07/06 /2015 Richard DePaso Manager: Aardvark Video & Media Productions, LLC 17 Winding Rd Henderson, NV 89052 Office: (702) 897

- 4477 Mobile: (702) 501

- 1244 Email: creators@computer.net Alternate: aardvarkvideo@gmail.com

Request for FAA Section 333 Exemption SUMMARY Aardvark Video & Media Productions , LLC seeks exemption from the requirements of 14 C.F.R ; 61.113(a) & (b), 91.7(a), 91.119(c), 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 (UAS) pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Aardvark Video & Media
P roductions , LLC to operate an Unmanned Aircraft System (UAS) for the purposes of aerial photograph y, cinematography, videography, and other flight operations that could be performed safely and more cost effectively with the use of small UAS at low altitude within the U.S. national airspace system as compared to a manned aircraft. Operations will be performed only at the request of and with the authorization and permission of clients or their authorized agents in order to facilitate commerce and raise awaren ess of the beneficial uses of small unmanned air systems. So long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333.INTRODUCTION TO AARDVARK VIDEO & MEDIA PRODUCTIONS, LLC Aardvark Video & Media Productions, LLC is a full service production company with over 28 years experience in the industry

. Aardvark Video & Media Productions , LLC is recognized as an expert in trade show video, corporate video and trainin g video production

. Aardvark Video has been building expertise in aerial video and photography since 2013. The objective of Aardvark Video & Media Productions , LLC aerial video and photography operations is to provide high quality imagi ng for a variety of commercial

uses more specifically targeting:

• Video capture for client’s marketing purposes.

• Video capture for industrial or training videos.

• Video and photo for real estate clientele. BACKGROUN D Unmanned Aircraft Systems owned : DJI Phantom 2 ; DJI Phantom 3 ( From here on both DJI Phantom 2 and DJI Phantom 3 will be referred to as “DJI Phantom series”)

Aardvark Video & Media Productions, LLC seeks an exemption to operate DJI Phantom series systems for compensation or hire within the National Airspace System ( NAS ) . The DJI Phantom series are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. UAS S PECIFICATIONS DJI Phantom 2 Weight (Battery & Propellers Included) 1000g Hover Accuracy (Ready To Fly) Vertical: 0.8m; Horizontal: 2.5mMax Yaw Angular Velocity 200°/s Max Tilt Angle 35° Max Ascent / Descent Speed Ascent: 6m/s; Descent: 2m/s Max Flight Speed 15m/s(Not Recommended) Diagonal Length 350mm Flight Time 25mins Take
- Off Weight ≤ 1300g Operating Temperature

- 10°C ~ 50°C Supported Battery DJI Smart Battery DJI Phantom 3 Weight (Including Battery And Propellers) 1280 g Diagonal Size (Including Propellers) 590 mm Max Ascent Speed 5 m/s Max Descent Speed 3 m/s Hover Accuracy:

• Vertical: +/

- 0.1 m (when Vision Positioning is active) or +/

- 0.5 m

• Horizontal: +/

- 1.5 m Max Speed 16 m/s (ATTI mode, no wind) Max Altitude Above Sea Level 6000 m Operating Temperature 0°C to 40°C GPS Mode GPS/GLONASS
The DJI Phantom series UA s that will be operated by Aardvark Video & Media Productions, LLC will be registered in accordance with 49 U.S.C. 44103, Registration ofAircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identif ication and Registration Marking.

BASIS FOR PETITION Petitioner, Aardvark Video & Media Productions, LLC, 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, hereby petitions to commercially operate the DJI Phantom series UAS in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R § § 61.113(a) & (b), 91.7(a), 91.121, 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, Aardvark Vi deo & Media Productions , LLC operation of DJI Phantom series UAS meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingly, Aardvark Video & Media Productions , LLC 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. Aardvark Video & Med ia Productions , LLC submits that the requested relief is proper sin ce an equivalent level of safety will always be ensured. Aardvark Video & Media Productions, LLC will use experienced personnel or technicians to performmaintenance, alterations, or preven tive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., DJI Phantom series Instruction Manual s ). Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command , is requested by Aardvark Video & Media Productions , LLC 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 flight

