UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

CONOR LUKAS CROUCH
FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF
TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) &

(a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION DJI Phantom 3

UNMANNED AIRCRAFT SYSTEM

PURSUANT TO S ECTION 333 OF
THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)

Submitted on December 26 , 2015

CONOR LUKAS CROUCH
715 MOSS CREEK DR. CAYCE, SC 29033
CONORCROUCH@AOL.COMTABLE OF CONTENTS

Page

GLOSSARY OF

ABBREVIATIONS............................................................
.......................3

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

INTRODUCT ION AND INTERESTS OF
PETITIONER....................................................4

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

BASIS FOR

PETITION...................

.............................................. ........................................5

NAME AND ADDRESS OF
PETITIONER.............................................................7

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH CONOR LUKAS CROUCH

SEE KS

EXEMPTION................................................................
.8

THE EXTENT OF RELIEF CONOR LUKAS CROUCH SEEKS AND THE

REASON CONOR LUKAS CROUCH SEEKS THE RELIEF

................... 11

THE REASONS WHY GRANTING CONOR LUKAS CROUCH’S REQUEST

WOULD BE IN THE PUBLIC INTEREST
.........................................................15

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY

AFFECT

SAFETY...................................................................
.......19

SU MMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER......30ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO

SUPPORT CONOR LUKAS CROUCH’S REQUEST.........32

CONCLUSION...............................................................

....... ..... ...................... ..............32

APPENDICES................... 33GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level
AOI Area of Interest
ATC Air Traffic Control ATO Air Traffic Organization
AV Aerial Vehicle CFR Code of Federal Regulations
COA Certificate of Authorization
FAA Federal Aviation Administration FAR Federal Aviation Regulation
GCS Ground Control Station GPS Global Positioning System
LOL Loss of Link NAS National Airspace System
NOTAM Notice to Airman
PIC Pilot In Command Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333 SO Safety Observer SOP Standard Operating Procedures
UA Unmanned Aircraft UAS Unmanned Aircraft System VFR Visual Flight Rules
VLOS Visual Line of Site VMC Visual Meteorological Conditions VTOL Vertical Takeoff and LandingSUMMARY

CONOR LUKAS CROUCH seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA
Modernization and Reform Act of 2012 (FMRA). This exemption will permit CONOR LUKAS CROUCH to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting
aerial video and photography of real estate, landmarks, for movies or television, for
historical reference , search and rescue, surveying, architecture, roof and pipeline inspection, l ive events, construction sites, natural resource management, insurance companies, tr aining on operation of UAS, golf courses and virtual tours

.

INTRODUCTION AND INTERESTS OF THE PETITIONER

CONOR LUKAS CROUCH provides his clients with photography and videography

of

p roperties for the purpose of advertising. CONOR LUKAS CROUCH has many

hours f lying experience. He has over 3 years of video production and photography experience. The objective of CONOR LUKAS CROUCH and his aerial operations is to provide high quality ima ging for a variety of commercial, public, and residential uses, specifically targeting:

• Real E state • Farming

• Search and Rescue • Surveying

• Architecture
• Movies
• Television • Roof and Pipeline Inspection
• Live Events
• Construction

• Natural R esource Management • Insurance Companies

• Golf Courses • Training on Operation of UAS

• Virtual Tours

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 3 UASs

CONOR LUKAS CROUCH seeks an exemption to operate DJI systems for compensation

or hire within the NAS. The DJI Phantom 3 is a vertical takeoff and landing (VTOL) UnmannedAircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phonesystems. The DJI Phantom 3 has a maximum gross weight of 6 pounds 7. 5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of approximately 42
knots. The DJI Phantom 3 UA S is equipped with four main rotors; driven by Lithium Polymer battery powered electric motors.

BASIS FO R PETITION

Petitioner, CONOR LUKAS CROUCH , pursuant to the provisions of the Federal
Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, her eby petitions the Administrator to commercially operate a DJI Phantom 3 UASs 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), 91.121, 91.151(b), 91.405(a), 91.407(a ) ( 1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

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

CROUCH operation of the DJI
Phantom 3 UAS meets the conditions o f FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart

H.

