### UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC

Regulatory DocketNo.

_____ _

IN THE MATTER OFTHE PETITIONFOREXEMPTION OF: LAWRENCE BRIDGES SOUTHERNAIR SERVICES FOR AN EXEMPTION SEEKING RELIEF FROMTHE REQUIREMENTS OF TITLE 14 OFTHE CODE OFFEDERALREGULATIONS SECTIONS 61.113(a) & 

### (b). 91.7(a). 91.121. 91.15Hb). 91.405(a). 91.407(a)(l), 91.409(a)(l) & 

### (a)(2). AND 91.417(a) & 

### (b) CONCERNING COMMERCIAL OPERATION OF DJI PHANTOM 2 VISION+ AND DJIINSPIRE 1 UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORMACT OF2012 (PUBLIC LAW 112-95)

Submitted onMay 22, 2015

Lawrence Bridges. Owner Black Forest GunWurk. LLC DBA: SAS Defense DBA: SouthernAir Services 1

01 Demorest Square Demorest GA 30535 706-778-1440 Hereafter referred to as "SAS".

### TABLE OF CONTENTS Page GLOSSARY OF ABBREVIATIONS............................................................................................................3 SUl\1Mr\RY.........................................................................................................................4 INTRODUCTION AND INTERESTS OF PETITIONER.................................................4 Bi-\CI(C1RC)lJND................................................................................................................5 BASIS FOR PETITION...........................................................................................................................S NAME AND ADDRESS OF PETITIONER..........................................................7 TllE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH SAS SEEKS EXEMPTI()N..........................................................................................................8 THE EXTENT OF RELIEF SAS SEEKS AND THE REASON SAS SEEKS TI-lE RELIEF...................................................................................11 THE REASONS WHY GRANTING SAS REQUEST WOULD BE IN THE PUBLIC INTEREST .................................................................................14 THE REASONS WHY GRANTING THEEXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY................................................................................................................17 CC)NCLtJSION.................................................................................................................32AGL 

### AOI ATC 

### ATO AV 

### CFR COA FAA fAR GCS GPS LOL NAS 

### NOTAM 

### PJC Section 333 

## so SOP UA UAS 

### VFR VLOS 

### VMC VTOL 

### GLOSSARY OF ABBREVIATIONS Above Ground Level Area oflnterest Air Traffic Control Air Traffic Organization Aerial Vehicle Code ofFederal Regulations Certificate ofAuthorization Federal Aviation Administration Federal Aviation Regulation Ground Control Station Global Positioning System Loss ofLink National Airspace System Notice to Airman Pilot In Command FAA Modernization and Reform Act of2012 (FMRA) Safety Observer Standard Operating Procedures Unmanned Aircraft Unmanned Aircraft System Visual Flight Rules Visual Line ofSite Visual Meteorological Conditions Vertical Takeoffand Landing

### SUMMARY SAS seeks exemptionfrom the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.12L 91.15l(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b). to operate an Unmanned Aircraft Systempursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA). This exemption will permit SAS to operate an Unmanned Aircraft System (UAS) for the commercial purpose ofconducting PI-IOTOGRAMMETRY, AERIAL PHOTOGRAPHY, MAPPING and SURVEYING

over certain areas ofthe United States.



### INTRODUCTION AND INTERESTS OF THE PETITIONER My name is Lawrence Bridges, I amthe owner ofSAS. I hold an ATP MultiEngine Land. certificate #2737408, date ofissue 07 MAR2008, with five (5) PIC Type Ratings. I have served as a Part 121 Air CarrierPIC with over 8000 hours and was a Part 135 Air Taxi ChiefPilot. Since there are no current UA V regulations onthe booksjust yet, I am seeking exemptions pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012. The objective is to add services to my existing company in orderto offer PHOTOGRAMMETRY, AERIAL PHOTOGRAPHY, MAPPING and SURVEYING

over certain areas ofthe United States for commercialpurposes.BACKGROUND Unmanned Aircraft Systems: DJI Phantom 2 Vision+, DJI Inspire 1UASs SAS seeks an exemptionto operate DJI systems for compensation orhire within the NAS. The DJI Phantom 2 Vision+ and DJI Inspire 1are vertical takeoffand landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The DJI Phantom 2 Vision+has a maximum gross weight ofapproximately 2 pounds 11 ounces, while having a length of 16 inches width of 16 inches, height of8 inches, and a maximum speed ofapproximately 29 knots. The OJI Inspire 1has a maximum gross weight of6pounds 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 2 Vision+ and DJI Inspire 1 UAs are equipped with four main rotors; driven by LithiumPolymerbatterypowered electric motors. The DJI Phantom 2 Vision+ and DJI Inspire 1UAs that will be operated by SAS will be registered in accordance with 49 U.S.C. 44103, 

### Registration of Aircraft, as well as I4 C.F.R Part 47, 

### AircrqfiRegistration, and marked in accordance with 14 C.F.R. Part 45, 

### identification andRegistrationMarking.

BASIS FORPETITION Petitioner, SAS, pursuant to the provisions ofthe Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of2012 (FMRA), Section 333, 

### S!xcialRulesfin· Certain UnmannedAircraftSystems, herebypetitions the Administrator to commercially operate the DJI Phantom 2 Vision+, DJI Inspire 1UASs 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)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b). In consideration ofthe speed, weight, size, and limited operating area associatedIn consideration ofthe speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, SAS operation ofDJI Phantom 2 Vision+ and D.lllnspire 1UASs meets the conditions ofFMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, SubpartH. Accordingly, SAS requests relieffrom Sections 91.405(a), 91.407(a)(1), 91.409(a)(l) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate. SAS submits that the requested reliefis proper since fi-n equivalent level ofsafety will be ensured. SAS will use experiencedpersonnel ortechnicians to perform maintenance, alterations, orpreventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1Instruction Manual). Furthermore, SAS will document and maintain all maintenance records for the DJI Phantom 2 Vision+ and DJI Inspire 1UASs. Relieffrom certain requirements ofSection 61.113(a) and (b), entitled

### Private pilotpriPileges 

### andlimitations: Pilot in command, is requested by SAS to the extent necessary to allow a Pilot in Command (PIC) holding a privatepilot or higher level certificate, as well as an airman medical certificate, and who has demonstrated, by meeting minimum flight- hour and currency requirements, thatthe PIC is able to safely operate the DJI Phantom 2 Vision+ and DJI Inspire 1UASs in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. SAS seeks relieffrom Section 91.7(a), entitled 

### Civil aircraft airworthiness, because the D.II Phantom 2 Vision+ and DJI Inspire 1UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, SAS submits that he will ensure that the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs are in

an airworthy condition, priorto every flight, by determining thatthe UASs are incompliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1 Instruction Manual), and thatthe aircraft are in a condition for safe t1ight. '- SAS also seeks an exemptionfrom the requirements ofSection 91.121, entitled 