- hour and currency requirements,
that the PIC is able to safely operate the DJI Phantom series i n a manner consistent with
this exemption, including evasive and emergency maneuvers and maintaining appropriate
distan ces from people, vessels, vehicles and structures. Aardvark Video & Media Productions , LLC seeks relief from Section 91.7(a),
entitled Civil Aircraft A irworthiness , because the DJI Phantom series UAS do not require an airworthiness certificate in accordanc e with 14 C.F.R. Part 21, Subpart H. As such,
Aardvark Video & Media Productions , LLC submits that he will ensure that the DJI Phantom series UAS are in an airworthy condition, prior to every flight, by determining that the UAS are in complian ce with the o perating documents and that the aircraft are in a condition for safe flight.
Aardvark Video & Media Productions, LLC also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , as the DJI Phantom series UAs will not have a typical barometric altimeter onboard. However, altitude information of the DJI Phantom series will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks fromthe UA to the GCS fo r active monitoring of the flight path. This altitude information, combined with Aardvark Video & Media Productions , LLC operation of the DJI
Phantom Series UAS within visual line of sight, at or below 500 feet above ground level , will ensure a level of safety equivalent to Section 91.121. Additionally, Aardvark Video & Media Productions, LLC seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR
conditions

. Aardvark Video & Media Productions, LLC submi ts that safety will not be affected by operation of the DJI Phantom series UAs during daylight hours in visual meteorological conditio ns (VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration of approximately 13.5 minu tes 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, Aardvark Video & Media Productions, LLC provides the following information in support of its p etition for exemption: A. Name And Address Of The Petitioner. The name and address of the Petitioner and point of contact is:
Aardvark Video & Media Productions, LLC Richard DePaso , Manager 17 Winding Rd Henderson , NV 89052 Office: 702

- 897

- 4477 Cell: 702

- 501

- 1244
B. The Specific Sections Of 14 C.F.R. from which Aardvark Video & Media Productions, LLC Seeks Exemption. 1. Aardvark Video & Media Productions, LLC Seeks Exemption From The Req uirements Of Section 61.113(a) a nd (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 pilot 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 hire, act as PIC of an aircraft in connection with any business or em ployment 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. Aardvark Video & Media Productions, LLC Seeks Exemption from the Requirements of Secti on 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. Aardvark Video & Media Productions, LLC 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 departure airport or an ap propriate altimeter setting available before departure.4. Aardvark Video & Media Productions, LLC 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. Aardvark Video & Media Productions , LLC 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 air craft

- (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 prescribed in part 43 of this chapter 6. Aardvark V ideo & Media Productions, LLC 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 aircraft 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. Aardvark Video & Media Productions, LLC 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 a ircraft unless, 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 f or the issuance of an airworthiness certificate in accordance with part 21 of this chapter. 8. Aardvark Video & Media Productions, LLC 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, a nd appliance of an aircraft. The records must include

— (i) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of completion of the work performed; and (iii) The signature, and certificate numbe r 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

- limite d parts of each airframe, engine, propeller, 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 comp liance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be retained until 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 o f Relief Aardvark Video & Media Productions, LLC Seeks and t he Reaso n Aardvark Video & Media Productions, LLC Seeks The Relief 1. Extent o f Relief Aardvark Video & Media Productions, LLC Seeks and t he Reason Aardvark Video & Media Productions, LLC Seeks Relief f rom Section 6 1.113(a) a nd (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 opera tions for compensation or hire. This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employm ent if: (1) The flight is only incidental to thatbusiness or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. As set forth more fully below, Aardvark Video & Media Productions, LLC submits that an equivalen t level of safety will be maintained because no PIC will be allowed to operate the DJI Phantom 3/DJI Phantom 2 UAS unless that PIC has met certain flight