Accordingly, CONOR LUKAS CROUCH requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to
aircraft with an airworthiness certificate.

CONOR LUKAS CROUCH submits that the requested relief is proper since an equivalent level of safety will be ensured. CONOR LUKA S CROUCH will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Ph antom 3 Instruction Manual). Furthermore, CONOR LUKAS CROUCH will document and maintain all
maintenance records for the DJI Phantom
3 UAS.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and
limitations: Pilot in command, is requested by CONOR LUKAS CROUCH to the

extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an airman medical certificate, and who has demonstrated, by meeting minimum flig ht

- hour and currency requirements, that the PIC is able to safely operate the DJI
Phantom 3 UAS in a manner consistent with this exemption, including evasive and emergency maneuvers andmaintaining appropriate distances from people, vessels, vehicles an d

structures.

CONOR LUKAS CROUCH seeks relief from Section 91.7(a), entitled Civil
aircraft airworthiness, because the DJI Phantom 3 UAS does not require an
airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, CONOR LUKAS CROUCHsubmits that he will ensure that the DJI Phantom 3 UAS is in airworthy condition, prior to every flight, by determining that the UAS are in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Instruction M anual), and that the
aircraft are in a condition for safe flight.

CONOR LUKAS CROUCH also seeks an exemption from the requirements of
Section 91.121, entitled Altimeter Settings, as the DJI Phantom 3 UAS will not have a typical barometric altimeter onb oard. However, altitude information of the DJI Phantom 3 UAS will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry datalink, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information,
combined with CONOR LUKAS CROUCH’S operation of the DJI Phantom 3 UAS within visual line of sight, at or below 400 feet AGL, will ensure a level of safety

E quivalent to Section 91.121.

Additionally, CONOR LUKAS CROUCH s eeks an exemption from the requirements

of Section 91.151(b), entitled Fuel requirements for flight in VFR
conditions. CONOR LUKAS CROUCH submits that safety will not be affected by operation of the DJI Phantom 3 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 14.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that
for at least 4.5 minutes.

In accordance with 14 C.F.R. § 11.81, CONOR LUKAS CROUCH provides the following information in support of its petition for exemption:

A. Name And Address Of The Petitioner. The name and address of the Petitioner and point of contact is:

CONOR LUKAS CROUCH
715 MOSS CREEK DR. CAYCE, SC 29033
CONORCROUCH@AOL.COMB. The Specific Sections Of 14 C.F.R. From Which CONOR LUKAS CROUCH Seeks Exemption.
1. CONOR LUKAS CROUCH Seeks Exemption From The Requirements Of Section 61.113(a) And (b). Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections (a) and (b) prescribe the following, in relevant part:

(a) No person who holds a private pilo t certificate 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 hir e, 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.
2. CONOR LUKAS CROUCH Seeks Exemption From The Requirements Of Section 91.7(a). Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following:

(a) No person may operate a civil aircraft unless it is in an airworthy
condition.
3. CONOR LUKAS CROUC H Seeks Exemption From The Requirements Of Section
91.121. Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

-- (1) Below 18,000 feet MSL, to

-- (i) The current reported altimeter setting of a station along the route
and within 100 nautical miles of the aircraft; (ii ) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or(iii) In the case of an aircraft not equipped with a radio, the elevation

of the d eparture airport or an appropriate altimeter setting available

before departure.

4. CONOR LUKAS CROUCH Seeks Exemption From The Requirements Of Section 91.151(b). Section 91.151, entitled Fuel requirements for flight in VFR conditions,
subsection

(b), states the following:

(b) No person may begin a flight in a rotorcraft under VFR conditions

unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed , to fly after that for
at least 20 minutes.