### AltimeterSe!lings, as the DJI Phantom 2 Vision+ and DJI Inspire 1 UAs will not have a typical barometric altimeter onboard. However, altitude information ofthe DJI Phantom 2 Vision+ and DJI Inspire 1 UAs will beprovidedto the PIC via Global Positioning System (GPS) equipment and radio communications telemetry datalink, which downlinks from the UA to the GCS for active monitoring oftheflight path. This altitude information, combined with SAS's operation ofthe DJI Phantom 2 Vision+ and DJI Inspire I UASs within visual line ofsight, at orbelow400 feet AGL, will ensure a level ofsafety equivalent to Section 91.121. Additionally, SAS seeks an exemption from the requirements ofSection 91.151 (b), entitled 

### Fuel requirementsforflight in VFR conditions. SAS submitsthat safety will not be affected by operation ofthe DJI Phantom 2 Vision+ and DJI Inspire 1 UAs during daylighthours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery powerto fly for a total duration ofapproximately 13.5 minutes to the first point ofintended 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, SAS provides the following information in support ofits petition for exemption:

A. Name and Address ofthe Petitioner. The name and address ofthe Petitioner andpoint ofcontact is: Lawrence Bridges Southern Air Services I0I Demorest Smmre Demorest GA 30535 706-778-1440 captbridges@aol.comB. The Specific Sections of 14 C.F.R. From Which SAS Seeks Exemption. 1. SAS Seeks Exemption from the Requirements ofSection 61.113(a) and (b). Section 61.113, entitled Private pilotprivileges and limitations: 

### Pilot in command, subsections (a) and (b) prescribe the following, inrelevant part: (a) No person who holds a private pilot certificate may act as a pilotin command (PIC) ofan aircraft that is carryingpassengers or property for compensation or hire; nor may that person, for compensation orhire, act as PIC ofan aircraft. (b) A Drivate pilot may, for compensation orhire, act as PIC ofan 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 orproperty for compensationor hire. 2. SAS seeks Exemption from the Requirements ofSection 91.7(a). Section 91.7, entitled 

### Civil aircraftairworthiness, subsection (a), states the following: (a) No person may operate a civil aircraft unless it is in an airworthy condition.

3. SAS seeks Exemption from the Requirements ofSection 91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: (a) Each person oDerating an aircraft shall maintain the cruising altitude or flight level ofthat aircraft, as the case may be, by reference to an altimeter that is set, when operating-- (l) Below 18,000 feet MSL, to-- (i) The current reDorted altimeter setting ofa station along the route and within 100 nautical miles ofthe aircraft; (ii) Ifthere is no station withinthe areaprescribed inparagraph (a) (1) (i) ofthis section, the currentreported altimeter setting ofan appropriate available station; or (iii) In the case ofan aircraft not equipped with a radio, the elevation of the departure aimort or an appropriate altimeter setting available before departure.4. SAS seeks 

### Exemption from the Requirements ofSection 91.151(b). Section 91.151, entitled Fuel requirementsforflight in VFR conditions, subsection (b). states the following: (b) 

### No oerson mavbezin aflizht in a rotorcraft under VFR conditions unless (considerinz vvindandforecast weather conditions) there is enouzhfuel to flv to 

### the first ooint ofintendedlandinz and, assumingnormal cruisingspeed, to jly C(/fer thatfor at least20 minutes. 5. SAS seeks 

### Exemption from the Requirement ofSection 91.405(a). Section 91.405, entitled Maintenance required, subsection (a), states the following: Each owner or operator ofan 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) ofthis section, have discrepancies repaired as prescribed inpart 43 ofthis chapter[.] 6. SAS seeks 

### Exemption from the Requirements ofSection 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 mav operate anv aircraftthat has undergone maintenance, preventive maintenance, rebuilding, or alteration unless-- ( I) 

### It has been approved for return to service by a person authorized under § 43.7 ofthis chapter[.] 7. SAS seeks 

### Exemption from the Requirements ofSections 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) ofthis section. no person mav operate an aircraft unless, within the preceding 12 calendar months, it has had-- (1) An annual insoection in accordance with oart 43 ofthis chaoter and has been aooroved for return to service by a person authorized by§ 43.7 of this chapter; or (2) An insoection for the issuance ofan airworthiness certificate in accordance withpart 21 ofthis chapter. 8. SAS seeks 

### Exemption from the Requirements ofSections 91.417(a) and 91.417(b). Section 91.417, entitledMaintenance 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) ofthis section: (1) Records ofthe maintenance, preventive maintenance, and alteration and

### records ofthe 1 00-hour. annuaL orogressive, and other required or aporoved insoections, as aporopriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance ofan aircraft. The records must include-- (i) 

### A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date ofcompletion ofthe workperformed; and (iii) The signature, and certificate number ofthe person approvingthe aircraft for return to service. (2) Records containing the following information: (i) The total time in service ofthe airframe, each engine, each propeller, and eachrotor. (ii) The current status oflife-limited parts ofeach airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul ofall items installed on the aircraft which are requiredto be overhauled on a specified time basis. (iv) The current inspection status ofthe aircraft includingthe time since the last inspection required by the inspectionprogram under which the aircraft and its appliances are maintained. (v) The current status ofapplicable airworthiness directives (AD) and safety directives including, for each, the method ofcompliance, the AD or safetydirective number and revision date. Ifthe AD or safety directive involves recurring action, the time and date whenthe next action is required. (vi) Copies ofthe forms prescribed by (3 

### 43.9(d) ofthis chapterfor each maior 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 paragraph (a)(1) 

### ofthis section shall be retained unti1the work is repeated or superseded by other work or for 1year after the work is performed. (2) The records specified in paragraph (a) (2) ofthis section shall be retained and transferred with the aircraft at the time the aircraft is sold. (3) A list ofdefects furnished to a registered owner or operator under (3 

### 43.11 ofthis chaoter shall be retained until the defects are repaired and the aircraft is approved for return to service. C. The Extent ofReliefSAS Seeks and the Reason SAS Seeks the Relief. I. Extent ofReliefSAS Seeks and the Reason SAS Seeks Relieffrom Section 61.113(a) and (b). 

### Relieffrom Section 61.113(a) and (b) entitled

### Privatepilotprivileges and limitations: Pilot in command, 

### is requested to the extent necessary to allow a PIC holding

aprivate pilot orhigher level certificate, as well as a current and valid airman medicalcertificate, and who has met certain f1ight-hour and currency requirements, to conduct the proposed UAS t1ight operations for compensation orhire. This reliefis requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation orhire, act as PIC ofan aircraft in connection with any business or employment if: (1) The flight is onlyincidental to that business or employment; and (2) The aircraft does not carrypassengers orproperty for compensation or hire. As set forth more fully below, SAS submits that an equivalent level ofsafety will be maintained because no PIC will be allowed to operate the DJI Phantom 2 Vision+ UAS or DJllnspire 1UAS unless that PIC has met certain flight-hour and currency requirements, demonstrating that the PIC is able to safely operate eitherthe DJI Phantom 2 Vision+ or DJI Inspire 1UAS in a manner consistent withthe 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, SAS submits that all flights oftheDJI Phantom 2 Vision+ and DJI Inspire I UASs, conducted by the PIC pursuant to the grant ofthis Petition: (1) will be incidental to SAS's business; and (2) will not carry passengers orproperty for compensation orhire. 2. Extent ofReliefSAS Seeks and the Reason SAS Seeks Relieffrom Section 9l.7(a).