- hour and currency requirements, demonstrating that the PIC is able to safely operate either the DJI Ph antom series 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, vesse ls, vehicles
and structures. Further, Aardv ark Video & Media Productions, LLC submits that all flights of the
DJI Phantom series UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to Aardvark Video & Media Productions, LLC business; and (2) will not carry passe ngers or property for compensation or hire. 2. Extent of Relief Aardvark Video & Media Productions, LLC Seeks and the Reason Aardvark Video & Media Productions, LLC Seeks Relief from Section 91.7(a). Relief from Section 91.7(a) entitled Civil aircraft airwor thiness , is requested to the extent required to allow to Aardvark Video & Media Productions, LLC to determine
that the DJI Phantom series UAS are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating docu ments

. Aardvark Video & Media Productions, LLC seeks the requested relief because the
DJI Phantom series UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, to Aardvark Video & Media Productions, LLCwill ensure that the DJI Phantom series UAS are in airworthy condition based upon its complian ce with the operating documents prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated in th e conditions and limitations below. 3. Extent of Relief Aardvark Video & Media Productions, LLC Seeks and the Reason Aardvark Video & Media Productions, LLC Seeks Relief from Section 91.121

. Relief from Section 91.121, entitled Altimeter settings , may be req uired to allow flight operations of the DJI Phantom series 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 pilot in command ( PIC ) at the grou nd 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), Aardvark Video & Media Productions, LLC seeks the requested relief because t he DJI
Phantom series UA’s altimeter may be set on the ground to zero feet above ground level ( 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 conditions and limitations stated below. As more fully set forth herein, an equivalent level of safety wi ll
be maintained since the DJI Phantom series UAs are equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the pilot with altit ude information of the UA on the heads

- up display of the ground control station ( GCS )

.4. Extent o f Relief Aardvark Video & Media Productions, LLC Seeks and t he Reason Aardvark Video & Media Productions, LLC Seeks Relief f rom Section 91.151(b).
Relief from S ection 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 series UAs during daylight hours in visual meteorological conditions (VMC), under visual fligh t rules (VFR), 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. Aardvark Video & Media Productions, LLC seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered DJI Phantom series UAs will severely constrain the practicality of any aerial video or still photo flight operations that Aardva rk Video & Media Productions, LLC proposes to conduct pursuant to this Petition.
Significantly, as set forth below, the technical specifications of the DJI Phantom series UAS, the DJI Phantom series operating documents, and Aardvark Video & Media
Productio ns, LLC proposed operating limitations, ensure that Aardvark Video & Media Productions, LLC will safely operate the battery powered DJI Phantom series UAs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), wit h 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.

5. Extent o f Aardvark Video & Media Productions, LLC Seeks and t he Reason Aardvark Video & Media Productions, LLC Seeks Relief f rom 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, Aardvark Video & Media
Productions , LLC requests relief from these Sections because the DJI Phantom series UAS do not require airworthiness certificates. As set forth more fully below, the DJI
Phantom series UAS meet the cond itions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, Aardvark Video & Media Productions, LLC will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, te chniques, and practices prescribed in the UAS operating
documents. Furthermore, Aardvark Video & Media Productions, LLC will document and maintain all maintenance records for the DJI Phantom series UAS.
D.The Reasons Why Granting Aardvark Video & Media Productions, LLC Request Would Be In The Public Interest; That Is, How It Would Benefit The Public As A Whole. Granting the present Petition will further the public interest by allowing Aardvark Video & Media Productions, LLC to safely, efficiently, and e conomically perform aerial
video and photography over certain areas of the United States.
Additionally, use of the DJI Phantom series UAS will decrease congestion of the National Airspace System ( NAS ) , reduce pollution, and provide significant benefits to the economy. Notably, the benefits of Aardvark Video & Media Productions, LLC proposed operation of the DJI Phantom series UAS will be realized without implicating any privacy issues.

