, as specified on the PIC's FAA-issued airman 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 safety observer (SO). The SO may be used to satisfy

the VLoS requirement as long as the PIC always maintains VLOS capability. The SO

and PIC must be able to communicate verbally at all times. Electronic messaging or

texting is not permitted during flight operations. The PIC must be designated before

T6 SE Blueprint Inc.'s Petitionfor 333 Exemption
the flight and cannot transfer his or her designation for the duration of the flight. The

PIC must ensure that the SO can perform the functions prescribed in the operating

documents.

8' The SO must not perform any other duties beyond assisting the PIC with seeing and

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

permitted to operate the camera or other instruments.

9. The operating documents and the grant of exemption must be accessible during

UAS operations and made available to the Administrator upon request. If a

discrepancy exists between the conditions and limitations contained in the grant of

exemption and the procedures outlined in the operating documents, the conditions and

limitations contained in the grant of exemption take precedence and must be followed.

Otherwise, the operator must follow the procedures as outlined in its operating

documents. The operator may update or revise its operating documents. It is the

operator's responsibility to track such revisions and present updated and revised

documents to the Administrator upon request. The operator must also present updated

and revised documents if it petitions for extension or amendment to the grant of

exemption. If the operator determines that any update or revision would affect the

basis upon which the FAA granted the exemption, then the operator must petition for

amendment to its grant of exemption. The FAA's UAS Integration Office (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 operating until the necessary maintenance has

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

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

alterations must be properly documented in the aircraftrecords.

11. Any UAS that has undergone maintenance or alterations that affect the UAS

operation or flight characteristics, e.g. replacement of a flight critical component,

must undergo a functional test flight. The PIC who conducts the functional test 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 operating documents.

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

l 7 SE Blueprint Inc.'s Petitionfor 333 Exemption
afuctaftecords, including total time in service, description of work accomplished,

and the signature of the authorized person returning the UAS to service. 

---:

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

16' The authorized person must make an entry in the airqaftrecord of the corrective action taken against discrepancies discovered between inspections.

17' The PIC must possess at least a private pilot certifi cate 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 qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualificatio" nignt hours must be logged in a manner consistent with 14 C.F.R. $ 61.51(b). Flights for the purposes of training the operator's pICs are permitted under 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 may not be conducteduring 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 IrAA office closesr to proposed area of operations. Flights under 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 curent 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 NorAM 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 than3 statute miles from the pIC.

22'If the UA loses communications or loses its GPS signal, itrnustreturn to apredetermined location within the planned operating area and,land or be recovered in

accordance with the operating documents.

23 ' The PIC must abort the flight in the event of unpredicted obstacles or emergencies

in accordance with the operating documents.

l 8 SE Blueprint Inc.'s Petitionfor 333 Exemption
24' The PIC is prohibited from beginning a flight unless (considering wind and

forecast weather conditions) there is enough power to fly at nomal cruising speed to

the intended landing point and land the UA with 25yobattery power remaining.

25' The operator must obtain an Air Traffic Organization (ATOr) issued Certificate of

Waiver or Authorization (COA) prior to conducting any operations 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 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 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, Subparl C. Markings must

be as large as practicable.

27 ' Prior to conducting operations, the radio frequency spectrum used for operation

and control of the UA must comply with the Federal Communications Commission

(FCC) or other appropriate government oversight agency requirements.

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 and activities at all times.

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

31. Flight operations must be conducted at least 500 feet frorn all nonparticipating

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

vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating

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

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

situation arises where nonparticipating persons leave such proiection and are

within 500 feet of the UA, flight operations must cease imrnediately and,lor;

b. The airuaft is operated near vessels, vehicles or structures where the

owner/controller of such vessels, vehicles or structures has granted permission

and the PIC has made a safety assessment of the risk of operating closer to

those objects and determined that it does not present an 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 Exemption
32' All operations shall be conducted over private or controlled-access properly with permission from the land owner/controller or authorized representative. 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 Safety Board (NTSB) per instructions

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

2' Reasons Why An Exemption From The Requirements Of Section dl.fl3(a) And (b) Would Not Adversely Affect Safety.

SE Blueprint, Inc. submits that the equivalent level of safety established by Section 61.113(a) and (b) will be maintained because no 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 consistent with the exemption, including evasive and emergency maneuvers

and maintaining appropriate distances from people, vessels, vehicles and structures.

Considering SE Blueprint, Inc. proposed area of operations, and the operating limitations set forth-above; the parallel nature of private pilot aeron autical knowledge requirements to those of commercial pilot requirements (See Exemption No. 1 1062); and the airmanship skills necessary

to safely operate the DJI Phantom 3 Professional UAS, SE Blueprint, l.nc. submits that the

additional manned airmanship experience of a commercially certifical.ed pilot would not coffelate to the airmanship skills necessary for SE Blueprint, Inc. sper:ific proposed 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, 11064,11065,11066,11067,110g0,1110t,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

Professional UAS training and curency requirements, that the PIC is able to safely operate the DJI Phantom 3 Professional UAS in a manner consistent with this exemption, including evasive

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

and structures.