Relieffrom Section 91.7(a) entitled 

### Civil aircraftairworthiness, is requested to the extent required to allow SAS to determine that the DJI Phantom 2 Vision+ and DJI Inspire I UASs are in airworthy conditionprior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., the SAS Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1Instruction Manual). SAS seeks the requested reliefbecause the DJI Phantom 2 Vision+ and DJIInspire 1UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 2I. Subpart H. Therefore, SAS will ensure that the DJI Phantom 2 Vision+ and DJI Inspire I UASs are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire I Instruction Manual) priorto every flight, and further, determine that the aircraft are in condition for safe f1ight, as stated in the conditions and limitations below.

3. Extent ofReliefSAS Seeks and the Reason SAS Seeks Relieffrom Section 91.121.

Relieffrom Section 91.121, entitled Altimeter settings, maybe required to allow f1ight operations ofthe DJI Phantom 2 Vision+ and DJI Inspire 1UASs, 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 requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), SAS seeks the requested reliefbecause the DJI Phantom 2 Vision+ and DJI Inspire 1UA's altimeter may be set on the ground to zero feet AGL, ratherthanthe local barometric pressure or field altitude, before each f1ight. Considering the limited altitude ofthe proposed operations, relieffrom 14 CFR 9I. I 2 I is sought to the extent necessary to comply withthe applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level ofsafety will be maintained since the DJI Phantom 2 Vision+ and DJI Inspire 1UAs are equipped with

a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established priorto each flight, and provides thePIC with altitude information ofthe UA on the heads-up display ofthe GCS.

4. Extent ofReliefSAS Seeks and the Reason SAS Seeks Relieffrom Section 91.151(b).Relieffrom Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extentrequired to allow t1ights ofthe battery powered DJI Phantom 2 Vision+ and DJI Inspire 1UAs during daylighthours in visual meteorological conditions (VMC), under visual f1ight rules (VFR), for a total duration of 13.5 minutes to the first point ofintended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. SAS seeks the requested reliefbecause without an exemption from Section 91.151(b), the flight time duration ofthe battery powered DJI Phantom 2 Vision+ and DJI Inspire 1UAs will severely constrain the practicality ofany aerial video

or still photo flight operations that SAS proposes to conductpursuantto this Petition. Significantly, as set forth below, the technical specifications ofthe DJI Phantom 2 Vision+ and DJI Inspire 1UASs, the DJI Phantom 2 Vision+ and DJI Inspire 1operating documents, and SAS proposed operating limitations, ensure that SAS will safely operate the battery powered DJI Phantom 2 Vision+ and DJI Inspire 1UAs during daylight hours in visual meteorological conditions (VMC), under visual f1ight rules (VFR), with enough battery power to f1y for a total duration of 13.5 minutes to the first point ofintended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.



### 5. Extent ofReliefSAS Seeks and the Reason SAS Seeks Relieffrom Sections 91.405(a), 91.407(a) (1), 91.409(a) (1) & 

### (a) (2), and 91.417(a) & 

### (b).

Since Sections 9l.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, SAS requests relieffrom these Sections because the DJI Phantom 2 Vision+ and DJI Inspire 1UASs do not require airworthiness certificates. As set fmih more fully below, the DJI Phantom 2 Vision+ and DJI Inspire 1UASs meet the conditions ofFMRA Section 333 for operation without an airworthiness certificate. Accordingly, SAS will use trained technicians to perform maintenance, alterations, orpreventive maintenance onthe UASs using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the SASAerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ and D.lI Inspire 1Instruction Manual). Furthermore, SAS will document and maintain all maintenance records for the DJI Phantom 2 Vision+ and DJI Inspire 1UASs.



### D. The Reasons Whv Grantin2: SAS ReuuestWould BeInThePublicInterest; That Is, How ItWould Benefit The Public As A Whole. Granting the present Petition will further the public interest by allowing SAS safely, efficiently, and economicallyperform PHOTOGRAMMETRY, AERIAL Pl-IOTOCiRAPHY, MAPPING and SURVEYING over certain areas ofthe United States. Additionally, use ofthe DJI Phantom 2 Vision+ and DJI Inspire 1UASs will decrease congestion ofthe NAS, reducepollution, and provide significant benefits to the economy. Notably, the benefits ofSAS'sproposed operation ofthe DJI Phantom 2 Vision+ and DJI Inspire 1UASs will be realized without implicating any privacy issues. 1. The Public Will BenefitFrom Decreased Congestion OfThe NAS. The DJI Phantom 2 Vision+ and DJI Inspire 1UAs are batterypowered and serve

as a safe, ef1icient, and economical alternative to the mmmed aircrafttraditionally utilized

Lo obtain aerial imagery. By reducing the amount ofmmmed aircraft needed to perform aerial acquisitions, an exemption allowing the use ofa DJI Phantom 2 Vision+ orDJI Inspire I UAS would reduce the amount ofmmmed aircraft inthe NAS, reduce noise and air pollution, as well as increase the safety oflife and property in the air and onthe ground.Furthermore, by reducing the number ofmanned aircraft operating inthe NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The OJI Phantom 2 Vision+ and DJI Inspire 1UAs do not require an airport to takeoffor land. Likewise, a reduction ofmanned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handledby air traffic control during the ground, takeoff: departure, arrival, and landing phases offlight operations.2. The Public Will Benefit From The Safetv And Efficiency OfThe DJI Phantom 2 Vision+ and DJI Inspire 1 UASs. 