1. The Public will Benefit from Decreased Congestion of the National Airspa ce System (NAS). The Phantom series UAs are battery powered and serve as a safe, efficient, andeconomical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowi ng the use of the DJI Phantom UAS would reduce the amount of manned aircraft in the National Airspace System ( 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 t he number of manned aircraft operating in the National Airspace System ( NAS ) , congestion around airports caused by arriving and departing aircraft will be reduced. The DJI Phantom series UAs do not require an airport to takeoff or land. Likewise, a reducti on 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 Benef it From The Safety And Efficiency Of The DJI Phantom series UAS. Conducting aerial acquisitions with the DJI Phantom series UAS, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution gener ated during traditional aerial video and still photography flight operations. By using battery power and electric motors, the DJI Phantom series UAS produce 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 aviation fuel. The DJI Phantom series UAs, while reducing the carbon footprint of

ae rial acquisitions, also eliminates noise pollution, as the UAs are propelled by batterypowered electric motors, rather than an internal combustion engine.
By using the DJI Phantom series UAS to perform aerial acquisitions, the substantial risk to life and property 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 series UAs 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.
3.Performing Aerial Video and Photography Operations With The DJI Phantom series UAS Will Benefit The Economy. In addition to being safe and efficient, the DJI Phantom series UAS are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom series UAS will allow United States based companies, like Aardvark Video & Media Productions, LLC , to remain compet itive and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new a nd alternative technology in order to remain competitive. Operating the battery powered DJI Phantom series UAS is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft.
By operating the DJI Phantom UAS, companies such as Aardvark Video & Media Productions, LLC , can remain competitive and profitable, and therefore, provide greaterjob stability to employee s 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 series UAS, provides a stable workforce that increases consumer spending; improve s 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.

3. There are no privacy issues.
Similar to the manned aerial acquisition flight operation s that h ave been conducted for decades, Aardvark Video & Media Productions, LLC proposed operation of the DJI Phantom series UAS will not implicate any privacy issues. Specifically, the
DJI Phantom series UAS will be operated onl y in compliance with operating d ocuments which requires property owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, including the min imum altitude requirements of C.F.R. § 91.119.

E. The Reasons Why Granti ng t he Exemption Would Not Adversely Affect Safety, o r How The Exemption Would Provid e a Level Of Safety At Least Equal To That Provided By The Rule From Which Aardvark Video & Media Productions, LLC Seeks Exemption. 1. Reasons Why The DJI Phantom Series 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, Aardvark Video & Media Productions, LLC operation of the DJI Phantom series UAS meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, SubpartH.
Section 333 provides authority for a UAS to operate without airworthine ss 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.

-- N otwithstanding any other requirement of this subtitle, and not later 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 sys tem before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act. (b) Assessment of Unmanned Aircraft Systems.

-- In making the determination under subsection (a), the Secretary shall determ ine, at a minimum

— (1) which types of unmanned aircraft 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 sys tem 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 aircra ft systems identified 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 requirement s for the safe operation of such aircraft systems in the national airspace system. In seeking this exemption, Aardvark Video & Media Productions, LLC submits that the and DJI Phantom series UAS can operate safely in the National Airspace System (NAS) pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI Phantom series UAS; (b) the pilot certification requirement; and (c) the specific operating limitations.

a. The Specificatios of the DJI Phantom series UAS Demonstrate it ’s Safe Characteristics The DJI Phantom series UAS do not create a hazard to users of the NationalAirspace System (NAS) or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability.

i. The DJI Phantom series UAS Autonomous Flight And Navigation Modes Enable The UAS To Remain Within a Defined Operational Area. The DJI Phantom series UAS may be operated in manual and fully autonomous flight modes.

ii. The DJI Phantom series UAS a re Designed For Automatic Return To Home Point o r Hover In The Event Of Loss Of The Control Link Or Navigation. When the Control Link is lost, the DJI Phantom series UAs will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom series
UAS do not reacquire control link data from the Ground Control Station (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 shutdow n. A complete description of the Failsafe Functions of the DJI Phantom are included in the operational manuals.

iii. The DJI Phantom Series GCS and it’s Operation
A complete description of the operation and specifications of the DJI Phantom
series Ground Cont rol Station (GCS) and flight control software is provided within the
the DJI Phantom Series User Manual s.

b. Flight Operations Of DJI Phantom series UAS Are Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer.Aardvark Video & Media Productions, LLC will only utilize certificated pilots who possess a current and valid airman medical certificate to act as a pilot in command (PIC)
of the DJI Phantom series UAS