5. CONOR LUKAS CROUCH Seeks Exemption From The Requirement Of Section 91.405(a). Section 91.405, entitled Maintenance required, subsection (a), states the following: Each owner or operator of an aircraft

—

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescr ibed in part 43 of this chapter

. 6. CONOR LUK AS CROUCH Seeks Exemption From The Requirements Of Section 91.407(a)(1) Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration, subsection (a)(1), states the following:

(a) No person may operate any airc raft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

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

7. CONOR LUKAS CROUCH Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2). Section 91.409, entitled Inspections, subsection (a), states the following:(a) Except as provided in paragraph (c) of this section, no person may operate an
aircraft u nless, within the preceding 12 calendar months, it has had

-- (1) An annual inspection in accordance with part 43 of this chapter and

has been approved for return to service by a person authorized by § 43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness certificate in
accordance with part 21 of this chapter.
8. CONOR LUKAS CROUCH Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b). Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following:

(a) Except for work performed in accordance with §§ 91.411 and 91.413,

each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preventive maintenance, and alteration

and
records of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe)

and each engine, propeller, rotor, and appliance of an aircra ft. 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,

p ropeller, rotor, and appliance. (iii) The time since last overhaul of all items installed on the aircraft
which are required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the time
since the last inspection required by the inspection program under which
the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safetydirective number and revision date. If the AD or safety directive
involves recurring action, the time and date when the next action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major
alteration to t he airframe and currently installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be
retained unt il the work is repeated or superseded by other work or for 1 year after the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be
retained and
transferred with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a registered owner or operator under §
43.11 of this chapter shall be retained until the defects are repaired and the
aircraft is approved for return to service.
C. The Extent Of Relief CONOR LUKAS CROUCH Seeks And The Reason

CO NOR LUKAS CROUCH Seeks The Relief.
1. Extent Of Relief CONOR LUKAS CROUCH Seeks And The Reason

CONOR LUKAS CROUCH 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 current 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

b usiness or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or
hire.

As set forth more fully below, CONOR LUKAS CROUCH submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the DJI Phantom 3 UAS unless that PIC has met certain flight

- hour and currency requirements, demonstrating that the PIC is able to safely operate either
the DJI Phantom 3 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 from people, vessels, vehicles and

structures.Further, CONOR LUKAS CROUCH s ubmits that all flights of the DJI Phantom 3
UASs, conducted by the PIC pursuant to the grant of this Petition: (1) will be
incidental to CONOR LUKAS
CROUCH’s business; and (2) will not carry passengers or property for compensation
or hire.

2. Extent Of Relief CONOR LUKAS CROUCH Seeks And The Reason

CONOR LUKAS CROUCH 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 CONOR LUKAS CROUCH to determine that the DJI Phantom 3 UASs are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., the CONOR LUKAS CROUCH
Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3
Instruction Manual).

CONOR LUKAS CROUCH seeks the requested relief because the DJI
Phantom 3 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, CONOR LUKAS CROUCH will ensure that the DJI Phantom
3

UAS are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual) prior to every flight, and further, determine that the aircraft are in condition for safe flight, as

state d in the conditions and
limitations below.

3. Extent Of Relief CONOR LUKAS CROUCH Seeks And The Reason

CONOR LUKAS CROUCH Seeks Relief From Section 91.121. Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the DJI Phantom 3 UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from

the UA to the PIC at the ground control station (GCS). Since the FAA requi res that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL),

CONOR LUKAS CROUCH seeks the requested relief because the DJI Phantom 3

UA S ’s altimeter may be set on the ground to zer o feet AGL, rather than the local barometric pressure or field altitude, before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply with the applicable conditio ns and
limitations stated below. As more fully set forth herein, an equivalent level of safety will be maintained since the DJI Phantom 3 UAS is equipped with a barometric pressure sensor and GPS equipment, which automaticallyensures 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 CONOR LUKAS CROUCH Seeks And The Reason

CONOR LUKAS CROUCH 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 UAS during day light hours in visual me teorological conditions (VMC), under visual flight rules (VFR), for a total duration of 14.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. CONOR LUKAS CROUCH seeks the

reque sted relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered DJI Phantom 3 UAs will severely constrain the practicality of any
aerial video or still photo flight operations that CONOR LUKAS CROUCH

propo ses to conduct pursuant to
this Petition.