### Conducting aerial acquisitions with the DJI Phantom 2 Vision+ and DJI Inspire 1 U

### ASs, instead ofmanned aircraft, will greatly benefitthe public by drastically reducing the levels ofair and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, the DJI Phantom 2 Vision+ and DJI Inspire 1UASs produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinderinternal combustion engine aircraft that are typically utilized for aerial video and photography, while burning approximately 20-30 gallons per hour ofleaded aviation fuel. The DJI Phantom 2 Vision+ and DJI Inspire 1UAs, while reducing the carbon footprint ofaerial 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 2 Vision+ and DJI Inspire 1

### UASs to perform aerial acquisitions, the substantial risk to life and property inthe 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 offlight crew members located onboard the aircraft, the DJI Phantom 2 Vision+ and DJI Inspire 1

### UAs (weighing approximately 2 pounds 11 ounces and 6pounds 7.5 ounces respectively, attheir maximum gross weights with lengths of 16 inches and 17.3 inches respectively, widths of 16 inches and 17.7 inches respectively, and with no fuel onboard), has less physical potential for collateral damage to life and property on the ground, and inthe air, compared to the manned aircraftthattypically conduct similar operations (weighing approximately 6,000 pounds with a wingspan ofapproximately 42 feet, a length of34 feet, and a fuel capacity of 180 gallons).3. Performin!! Aerial Video and Photo!!raohv Ooerations With The DJI Phantom 2 Vision+ and DJI Inspire 1UASs Will Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 2 Vision+ and DJI Inspire I UASs are also an economical alternative to using manned aircraftto conduct similar aerial operations. As such, operation ofthe DJI Phantom 2 Vision+ and DJI Inspire 1 UASs will allow United States based companies, like SAS, to remain competitive and contribute to growth ofthe U.S. economy. Specifically, with the rising cost ofaviation fuel and the Environmental ProtectionAgency ("EPA") regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery powered DJI Phantom 2 Vision+ and DJI Inspire 1UASs is one such technology that not only allows companies greater operational flexibility comparedto manned aircraft, butprovides such flexibility without the high operational cost ofa traditional mmmed aircraft. By operating the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs, companies such

as SAS, can remain competitive and profitable, and therefore, provide greaterjob stability to employees and contractors, which will ultimately contributeto growth ofthe U.S. economy. Improved financial performm1ce ofU.S. companies, through commercial

use ofthe DJI Phantom 2 Vision+ and DJI Inspire 1 UASs, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allovv·s companies to invest in research and development in orderto remain competitive both in the United States and abroad. 4. The1·e Are No Privacy Issues. Similar to the manned aerial acquisition flight operations thathave been conducted for decades, SAS's proposed operation ofthe DJI Phantom 2 Vision+ and DJI Inspire 1 UASs will not implicate any privacy issues. Specifically, the DJI Phantom 2 Vision+ and

### DJI Inspire 1UASs will be operated only in compliance with operating documents (i.e., the SAS Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1Instruction Manual) whichrequires 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 Whv Grantine: The Exemotion Would NotAdverselv Affect Safety, Or How The Exemotion Would Provide A Level OfSafetv At LeastEqual To 

### That P1·ovided By The Rule From Which SAS Seeks Exemption. 1. Reasons Whv The DJI Phantom 2 Vision+ and DJI Insoire 1 UAs Meet The Conditions OfTheFAA Modernization and Reform Act of2012 (FMRA) Section 333.



### In consideration ofthe size, weight, speed, and limited operating area associated \Vith the unmanned aircraft and its operation, SAS's operation ofthe DJI Phantom 2 Vision+ and OJI Inspire 1UASs meet the conditions ofFMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

### Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users ofthe NAS or the public, or otherwisepose a threat to national security. Specifically, FMRA Section 333 states the following, inpart: (o) in General.--Notwithstandinf!anv other reauirement of this subtitle. andnot later than 180 davs after the date of enactment of thisAct. the Secretarv of Tranmortation shall determine if certain unmannedaircraftsvstems mav ooerate safelv in the national airsvace svstem before comvletion of the olan andrulemakinz reauiredbysection 332 of thisActor the guidance required by section 334 of thisAct. (b) AssessmentofUnmannedAircraftSvstems.--In makinf! the determination under subsection (a), the Secretary shalldetermine, ata minimum-- (!) which tvves of unmannedaircraftsvstems. if anv. as a result of their size. weidtt. sveed. overational cavabilitv. vroximitv to aimorts and vovulatedareas. andoveration within visual line of sif!htdo notcreate ·a hazardto users of the nationalairspace system. or thepublic orpose a threat to nationalsecurity; and (2) ·whether a certificate of waiver, certificate of authorization, orairworthiness certification undersection 44704 of title 49. United States Code. is reouiredfor the overation of unmannedaircrqft systems identified underparagraph (1). (c) Reouirementsfor Safe Overation.--Jfthe Secretarvdetermines under this section that certain unmannedaircraftsvstemsmav overate safelv in the nationalairsvace svstem. the Secretarvshall establish reouirementsfor the safe operation of such aircraftsystems in the nationalairspace system.



### In seekingthis exemption, SAS submits thatthe DJI Phantom 2Vision+ and DJI Inspire IUASs can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics ofthe DJI Phantom 2 Vision+ and DJI Inspire 1 UASs; (b) the pilot certificationrequirement; and (c) the specific operating limitations. a. The Snecifications OfThe DJIPhantom 2 Vision+ and DJIInspire 1 UASs DemonstrateIts Safe Characteristics.

The DJI Phantom 2 Vision+ and DJI Inspire 1UASs do not create ahazard to

users ofthe NAS or the public, or otherwise pose a threatto national security considering its size, weight, speed, and operational capability. i. Technical Snecifications OfTheDJI Phantom 2 Vision+ and DJI

Inspire 1 UASs.

The technical specifications ofthe DJI Phantom 2 Vision+ and DJI Inspire 1 UASs are set forth by the DJI Phantom 2 Vision+ and DJI Inspire 1 Specifications and Data Sheet, attached hereto as Exhibit A and B. ii. TheDJIPhantom 2 Vision+ and DJIInsnire 1 UASs Autonomous Fli2:ht And Navi2:ation Modes EnableTheUASs To Remain Within A Defined OperationalArea.

The DJI Phantom 2 Vision+ and DJI Inspire 1UASs may be operated in both manual and fully autonomous flight modes. A complete description ofthe flight and navigational modes ofthe DJI Phantom 2 Vision+ and DJI Inspire 1UASs is provided at pages 25-35 ofthe DJI Phantom 2 Vision+ andpages 12-16 and 45-50 ofthe DJI Inspire I User Manuals, attached hereto as Exhibit C and D. iii. TheDJI Phantom 2 Vision+ and DJI Insnire 1 UASs AreDesi2:ned ForAutomatic Return To Home Point OrHoverIn TheEvent Of Loss OfTheControlLinkOrNavigation.When the Control Link is lost, the DJI Phantom 2 Vision+ and DJI Inspire 1UAs will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 2 Vision+ and DJI Inspire 1UAs do not reacquire control link datafrom 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 takeoffposition and shutdown. A complete description ofthe Failsafe Functions ofthe DJIPhantom 2 Vision+ UAS are set forth at pages 27 through 29 and for the DJI Inspire 1 at pages 13 through 15 ofthe DJI Phantom 2 Vision+ and DJI Inspire 1User Manuals, attached hereto as Exhibit C and D. 