. Additionally, a safety observer will assist all pilots during flig ht time.

c. Flights Of DJI Phantom Series UAS Will Be Conducted Pursuant To Specific Operating Limitations. In seeking this exemption, Aardvark Video & Media Productions, LLC proposes to commercially operate DJI Phantom series UAS for the special purpose of conducting aerial video and photography over certain areas of United States, pursuant to the following specific operating limitations:
1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UAS weighing less than 55 pounds maximum gross weight: DJI Phantom series Unmanned Aircraft Systems. Proposed operat ions 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 indi cated airspeed exceeding 20 knots.
4. The UA must be operated at an altitude of no more than 500 feet above

5. 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. 6. The UAs must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on t he PIC’s FAA

- issued airman medical certificate.

7. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted.8. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as th e PIC always maintains VLOS capability. The SO and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the SO can perform the functions prescribed in the operating documents.

9. 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.
10. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. I f 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 followe d. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents t o the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. If the operator determines that any update or revision would affect the basis upon which th e FAA granted the exemption, then the operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operating documents. 11. Prior to each fli ght the PIC must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been perfo rmed 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.
12. Any UAS that has undergone mainte nance 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

.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 wi th the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature of the authoriz ed 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 discov ered between inspections.
17. The PIC must possess at least a private pilot certificate and at least a current third

- class medical certificate.
18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and dem onstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PI C qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator’s PICs are permitted under the terms of the exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in a ccordance with 14 C.F.R. § 91.119.
19. UAS operations 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). If flight at night is required, a special request will be ma de at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized.
20. The UA may not operate within 5 nautical miles of an airport reference point as denoted on a current FAA

- published aeronautic al chart unless a letter of agreement with 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 UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.
22. If the UA loses communications or loses its GPS signal, it mu st 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 operat ing documents.
24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 25% battery power remaining.
25. T he operator must 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 requir ements.
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 mus t be as 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 official upo n request.
29. The UA must remain clear and yield the right of way to all manned aviation operations and activities at all times.
30. The UAS may not be operated by the PIC from any moving device or vehicle.31. Flight operations must be conducted at least 500 feet 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 c ease 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 the risk of operating closer to th ose 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 pri vate 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 Transp ortation 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. Aardvark Video & Media Productions, LLC submits t hat the equivalent level of safety established by Section 61.113(a) and (b) will be maintained because no Pilot in Command (PIC) will be allowed to operate the DJI Phantom series 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 series UAS in a manner consistent with theexemption, including evasive and emergency maneuvers and maintaini ng appropriate distances from people, vessels, vehicles and structures. Considering Aardvark Video & Media Productions, LLC proposed area of operations, and the operating limitations set forth

- above; the parallel nature of private pilot aeronautical knowle dge requirements to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI Phantom series UAS, Aardvark Video & Media Productions, LLC submits that the additional manned airmanship ex perience of a commercially certificated pilot would not correlate to the airmanship skills necessary for Aardvark Video & Media Productions,
LLC 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 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, 11158, 11159, 11160, 11161).

Aardva rk Video & Media Productions, LLC will not allow any Pilot in Command (PIC) to operate the DJI Phantom series UAS unless that Pilot in Command (PIC) has demonstrated, by meeting minimum flight

- hour requirements or the DJI Phantom series UAS training and cu rrency requirements, that the PIC is able to safely operate the DJI
Phantom series UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels,
vehicles and structures

. Specifically, the Pilot in Command (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 rotorcraftpilot (with a minimum of 5 hours of those hours as a UAS pilot operating the same mak e and model of UAS to be used for operations under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes).
As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure

an equivalent level of safety during Aardvark Video & Media Productions, LLC proposed operations. The Administrator has held that prior documented flight e xperience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows:
In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar opera tions), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi

- rotor UAS. Prior to operations under Exemption No . 11062, the PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be in clusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi

- rotor time and the 10 hours may be included in the 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 p etitioner’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience

- building flights can also be condu cted under the grant of exemption to accomplish the required flight time. During training, proficiency, and experience