Specifically, the PIC must have accumulated and logged, in a marmer consistent with 14 C.F.R. $

61'51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimurn of 5 hours of those

hours as a UAS pilot operating the same make and model of uAS to be used for operations under

20 SE Blueprint Inc.'s Petitionfor 333 Exemption
the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes).

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

In Exemption No' 11062, the FAA required that prior to conducting operations for the

purpose of motion picture filming (or similar operations), the PIC must have accumulated

and logged, in a manner consistent with 14 cFR 61.51(b),25 hours of total time as a

UAS rotorcraft pilot including at least 10 hours logged as 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 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 ral;her 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 total25 hours of UAS rotorcraft tirne. In addition to 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 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 grzrnt of exemption to

accomplish the required flight time. During training, proficiency, ancl experience-tuilding

flights the PIC is required to operate the UA with appropriate distances in accordance

with 14 C.F.R 91.1i9.

ExemptionNo. 11138 atpage 15.

Accordingly, SE Blueprint, Inc. will ensure safe operations by not allowin g any pIC to operate

the DJI Phantom 3 Professional UAS unless that PIC has demonstrated, by meeting minimum

flight-hour and currency requirements, that the PIC is able to safely operate the DJI phantom 3

Professional UAS in a manner consistent with the exemption, including evasive and emergency

maneuvers and maintaining appropriate distances from people, vessels, vehioles and structures.

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

Adversely Affect Safety.

The equivalent level of safety established by Section 9L7(a) will be maintained because prior to

every flight, SE Blueprint, Inc. will ensure that the DJI Phantom 3 Professional 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.

21 SE Blueprint Inc.'s Petition for 333 Exemption
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, 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 Requirements Of Sectiorrgl.I2l Would Not Advers ely Affect Safefy.

The equivalent level of safety established by Section gI.I2l will be maintained because the altitude information of the DJI Phantom 3 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 safety equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed onboar6 the aircraft. prior to each flight, a zero altitude initiation point is attomatically established by the uAS 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, 11066,11067,110g0, 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) as a result of (1) the technical specifications of the DJI phantom 3 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 Phantom 3 Professional UAS during daylight hours in VFR conditions, with

enough battery power to fly for a total duration of 23 minutes.

Here, as in Exemption No. 11109, the technical specif,rcations of the DJI phantom 3 professional

UAS; the limitations on the proposed flight operations; and the location of the proposed

operations, will ensure an equivalent level of safety established by 14 C.F.R. Section 91.11116).

Furthermore, safety will be ensured as the DJI Phantom 3 Professional UAS provide audible and

visual warnings to the PIC at the GCS when the UAS experiences low battery voltage, the first

waming occuffing at approximately 33Yo remaining 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, previous exemptions granted by the FAA concerning Section 91 . 15 1 establish that

safety is not adversely affected when the technical characteristics and operating limitations of the

22 SE Blueprint Inc.'s Petitionfor 333 Exemption
UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos.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, 11136,1 139, 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 Professional Instruction Manual). Furthermore, SE Blueprint, Inc. will

document and maintain all maintenance records for the DJI Phantom 3 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 Phantom 3 prof'essional User

Manuals are attached hereto as Appendix A and B; a copy of the DJI phantom 3 professional

UAS Maintenance LOG is attached hereto as Appendix C.

Likewise, the exemption sought will not adversely affect safety because SIJ Blueprint, Inc. will

use trained technicians to perform maintenance, alterations or preventive maintenance on the

UAS using the methods, techniques, and practices prescribed by the operating documents.

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 performed by trained technicians. Maintenance will be documented

and maintained utilizing 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

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

In consideration of SE Blueprint, Inc. proposed operating limitations, the operating documents,

and the technical aspects of the DJI Phantom 3 Professional UAS, SE Blueprint, Inc. submits that

safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a),

9l'a07@)(l) and (a)(2),91.a09@)(2), and 9l.aI7@) and (b). The FAA has previously granted

relief specific to UAS in circumstances similar, in all material respects, 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 Prescribe Any other conditions For Safe operation.

In accordance with Section 333 of the FAA Modemization and Reform Act of 2012 (FMRA) and 14 C'F'R' $ 21.16 entitled Special Conditions, SE Blueprint, Inc. requests that the FAA prescribe special conditions for the intended operation of the DJI phantom j 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 safe operation 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 whether a

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 Professional UAS, since the airworthiness

regulations of 14 C.F.R. Part 2l do not contain adequate or appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special Conditions,

states the following:

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

adequate or appropriate safety standards for an aircraft., aircraft engine, or propeller

because of a novel or unusual design feature of the aircraft, airqaft 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 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 prescribe special conditions for SE Blueprint, Inc. intended operation of the DJI phantom 3

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 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 Petition for 333 Exemption
SE 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), and 9L417(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 made pursuant to the FAA Modernizationand 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, SE Blueprint, Inc. request for exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. part 11, as set forth above.

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

hazard to users of the NAS or the public, or otherwise poses athreatto national security; and further, provides the authority for such UAS to operate without airworthiness certification.

As discussed in detail above, SE Blueprint, Inc. will operate the

UAS safely in the NAS, without creating a hazafi, to users of

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 set forth herein, SE Blueprint, Inc. seeks an exemption pursuant to 14 C.F.R. $ 11 .6I and Section 333 of the FAA Modernization and Reform Aci of 2012 (FMRA), which will permit safe operation of the DJI Phantom 3 Professional UAS commercially, without an airworthiness certificate, for the limited putpose of conducting aerial video and photography over certain areas of the United States. By granting this Petition, the FAA Administrato. *ill be fulfilling the congressional mandate of 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 the NAS.

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 grant this 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 the purpose of conducting aerial video and photography over certain areas of the United States.

Dated: January 25,2016

Very truly yours, nlr

William F.

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{ i iinnovations.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 SE Blueprint Inc.'s Petitionfor 333 Exemption