### iv. The DJI Phantom 2 Vision+ and DJI Inspire 1 GCS and Its Operation.

A complete description ofthe operation and specifications ofthe DJI Phantom 2 Vision+ and DJI Inspire 1 GCS and flight control software is provided at pages 32 through 43 ofthe DJI Phantom 2 Vision+ User Manual andpages 40 through 47 ofthe DJI Inspire 1User Manual. DJI Phantom 2 Vision+ and DJI Inspire 1 User Manuals are attached hereto as Exhibits C and D. 

### b.**Fli~ht** 

### Ooerations OfDJIPhantom 2 Vision+ and DJIInsoire 1UASs Are Limited To TheLine OfSight OfA Certificated Pilotin Command With A Safety Observer. SAS will only utilize certificated pilots who possess a current and valid airman medical certificate to act as a pilot in command (PIC) ofthe DJI Phantom 2 Vision+ and DJI Inspire 1UASs. Additionally, a safety observer will assist all pilots during flight time.



### c.**Fli~hts** 

### ofDJI Phantom 2 Vision+ and DJI Insoire 1UASs Will Be Conducted PursuantTo Specific OperatingLimitations. In seeking this exemption, SAS proposes to commercially operate DJI Phantom 2 Vision+ and DJI Inspire 1 UASs for the special purpose ofconducting aerial video and photography over certain areas ofUnited States, pursuantto the following specific operating limitations: 1. Operations authorized by this grant ofexemption will be limited to thefollowing aircraft described in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: DJI Phantom 2 Vision+ and 

### DJI Insnire 1 Unmanned Aircraft Systems. Proposed operations ofany other aircraft will require a newpetition or a petition to amend this grant. 2. t!AS onerations undet: this_ exemntion will be limited to conducting operations for the purpose ofaenal vrdeo and photography. 3. The UAs may not be flown at an indicated airspeed exceeding 20 knots. 4. The UA must be ODerated at an altitude ofno morethan400 feet above ground level (AGL), as indicated by the procedures specified inthe operating documents unless a special rec.lUest is made and approved by ATC. All altitudes reported to ATC must be in feet AGL. 5. The UAs must be ODerated within visual line ofsight (VLOS) ofthe PIC at all times. This rec.lUires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified onthe PIC's FAA-issued airman medical certificate. 6. The use offirst person view (FPV) by the PIC or safety observer (SO) is not permitted. 7. All operations must utilize a safety observer (SO). The SO maybe used to satisfy the VLOS requirement as long as the PIC always maintains VLOS caoability. The SO and PIC must be able to communicate verbally at all times. Electronic messaging ortexting is not permitted during flight operations. The PIC must be designated before the flight and cannottransferhis orher designation for the duration ofthe flight. The PIC must ensure that the SO can perform the functions prescribed in the operating documents.

**~-** The SO must not nerform 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 ooerating documents and the grant ofexemption mustbe accessible during UAS onerations and made available to the Administrator uponrequest. Ifa discreDancy exists between the conditions and limitations contained in the grant ofexemntion and the txocedures outlined in the operating documents, the conditions and limitations contained inthe grant ofexemptiontake precedence and must be followed. Otherwise, the operatormust follow the procedures as outlined in its ODerating documents. The operatormay update orrevise its operating documents. Itis the operator's responsibility to track suchrevisions and present updated and revised documents to the Administrator uponrequest. The onerator must also present updated and revised documents ifit petitions for extension or amendment to the grant ofexen11Jtion. Ifthe operator determines that any undate or revision would affect the basis upon which the FAA granted the exemDtion. then the oDerator must netition for amendment to its grant ofexemntion. The FAA's UAS Integration Office (AFS-80) maY be contacted ifquestions arise regarding updates or revisions to the operating documents. 10. Prior to each flight the PIC mustinspectthe UAS to ensure that it is in a condition for safe f1ight. Ifthe inspectionreveals a condition that affects thesafe cmeration ofthe UAS, the aircraft is orohibited from operating until the necessary maintenance has beenperformed andthe UAS is found to be in a condition for safe flight. The Ground Control Stationmustbe included in the oreflight insnection. 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 ooeration or flight characteristics, e.g. replacement ofa flight critical comnonent must undergo a functional test flight. The PIC who conducts the functional test flight mustmake an entry in the aircraft records. 12. The m·e-flight inspection must account for all potential discrepancies, e.g. inonerable components, items, or equipment not already covered in the relevant sections ofthe operating documents. 13. The onerator must follow the UAS manufacturer's aircraft/component maintenance, overhaul, replacement, inspection, and life limitrequirements. 14. The onerator must carry out its maintenance, inspections, and record keeping recmirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status ofreplacement/overhaul componentparts must be noted in the aircraft records, including total time in service, description ofwork accomplished, and the signature ofthe authorized person returning the UAS to service. 15. Each UASs operated underthis exemptionmust comply with all manufacturer Safety Bulletins. 16. The authorized person mustmake an entry in the aircraft record ofthe corrective actiontaken against discrepancies discovered between inspections. 17. The PIC must possess at least a privatepilot certificate and at least a current third- class medical certificate. 18. The onerator may not nennit any PIC to operate unless the PIC meets the ooerator's qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with howthe UAS will be operated underthe exemption, including evasive and emergencymaneuvers and maintaining aonrooriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours mustbe logged in a manner consistent with 14 C.F.R.

**~** 61.51(b). Flights for the purposes oftrainingthe operator's PICs are oermitted underthe terms ofthe exemption. However, training operations may only be conducted during dedicated training sessions. During training, oroficiency, and experience-building flights, all persons notessential for fliQ;ht ooerations 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 cmerations may not be conducted during night as defined in 14 C.F.R.

**~** 1.1. All operations must be conducted under visual meteorological conditions (VMC). Ifflight at night is required, a special request will be made at the FAA office closest to proposed area ofoperations. Flights under special visual flight rules (SVFR) are not authorized.20. The UA may not ooerate within 5 nautical miles ofan airoortreference ooint as denoted on a current FAA-oublished aeronautical chart unless a letter of agreement with that airoort's management is obtained, andthe ooeration is conducted in accordance with a NOT AM as required bythe ooerator's COA. The letter ofagreement withthe airport management mustbe made available to the Administrator upon request. 21. The UA may not be ooerated 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. Ifthe UA loses communications orloses its GPS signaL it mustreturn to a nre- determined location within the olanned ooerating area and land orbe recovered in accordance withthe operating documents. 23. The PIC must abort the flight in the event ofunoredicted obstacles or emergencies in accordance with the operating documents. 24. The PIC is orohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enoughoowerto fly at normal cruising