Significantly, as set forth below, the technical specifications of the DJI Phantom 3 UASs, the DJI DJI Phantom 3 operating documents, and CONOR LUKAS CROUCH’s proposed operating limitations, ensure that CONOR LUKAS CROUCH will safely operate

the battery powered DJI Phantom 3 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

14.5 minutes to the first poi nt of intended landing and, assuming normal cruising speed, to fly after
that for at least 4.5 minutes.
5. Extent Of Relief CONOR LUKAS CROUCH Seeks And The Reason

CONOR LUKAS CROUCH Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b). Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, CONOR LUKAS CROUCH requests
relief from these Sections because the DJI Phantom 3 UA S does not require
airworthiness certificates. As set forth more fully below, the DJI
Phantom 3 UAS meets the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, CONOR LUKAS

CROUCH will use trained technicians t o perform maintenance, alterations, or preventive maintenance on the UAS ’ s using the methods, techniques, and practices prescribed in the UAS operating documents(i.e., the CONOR LUKAS

CROUCH Aerial Operations Manual, Monthly Maintenance Log, and DJI Phanto m 3 Instruction Manual). Furthermore, CONOR LUKAS CROUCH will document and
maintain all maintenance records for the and DJI Phantom 3 UAS.D. The Reasons Why Granting CONOR LUKAS CROUCH Request Would Be In The Public Interest; That Is, How It Would Ben efit The Public As A Whole. Granting the present Petition will further the public interest by allowing CONOR LUKAS CROUCH to safely, efficiently, and economically perform aerial video and photography of real estate, landmarks, for movies or television, for historical reference , search and rescue, surveying, architecture, roof and pipeline inspection, live events, construction sites, natural resource management, insurance companies, training on operation of UAS, and golf courses over certain areas of the
United States.

Additionally, use of the DJI Phantom 3 UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of CONOR LUKAS CROUCH’s p roposed operation of the DJI Phantom 3 UAS w ill be realized without implicating any privacy issues.

1. The Public Will Benefit From Decreased Congestion Of The NAS. The DJI Phantom 3 UAS is a battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft
tradit ionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of
the DJI Phantom 3 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and
air pollution, as well as increase the safety of life and property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduc ed. The
DJI Phantom 3 UAS do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handled by air
traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The DJI
Phantom 3

UAS. Conducting aerial acquisitions with the DJI Phantom 3 UAS, instead of manned aircraft, will greatl y benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, DJI Phantom 3 UAS produces no air pollution, and is the
most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically utilized for aerial video and photography, while burning approximately
20

- 30 gallons per hour of leaded a viation fuel.

By using the DJI Phantom 3 UASs to perform aerial acquisitions, the
substantial risk to life andproperty in the air and on the ground, which is usually associated with
traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI Phantom 3 UAS (weighing approximately 6 pounds 7.5 ounces, at their maximum gross weights with

len gth of 17.3 inches respectively, widths of 16 inches and 17.7 inches respectively, 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 typic ally conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations With The DJI
Phantom 3

UAS W ill Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 3 UAS is also an
economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom 3
UAS will allow United State s based companies, like CONOR LUKAS CROUCH , 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 aviat ion fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery powered
DJI Phantom 3 UAS is one such technology that not only allows companies greater operational flexibility com pared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft.

By operating the DJI Phantom 3 UAS , companies such as CONOR LUKAS CROUCH can remain competitive and profitable, and therefore, pr ovide greater job stability to employees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through
commercial use of the DJI Phantom 3 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.

E. The Reasons Why Granting The Exemption Wou ld Not Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which CONOR LUKAS CROUCH Seeks Exemption. 1. Reasons Why The DJI Phantom 3 UAS Meet The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333.In consideration of the size, weight, speed, and limited operating area
associated with the unmanned aircraft and its operation, CONOR LUKAS
CROUCH’s DJI Phantom 3 UAS meet the conditions of FMRA Se ction 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Section 333 provides authority for a UAS to operate without airworthiness
certification and sets forth requirements for considering whether a UAS
will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part:

(a) In General.

-- Notwithstanding any other requirement of this subtitle,

and not la ter than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely
in the national airspace system before completion of the plan and rulemaking required by

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

(b) Assessment of Unmanned Aircraft Systems.