**soeec~** 

## t? the intended landing point and land the UA with 25% batterypower remammg. 25. The cmerator must obtain an Air Traffic Organization (ATO) issued Certificate ofWaiver or Authorization (COA) oriorto conducting any onerations under the grant ofexemotion. This COAwill also require the oneratorto request a Notice to Airman (NOT AM) not more than 72 hours in advance, but not less than 48 hours oriorto the ooeration. All ooerations shall be conducted in accordance with airsoace requirements inthe ATO issued COA including class ofairspace, altitude level and potential transponder requirements. 26. All aircraft onerated in accordance withthe exemotion mustbe identified by serial number, registered in accordance with 14 C.F.R. oart 47, and have identification (N- Number) markings in accordance with 14 C.F.R. part45, Subpart C. Markings must be as large aspracticable. 27. Before conducting ooerations, the radio frequency soectrum used for oneration and control ofthe UA must comolY 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 mustbe available to the PIC at the Ground Control Station ofthe UAS any time the UAS is ooerating. These documents mustbe made available to the Administrator or any law enforcement official uponrequest. 29. The UA mustremain clear and yield the right ofway to all manned aviation operations and activities at all times. 30. The UAS may not be operatedby the PIC from anymoving device or vehicle. 31. Flight onerations must be conducted at least 500 feet from all nonoarticipating persons (persons other than the PIC, SO, operatortrainees or essentialpersons), vessels, vehicles, and structures unless:

a. Barriers or structures are oresent that sufficiently protect nonnarticinating nersons fi-om the UA and/or debris inthe event ofan accident. The operatormust ensure thatnonparticipating persons remain under suchprotection. Ifa situation arises where nonparticipating persons leave suchprotection and are within 500 feet ofthe UA, flight operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/controller ofsuch vessels, vehicles or structures has granted nermission and the PIC has made a safety assessment ofthe risk of onerating closer to those objects and determined that it does notpresent an undue hazard, and;

c. Onerations nearerto the PIC SO, operatortrainees or essential persons do not present an undue hazardto those persons per§ 91.119(a). 32. All onerations shall be conducted overprivate or controlled-access property with Dermission from the land owner/controller or authorized reDresentative. Permission from land owner/controller orauthorized representative will be obtained for eachflight to be conducted. 33. Anv incident accident or flight operationthat transgresses the lateral or vertical boundaries ofthe ODerational area as defined by the applicable COA must be reDorted to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be renorted to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: WWlN.ntsb.rrov. 

### 2. Reasons Whv an Exemotion from the Reouirements ofSection 61.113(a) and (b) Would Not Adversely Affect Safety. SAS submits that the equivalent level ofsafety establishedby Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs unless that PIC has demonstrated, by meeting minimum l1ight-hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS in a manner consistent withthe exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering SAS'sproposed area ofoperations, and the operating limitations set forth-above; the parallel nature ofprivatepilot aeronautical knowledgerequirements to those ofcommercial pilot requirements (See ExemptionNo. 11062); and the airmanship skilis necessary to safely operate the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS, SASsubmits that the additional manned airmanship experience ofa commercially certificated pilot would not correlate to the airmanship skills necessary for SAS's specificproposed f1ight operations. The FAA has previously granted relieffrom Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presentedherein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112,11136,11138,11150,11153,11156,11158,11159,11160, 11161). SAS will not allow any PIC to operate the DJI Phantom 2 Vision+ orDJI Inspire I UAS unless that PIC has demonstrated, bymeetingminimum flight-hour requirements

or the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS training and currencyrequirements, that the PIC is able to safely operate the DJI Phantom 2 Vision+ orDJI Inspire 1UAS in

a manner consistent with this exemption, including evasive and emergencymaneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Specifically, the PIC musthave accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours oftotal time as a UAS rotorcraft pilot (with a minimum of5 hours ofthose 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 hourrequirements, the PIC must accomplish 3 takeoffs and landings inthe 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 ensure an equivalent level ofsafety during SAS'sproposed operations. The Administratorhas held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows: In Exemotion No. 11062, the FAArequired that oriorto conducting ooerations for the ouroose ofmotion oicture filming (or similar ooerations), the PIC musthave accumulated and logged, in a manner consistent with 14 CFR 61.5l(b), 25 hours oftotal time as a UAS rotorcraft oilot including at least 10 hours logged as a UAS oilot with a multi-rotor UAS. Priorto ooerations under ExemotionNo. 11062, the PIC must also have accumulated and logged a minimum of5 hours as a UAS pilotonerating the same make and model ofUAS to be used for operations under the exemntion. For clarification, the FAA considers these minimumhour requirements to be inclusive rather than additive: i.e. 5 hours make and model time mav be included in the 10 hours ofmulti-rotortime and the 10 hours maybe included in the total25 hours ofUAS rotorcrafttime. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings inthe preceding 90 davs (for currency purnoses). The FAA finds that at a minimum, the flighthour reouirements in Exemntion No. 11062 are appropriate to practice and build nroficiencv in the skills necessary to safely conductthe petitioner's proposed onerations. The FAA also finds that prior documented f1ight experiencethat was obtained in comnliance with applicable regulations would satisfy this requirement. Training, nroficiency, and experience-building f1ights can also be conducted underthe grant ofexemption to accomplish the required f1ight time. During training, nroficiency, and experience-buildingflights the PIC is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15. Accordingly, SAS will ensure safe operationsby not allowing any PIC to operate the 0.11 Phantom 2 Vision+ or DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum f1ight-hour and currency requirements, thatthe PIC is able to safely operate the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS in a manner consistent withthe exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 

### 3. Reasons Whv an Exenmtion from the Requirements ofSection 91.7(a) Would Not Adversely Affect Safety. The equivalent level ofsafety established by Section 91.7(a) will be maintained because prior to every f1ight, SAS will ensure that the DJI Phantom 2 Vision+ orDJI Inspire 1 UAS is in an airworthy condition based uponthe UAS's compliance with its operating documents and as stated in the conditions and limitations herein. Additionally, the FAA has previously grantedrelieffrom Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to thosepresented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, I11 1 2, 1I 1 36, 1 1138, 11150, 1 1153, 11156, 11157, 11158, 11159, 11160, 11161). 

### 4. Reasons Whv an Exemotion from the Requirements ofSection 91.121 Would Not Adversely Affect Safety.

The equivalent level ofsafety established by Section 91.121 will be maintainedbecause the altitude information ofthe DJIPhantom2 Vision+ and DJI Inspire 1 UAs will be provided to the PIC via GPS equipment and a radio communications telemetry data link, which downlinks from the UAto the GCS for active monitoring ofthe flight path and altitude. This altitude information, combined with SAS's operation ofthe DJI Phantom 2 Vision+ and DJI Inspire 1 UAs within visual line ofsight, at orbelow400 feet AGL, will ensure a level ofsafety equivalentto Section 91.121. The altitude information will be generated by GPS equipment installed onboardthe aircraft. Prior to eachflight, a

zero altitude initiation point is automatically established by the UASs at ground level. The FAA has previously granted relieffrom Section 91.121 specific to UAS, in circumstances similar, in all material respects, to thosepresentedherein (e.g. Exemption Nos. 11062,11063,11064,11065,11066,11067,11080,11109,11112,11136,11138, 11150,11153,11156,11157,11158,11159,11160, 11161).



### 5. Reasons Whv an Exemotion from the Requirements ofSection 91.15l(b) Would Not Adversely Affect Safety. A grant ofthis exemption would ensure an equivalent level ofsafety established by 14 C.F.R. Section 91.151(b) as a result of(1) thetechnical specifications ofthe DJI Phantom 2 Vision+ and DJI Inspire 1UASs; (2) the limitations onthe proposed flight operations; and (3) the location ofthe proposed flight operations. Accordingly, SAS will

ensure that it will safely operate the batterypowered DJI Phantom 2 Vision+ and DJI Inspire IUAs during daylight hours in VFR conditions, with enough batterypowerto fly for a total duration of 13.5 minutes to the first point ofintended landing and, assuming normal cruising speed, to fly afterthat for at least4.5 minutes. Here, as inExemptionNo. 11109, the technical specifications ofthe DJI Phantom 2 Vision+ and DJllnspire 1 UASs; the limitations onthe proposed flight operations; and the location ofthe proposed operations, will ensure an equivalent level ofsafety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Phantom 2 Vision+ and DJI Inspire 1 UASsprovide audible and visual warnings tothe PIC at the GCS when the UAs experiences lowbattery voltage, the first warning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery power. At the critically lowbattery level, the DJI Phantom Vision+ and DJI Inspire 1UASs \vill descend and land automatically. Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations ofthe UAS are considered. Reliefhas been granted for manned aircraft to operate at less than the minimumsprescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAAhas previously granted reiieffrom Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. ExemptionNos. 8811, 10808, 10673, 11042, 11062,11063,11064,11065,11066,11067,11080,11109,11110,11136,11138,11150, 11153, 11156,11157,11158,11159,11160, 11161).

6. Reasons Whv An Exemotion From The Reauirements OfSections 9l.405(a). 91.407(a) (1). 91.409(a) (1) & (a) (2), And 91.417(a) & (b) Would Not Adversely Affect Safety. In seekingthis exemption, SAS submits thatthe equivalent level ofsafety with regard to the regulatory maintenance and alteration requirements establishedby Sections 91.405(a), 91.407(a)(1 ), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) will be met because SAS will use trained technicians to perform maintenance, alterations, orpreventive maintenance on the UASs using the methods, techniques, and practicesprescribed in the operating documents (i.e., the SAS Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1Instruction Manual). Furthermore, SAS will document and maintain all maintenance records for the DJI Phantom 2 Vision+ and DJI Inspire 1UASs. Since the DJI Phantom 2 Vision+ and DJI Inspire 1UASs will be inspected as prescribed by the operating documents, SAS will maintain the equivalent level ofsafetyestablished by Sections 91.405(a), 91.409(a)(l), and 91.409(a)(2). A copy oftheDJI Phantom 2 Vision+ and DJI Inspire 1User Manuals are attachedhereto as Exhibit C and D; a copy ofthe DJI Phantom 2 Vision+ and DJI Inspire 1UAS Maintenance LOG will be an android based digital app that will be downloaded on a monthly basis to a hard paper copy. Likewise, the exemption sought will not adversely affect safety because SAS will

use trained technicians to perform maintenance, alterations orpreventive maintenance on the UAS using the methods, techniques, and practicesprescribedbythe operating documents. Furthermore, the exemption sought would maintain an equivalent level ofsafety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance ofthe D.JI Phantom 2 Vision+ and DJI Inspire 1UASs 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 91.405(a), 91.407(a)(1), 91.409(a)(l) & (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 ofSAS'sproposed operating limitations, the operating documents, and the technical aspects ofthe DJI Phantom 2 Vision+ and DJI Inspire 1 UASs. SAS submits that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(l) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted reliefspecific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. ExemptionNos. 11062, 11063, 11064,11065,11066,11067.11080,11109,11110,11112,11136,11138,11150,11153, 11156,11157,11158,11159,11160, 11161).

7. The FAA May Prescribe Any Other Conditions For Safe Operation.In accordance with Section 333 ofthe 

### P AA Modernization and Reform Act of 2012 (FMRA) and 14 C.P.R. § 21.16 entitled Special Conditions, SAS requests that the FAA prescribe special conditions for the intended operation ofthe DJI Phantom 2 Vision+ and DJI Inspire 1UASs, which contain such safety standards that the Administrator finds necessary to establish a level ofsafety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.P.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151 (b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation ofthe UAs for the limitedpurpose of conducting aerial video and photography over certain areas ofthe United States for compensation or hire. PMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users ofthe NAS orthe 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 requirements thatmustbe established for the safe operation ofthe UAS inthe NAS. Likewise, the Administratormayprescribe special conditions pursuantto 14 C.F.R. § 21.16, for operation ofthe DJI Phantom 2 Vision+ and DJI Inspire 1UASs, since the airworthiness regulations of 14 C.P.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features ofthe aircraft. Section 21.16, entitled Special Conditions, states the following: Ifthe FAA finds that the airworthiness regulations ofthis subchapter do not contain adecmate or annronriate safety standards for an aircraft aircraft engine, or orcmeller because ofa novel or unusual design feature ofthe aircraft aircraft engine or oroneller. he orescribes soecial conditions and amendments thereto for the nroduct. The snecial conditions are issuedin accordance with Part 11 ofthis chanter and contain such safety standards for the aircraft aircraft engine or nroneller as the P AA finds necessary to establish a level ofsafety equivalent to that established in the regulations.

See 14 C.P.R.§ 21.16.Theref()re, in accordance with FMRA Section333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for SAS'sintended operation oftheDJI Phantom 2 Vision+ and DJI Inspire 1UASs, which contain such safety standards that the Administrator finds necessary to establish a level ofsafety equivalentto that established by 14 C.F.R. Part 21, Subpmi H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.15l(b), 91.405(a), 91.407(a)(l), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). 

### • A Summarv That Can Be Published In The Federal Register, stating: The Rules From Which SAS Seeks Exemption: S'ASseeks exemotion kom the reauirements o(]4 C.F.R Sections 61.1JJ(a)&(b), 9!. 7(a). 9!. J 21. 91.15J (b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 9J .4!7(a) & (b). 

### A BriefDescription ofthe Nature ofthe Exemption SAS Seeks: This exemvtion

**~will** vermitSASto commerciallv overate an UnmannedAircraft Svstem (UAS) 

### forthe vurvose of conductingaerial video and photography over certain areas o/the UnitedStates.



### • Anv Additional Information, Views, orArguments Available to Support 

### SAS's Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary ofTransportation to determine if certain UAS may operate safely in the NAS. As such, SAS'srequest for exemption may be granted pursuant to the authority ofFMRA 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 \viii create a hazard to users ofthe NAS orthe 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, SAS will operate the DJI Phantom 2 Vision+ and DJl Inspire 1 UASs safely in the NAS, without creating a hazard to users ofthe NAS, or the public, or otherwisepose a threat to national security

### CONCLUSION As set forth herein, SAS seeks an exemptionpursuantto 14 C.F.R. § 11.61 and Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA), which will permit safe operation ofthe DJI Phantom 2 Vision+ and DJI Inspire 1UASs commercially, without an airworthiness certificate, for the limitedpurpose ofconducting aerial video and photography over certain areas ofthe United States. By granting this Petition, the FAA Administrator will be fultllling the Congressional mandate ofthe FAA Modernization and Reform Act of2012, while also advancing the interests ofthe public, by allowing SAS to safely, efficiently, and economically operate the DJI Phantom 2 Vision+ and DJI Inspire 1UASs commercially within the NAS. 