-- In making the determination

under subsection (a), the Secretary shall determine, at a minimum

-- (1) which types of unmanned aircr aft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard

to users of the national airspace system or the public or pose a threat to
national security; and (2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems id entified

under paragraph (1). (c) Requirements for Safe Operation.

-- If the Secretary determines under
this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation

of such aircraft systems in the national airspace system. In seeking this exemption, CONOR LUKAS CROUCH submits that the DJI
Phantom 3 UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the charac teristics of the DJI Phantom 3 UAS; (b) the pilot certification requirement; and (c) the specific operating
limitations.a. The Specifications Of The DJI Phantom 3 UAS Demonstrate Its Safe
Characteristics.
The DJI Phantom 3 UASs does not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability.

i. Technical Specifications Of The DJI Phantom 3 UAS. The technical specifications of the DJI Phantom 3 UAS is set forth by the
DJI Phantom 3 User Manual, attached hereto as Appendix A.

ii. The DJI Phantom 3 UAS Autonomous Flight And Navigation Modes Enable The UAS To Remain Within A Defined Operational Ar ea. The DJI Phantom 3 UASs may be operated in both manual and fully autonomous flight modes. A complete description of the flight and navigational modes of the DJI Phantom 3 UAS is provided at pages 12

- 16

and 45

- 50 of the DJI Phantom 3 User Manuals, attac hed hereto as Appendix

B.

iii. The DJI Phantom 3 UAS Are Designed For Automatic Return To
Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation. When the Control Link is lost, the DJI Phantom 3 UAS will remain stationary, in fligh t, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 3 UAS does not reacquire control link data from the GCS, the UAS will assume that the
Control Link is lost and the UAS will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown.

A complete description of the Failsafe Functions of the DJI Phantom 3 at pages 13 through 15 of the DJI Phantom 3 User Manuals, attached hereto as Appendix B.

iv. The DJI Phantom 3 GCS And Its Operation. A complete description of the operation and specifications of the DJI Phantom 3 GCS and flight control software is provided at pages 40 through
47 of the DJI Phantom 3 User Manual. DJI Phantom 3 User Manuals are attached hereto as Appendix A.

b. Flight Operations Of DJI Phantom 3 UAS Is Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer.

CONOR LUKAS CROUCH will be the only person to act as a pilot in command (PIC) of the DJI Phantom 3 UAS. Additionally, a safety ob server will assist in flights.

c. Flights Of The DJI Phantom 3 UAS Will Be Conducted Pursuant To Specific Operating Limitations. In seeking this exemption, CONOR LUKAS CROUCH proposes to commercially operate the DJI Phantom 3 UASs for the special purpos e 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 UASs weighing

less than 55 pounds maximum gross weight: DJI Phantom 3 Unmanned Aircraft Systems. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant. 2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photography. 3. The UAS may not be flown at an indicated airspeed exceeding 20 knots.

4. The UA S must be operated at an altitude of no mor e than 400 feet above ground level(AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved by ATC. All altitudes reported to ATC must be in

feet AGL. 5. The UAs must be operated within visua l 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 (FP V) by the PIC or safety observer (SO)
is not permitted. 7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The SO and
PIC must be able to communic ate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the SO c an 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 outl ined 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 pr esent 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 petiti on 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

i s in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found
to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All
maintenance and alterations must be properly documented in the aircraft records. 11. Any UAS that has undergone maintenance or alterations that affect the

UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraft

records. 12. The pre

- flight inspection must acc ount for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the

relevant sections of the operating documents. 13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul , replacement, inspection, and life limit requirements.14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of repl acement/overhaul component parts must be

noted in the aircraft records, including total time in service, description of work accomplished, and the signature of the authorized person returning the UAS to service.
15. Each UAS operated under this exemption must comply with all

manufacturer Safety Bulletins. 16. The authorized person must make an entry in the aircraft record of
the corrective action taken against discrepancies discovered between inspections. 17. The PIC must possess at least a private pil ot 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 qualification criteria and demonstrates the ability to safely operate the UAS in a manner consi stent 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 qualification flight hours must be logged in a manner consiste nt with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator’s PICs are permitted under the terms of the exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, a nd experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. §
91.119. 19. UAS operations may n ot be conducted during night, as defined in 14
C.F.R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will be made at the FAA
office closest to proposed area of oper ations. 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 current FAA

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

21. The U A may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3
statute miles from the PIC. 22. If the UA loses communications or loses its GPS signal, it must return to a pre

determined 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.
24. The P IC is prohibited from beginning a flight unless (considering
wind and forecast ed weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA S with 25% battery power remaining. 25. The operator mu st obtain an Air Traffic Organization (ATO) 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 (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requirements.
26 . All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (N

Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be a s large as practicable.27. Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be
available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made available to the Administrator or any law

enforcement offi cial 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 conduc ted at least 500 feet from all nonparticipating persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The
operator must ensure that nonparticipating persons remain under such protection.

If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/ controller of such vessels, vehicles or structures has granted permission

and the PIC has made a safety assessment of th e risk of operating closer to those objects and determined that it does not present an undue hazard,
and; c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a).32. All operations shall be conducted over private or controlled

- access property 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.gov. 2. Reasons Why An Exemption From The Requirements Of Section 61.113(a)

And (b) Would Not Adversely Affect Safety.

CONOR LUKAS CROUCH 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 the DJI Phantom 3 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
UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate d istances from people, vessels, vehicles and structures.

Considering CONOR LUKAS CROUCH’s proposed area of operations, and the operating
limitations set forth

- above; the parallel nature of private pilot aeronautical knowledge re quirements to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI Phantom 3 UAS, CONOR LUKAS CROUCH
submits that the additional manned airmanship experience of a commercially certi ficated pilot would not correlate to the airmanship skills necessary for CONOR LUKAS CROUCH’s specific proposed flight operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all mat erial respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

CONOR LUKAS CROUCH will not allow any PIC to operate the DJI Phantom 3

UAS unless that PIC has demonstrated, by meeting minimum flight

- hour requirements or the DJI Phantom 3 UAS training and currency requirements, that the PIC is able to safely operate the DJI
Phantom 3 U AS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels,
vehicles and structures.Specifically, the PIC must have accumulated and logged, in a manner
consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a
minimum of 5 hours of those hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In addition to the hour requirem ents, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes).

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations
will ens ure an equivalent level of safety during

CONOR LUKAS CROUCH’s proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as fo llows:

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

tot al time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi

- rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have

accumulated and logged a minimum of 5 hours as a UAS pilot operating the sam e make and

model of UAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi

- rot or time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum , the flight

- hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the petitioner’s proposed operations. The FAA also finds that prior documented flight experience that was o btained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience

- building flights

can also be conducted under the grant of exemption to accomplish the required flight time. During training, proficien cy, and experience

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

Exemption No. 11138 at page 15.Accordingly, CONOR LUKAS CROUCH will ensure safe operations by not allowing any PIC to operate the DJI Phantom 3 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 UAS in a manner consistent with the exemption, including evasive and e mergency maneuvers and maintaining appropriate distances from people, vessels,
vehicles and structures.

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a)

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.7(a) will be maintained because prior to every flight, CONOR LUKAS CROUCH will ensure that the DJI Phantom 3 UAS
is in an airworthy condition based upon the UAS’s compliance with its operating

docu ments and as stated
in the conditions and limitations herein.

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety. The equi valent level of safety established by Section 91.121 will be
maintained because the altitude information of the DJI Phantom 3 UAS will be provided to the PIC via GPS equipment and a radio communications telemetry data link, which downlinks from the UA to the
GCS for active monitoring of the flight path and altitude. This altitude information, combined with CONOR LUKAS CROUCH’s operation of the DJI Phantom 3 UAS within visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section
91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically established by the UASs at ground level.

The FAA has previously grant ed relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157,

111 58, 11159, 11160, 11161).