### WHEREFORE, in accordance withthe Federal Aviation Regulations and the FAA Modernization and Reform Act of2012, Section 333, SAS respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.15l(b), 91.405(a), 91.407(a)(l), 91.409(a)(J) & (a)(2), and 91.417(a) & (b), and permit SAS to operate the DJI Phantom 2 Vision+ and DJI Inspire 1UASs commercially for the purpose ofconducting aerial video and photography over certain areas ofthe United States. Dated: May 22,2015 Respectfully submitted, Lawrence Bridges



# Lawr~ri~ Lawrence Bridges Black Forest GunWurks, LLC DBA: SAS Defense DBA: SouthernAir Services 101 Demorest Square Demorest GA 30535 706-778-1440Appendices: A- OJ! Phantom 2 Vision+ Soecifications Data Sheet B

- OJl Insoire 1Soecifications Data Sheet C --OJ! Phantom 2 Vision+ User Manual 0

- OJ1Inspire 1User Manual

APPENDIX-A 

### DJI PHANTOM 2 VISION+ TECHNICAL SPECIFICATIONS SAS onlv utilizes safe and reliable UASs. DJI is an industry leader in small UAS oroduction. OJI UASs are loaded with ground breaking software enablingthe user to set oarameters which will not allow flight into controlled airsoace. Parameters can also be set to limit flight to no higherthan a oredetermined and set altitude as well as limit flight to a oredetermined and set distance. In addition, DJI software movides real-time altitude and location information to the PIC via the linked monitor (smartphone/tablet devices) 1.1 

### DJI Phantom 2 Vision+ I. I . I Aircraft I.1.1.I Suooorted Battery- DJI 5200mAH LiPo Battery 1. I.1.2 Weight (Battery & Prooellers Included)- 2lbs 11.810oz (1242g) 1.1.1.3 Hover Accuracy (Readvto Flv)- Vertical: .8m; Horizontal: 2.5m 1.1.1.4 Max Yaw Angular Velocity- 2000/s I.1.1.5 Max Tilt Angel- 350 I.1.1.6 Max Ascent Soeed- 6m/s I. I. I.7 Max Descent Sneed- 2m/s I.I.1.8 Max Flight Speed- 15m/s (NOT RECOMMENDED) 1.1.2 Gimbal 1.1.2.1 Working Current- Static: 750mA; Dynamic: 900mA 1.1.2.2 Control Accuracy- ±0.030 1.1.2.3 Controllable Range- Pitch: -900

- 00 1.1.2.4 Maximum Angular Speed- Pitch: 900/s 1.1.3 Camera I. 1.3.1 Ooerating Temoerature Range- 320F- 1040F (OOC- 400C) I.1.3.2 Sensor Size- 1/2.3" I. I.3.3 Effective Pixels- 14M I. I.3.4 Resolution- 4384x3288 4. 1.3.5 HD Video Recording- 1080o30 & 720p 4. I.3.6 Recording Field ofView- 1100/850 I. I.4 Transmitter 1.1.4.1 Ooerating Frequency- 5.728GHz- 5.85GHz I. I.4.2 Communication Distance (unobstructed)- FCC Compliance: 800m 1.1.4.3 Receiver Sensitivity (1%PER)

- -93dBm1.1.4.4 Transmitter Power- FCC Compliance: 1OOmW 1.1.4.5 Working Voltage- 120mA@3.7V 1.1 .5 Range Extender 1.1.5.1 Onerating Frequency- 2412-2462MHz 1.1.5.2 CommunicationDistance (unobstructed)- 500-700m 1.1.5.3 Transmitter Power- 20dBm 1.1.5.4 Power Consumption- 2W

APPENDIX-B 

### DJI INSPIRE 1 TECHNICAL SPECIFICATIONS SAS onlv utilizes safe and reliable UASs. DJI is anindustry leader in small UAS nroduction. DJI UASs are loaded with ground breaking software enabling the userto set narameters which will not allow flight into controlled airspace. Parameters can also be set to limit llir.d1t to no higher than a nredetermined and set altitude as well as limit flight to a ])redetermined and set distance. In addition, DJI software nrovides real-time altitude and location information to the PIC viathe linked monitor (smartphone/tablet devices) 2.2 DJI Inspire 1 2.2.1 Aircraft 2.2.1.1 Model- T600 2.2.1.2 Weight (Batterv Included)- 61bs 7.5291oz (2935g) 2.2.1.3 Hovering Accuracv (GPS Mode)- Vertical: 0.5m: Horizontal: 2.5m 2.2.1.4 Max Angular Velocity- Pitch: 300°/s; Yaw: 150°/s 2.2.1.5 MaxTilt Angle- 35° 2.2.1.6 Max Ascent Speed- 5m/s 2.2.1.7 Max Descent Speed -4m/s 2.2.1.8 Max Speed- 22m/s (ATTl mode, no wind- NOT RECOMMENDED) 2.2.1.9 Max Flight Altitude- 4500m 2.2.1.10 Max Wind Resistance- 10m/s 2.2.1.11 Max Flight Time- Approximately 18 minutes 2.2.1.12 Motor Model- DJI 3510 2.2.1.13 Propeller Model- DJI1345 2.2.1.14 OperatingTemperature Range -14°F to 104°F (-10°C to 40°C) 2.2.1.15 Dimensions -17 

### W' x 17 %" x 12" 2.2.2 Gimbal 2.2.2.1 Model- ZEN MUSE 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- X3 2.2.3.2 Model- FC350 2.2.3.3 Total Pixels -12.76M2.2.3 Camera 2.2.3.1 Name -X3 2.2.3.2 Model- FC350 2.2.3.3 Total Pixels -12.76M 2.2.3.4 Effective Pixels -12.4M 2.2.3.5 Image Max Size- 4000x3000 2.2.3.6 ISO Range -100-3200 2.2.3.7 Field ofView- 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: 1920x1080p24/25/30/48/50/60; HD: 1280x720p24/25/30/48/50/60 2.2.3.10 OperatingTemperature 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 (unobstructed)- 2000m 2.2.4.4 Output Power- 9W 2.2.4.5 OperatingTemperature Range- 14°F to 104°F (-10°C to 40°C) 2.2.4.6 Battery- 600mAh LiPo 2S