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely Affect Safety. A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R.Section 91.151(b) as a result of (1) the technical specifications of the DJI Phantom 3 UAS; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, CONOR LUKAS CROUCH will ensure that it will safely operate

the battery powered DJI Phantom 3 UAS during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 3 UAS; the limitations on the proposed flight operations; and the location of the proposed operations, will

ensure an equivalent level of safety established b y 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Phantom 3 UAS provide audible and visual warnings to the PIC at the GCS when the UAS experiences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery power. At the critically low battery level, t he DJI Phantom 3 UAS will

descend and land automatically.

Significantly, previous exemptions granted by the FAA concerning Section
91.151 estab lish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exem ption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 1 1063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would

Not Adversely Affect Safety.

In seeking this exemption, CONOR LUKAS CROUCH submits that the equivalent

level of safety with regard to the regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91. 409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because CONOR LUKAS CROUCH will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e.,the Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual). Furthermore, CONOR LUKAS CROUCH will document and maintain all
maintenance

records for the DJI Phantom 3 UAS.

Since the DJI Phantom 3 UAS will be inspected as prescribed by the operating documents,

CONOR LUKAS CROUCH will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI
Phantom 3 User Ma nuals are attached hereto as Appendix A; a copy of the
DJI Phantom 3 UAS Maintenance LOG is attached

H ere to as Appendix B.

Likewise, the exemption sought will not adversely affect safety because

CONOR LUKAS CROUCH will use trained technicians to perfor m 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 9 1.407, 91.417(a) and 91.417(b), because all maintenance of the
DJI Phantom 3 UAS will

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

Significantly, previous exemptions granted b y the FAA concerning Sections 91.405(a), 91.407(a) (1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are
considered.

In consideration o f CONOR LUKAS CROUCH’s proposed operating limitations,

the operating documents, and the technical aspects of the DJI Phantom 3
UAS, CONOR LUKAS CROUCH submits that safety will not be adversely affected by granting exemption

from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted relief specific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11 063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

7. The FAA May Prescribe Any Other Conditions For Safe Operation.
In accordance with Section 333 of the FAA Modernizati on and Reform Act of 2012 (FMRA) and14 C.F.R. § 21.16 entitled Special Conditions, CONOR LUKAS CROUCH requests that the FAA prescribe special conditions for the intended operation of the DJI Phantom 3 UAS, which contain such safety standards that the Ad ministrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b),

91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAS for the limited purpose of conducting aerial video and photography over certain areas of the United States for compensation or hire. FMRA Section 333 sets forth the requirements for con sidering
whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without
airworthiness certification in accordance with any require ments that must be established for the safe operation of the UAS in the NAS. Likewise, the Administrator may prescribe special conditions pursuant to
14 C.F.R.

§ 21.16, for operation of the DJI Phantom 3 UAS, since the airworthiness regulations of 14 C. F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special Conditions, states the following:

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

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

because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he

prescribes special conditions and ame ndments thereto for the product. The special

conditions are issued in accordance with Part 11 of this chapter and contain such safety

standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to

establish a level of safety eq uivalent to that established in the regulations.See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for CONOR LUKAS CROUCH’s intended operation of the DJI Phantom 3 UAS, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14

C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 9 1.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). • A Summary That Can Be Published In The Federal Register, stating:
The Rules From Which CONOR LUKAS CROUCH Seeks Exemption:

CONOR LUKAS CROUCH seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

A Brief Description Of The Nature Of The Exemption CONOR LUKAS CROUCH
Seeks:

This exemption will permit CONOR LUKAS CRO UCH to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial
video and photography over certain areas of the United States.

• Any Additional Information, Views, Or Arguments Available To Support CONOR LUKAS CROUCH ’s Request. This Petition is made pursuant to the FAA Modernization and Reform Act of
2012

(FMRA) Section 333, which directs the Secretary of Transportation to
determine if certain UAS may operate safely in the NAS. As such, CONOR

LUKAS CROUCH request f or exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11,
as set forth above.

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

to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness
certification.As discussed in detail above, CONOR LUKAS CROUCH will operate the DJI

Ph antom 3 UAS safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.

CONCLUSION

As set forth herein, CONOR LUKAS CROUCH seeks an exemption pursuant to 14

C.F.R. § 11.61 and Sect ion 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI Phantom 3 UAS commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography. By granting th is Petition, the FAA Administrator will be fulfilling the Congressional

mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing CONOR LUKAS CROUCH to safely, efficiently, and economically

oper ate the DJI Phantom 3 UAS commercially within the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and the
FAA Modernization and Reform Act of 2012, Section 333, CONOR LUKAS CROUCH respectfully requests that the Administrator grant th is Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a) (2), and 91.417(a) & (b), and permit CONOR LUKAS CROUCH to operate the

DJI
Phantom 3 UAS comm ercially for the purpose of conducting aerial video and photography. Dated: June 12, 2015

Respectfully submitted
,

CONOR LUKAS CROUCH

715 MOSS CREEK DR.

CAYCE, SC 29033

CONORCROUCH@AOL.COMAppendices:

A

– DJI Phantom 3 Specifications Data Sheet

APPENDIX

– A

DJI Phantom 3 TECHNICAL SPECIFICATIONS

CONOR LUKAS CROUCH only utilizes safe and reliable UAS. DJI is an industry leader in small UAS production. DJI UASs are loaded with ground breaking software enabling the user to set parameters whic h will not allow flight into controlled airspace.

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

- time altit ude and location information to the PIC via the linked monitor (smart phone/tablet devices)

2.2.1 Aircraft
2.2.1.1 Model

– Phantom 3 2.2.1.2 Weight (Battery Included)

– 1280 grams 2.2.1.3 Hovering Accuracy (GPS Mode)

– Vertical: +/

- 10cm; Horizontal: +/

- 1m 2.2.1.4 Max Angular Velocity

– Yaw: 200°/s 2.2.1.5 Max Tilt Angle

- 35° 2.2.1.6 Max Ascent Speed

– 5m/s 2.2.1.7 Max Descent Speed

– 3m/s 2.2.1.8 Max Speed

– 16m/s (ATTI mode, no wind

– NOT RECOMMENDED) 2.2.1.9 Max Flight Altitude

– 6000m
2.2.1 .10 Max Flight Time

– Approximately 23 minutes
2.2.1.12 Motor Model

– DJI 3510 2.2.1.13 Propeller Model

– DJI 13452.2.1.14 Operating Temperature Range

– 14°F to 104°F (

- 10°C to 40°C)

2.2.1.15 Dimensions

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

– ZENMUSE X3 2.2.2.2 Output Power (with camera)

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

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

- ±0.03° 2.2.2.5 Mounting

– Detachable 2.2.2.6 Controllable Range

– Pitch:

- 90° to +30°; Pan: ±320° 2.2.2.7 Mechanical Range

– Pitch:

- 125° to 45°; Pan: ±330° 2.2.2.8 Max Controllable Speed

– Pitch: 120°/s; Pan: 180°/s

2.2.3 Camera
2.2.3.1 Name

– Sony EXMOR
2.2.3.2 Model

– 12.4M Pixel
2.2.3.3 Total Pixels

– 12.4M
2. 2.3.4 Effective Pixels

– 12.76M 2.2.3.5 Image Max Size

– 4000x3000 2.2.3.6 ISO Range

– 100

- 3200
2.2.3.7 Field of View

- 94°

2.2.3.8 CMOS

– Sony EXMOR 1/2.3” 2.2.3.9 HD Video Recording

– UHD(4K): 4096x2160p24/25, 3840x2160p24/25/30; FHD: 1920x1080p24/2 5/30/48/50/60; HD: 1280x720p24/25/30/48/50/60 2.2.3.10 Operating Temperature Range

- 32°F

- 104°F (0°C

- 40°C)

2.2.4 Transmitter
2.2.4.1 Name

– C1 2.2.4.2 Operating Frequency

– 5.728

- 5.850GHz; 2.400

- 2.483GHz 2.2.4.3 Communicating Distance (unobstructe d)

– 2000m 2.2.4.4 Output Power

– 9W 2.2.4.5 Operating Temperature Range

- 14°F to 104°F (

- 10°C to 40°C) 2.2.4.6 Battery

– 600mAh LiPo 2S