- building flights the PIC is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119.Exemption No. 111 38 at page 15. Accordingly, Aardvark Video & Media Productions, LLC will ensure safe operations by not allowing any PIC to operate the DJI Phantom series 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 series UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maint aining 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 mainta ined because prior to every flight, Aardvark Video & Media Productions, LLC will ensure that
the DJI Phantom series UAS is in an airworthy condition based upon the UAS’s compliance with its operating documents and as stated in the conditions and limitation s 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, 1 1110, 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 equivalent level of safety established by Section 91.121 will be m aintained because the altitude information of the DJI Phantom series UAs will be provided to the Pilot in Command (PIC) via GPS equipment and a radio communications telemetry data link, which downlinks from the UA to the Ground Control Station (GCS) for ac tive monitoring of the flight path and altitude. This altitude information, combined with Aardvark Video & Media Productions, LLC operation of the DJI Phantom series UAswithin visual line of sight, at or below 500 feet Above Ground Level (AGL) , will ensur e 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 UAS at ground level.

T he FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 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 series UAS; (2) the limitations on the proposed flight operations; and (3) th e location of the proposed flight operations. Accordingly, Aardvark Video & Media Productions, LLC will ensure that it will safely operate the battery powered DJI Phantom
series UAs during daylight hours in Visual Flight Rules (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 afte r that for at least 4.5 minutes.
Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom
series UAS; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Phantom Series (UAS) provide audible and visual warnings to the Pilot in Command (PIC) at the GroundControl Station (GCS) when the UAs experiences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and again at approxi mately 10% remaining battery power. At the critically low battery level, the DJI Phantom series UAS will 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 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 Exemption 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, 11063, 11064, 11065, 11066, 11067, 11 080, 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. I n seeking this exemption, Aardvark Video & Media Productions, LLC 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 Aardvark Video & Media Productions,
LLC will use trained technicians to perform maintenance, alterations, or preventive
maintenance on the UAS using the methods, techniques, and practices prescr ibed in the operating docu ments. Furthermore, Aardvark Video & Media Productions, LLC will document and maintain all maintenance records for the DJI Phantom series UAS

.Since the DJI Phantom Series UAS will be inspected as prescribed by the operating documents, Aardvark Video & Media Productions, LLC will maintain the equivalent level of safety established by Sections 91.405(a), 91.4 09(a)(1), and 91.409(a)(2).
Likewise, the exemption sought will not adversely affect safety because Aardvark Video & Media Productions, LLC will us e trained technicians to perform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescr ibed by the operating documents.
Furthermore, the exemption sought would maintain an equivalent level of safe ty established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the
DJI Phantom series UAS will be performed by trained technicians. Maintenance will be documented and maintained utiliz ing the monthly maintenance log.
Significantly, previous exemptions granted by 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 cons idered.

In consideration of Aardvark Video & Media Productions , LLC proposed operating limitations, the operating documents, and the technical aspects of the DJI Phantom series UAS , Aardvark Video & Media Productions , LLC submits that safety will not be a dversely 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 thosepres ented 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).
7. The FAA May Prescribe Any Other Conditions for Safe Operation

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Aardvark Video &
Media Productions , LLC requests that the FAA prescribe special conditions for the intended operation o f the DJI Phantom series 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 §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.15 1(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
compensa tion or hire. 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
wi thout airworthiness certification in accordance with any requirements that must be established for the safe operation of the UAS in the NAS.
Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of the DJ I Phantom series 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 SpecialConditions, states the foll owing:
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 engi ne or propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the F AA finds necessary to establish a level of safety equivalent 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 Leading Edge’s intended operation of the DJI Phantom series UAS, which contain such safety standards that the Administrator finds necessary t o 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), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).
F. A Summary That Can Be P ublished In The Federal Register, stating: The Rules From Which Aardvark Video & Media Productions, LLC Seeks Exemption: Aardvark Video & Media Productions , LLC seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.1 51(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 o f The Exemption Aardvark Video & Media Productions, LLC Seeks: This exemption will permit Aardvark Video & Media Productions , LLC to commerciall y operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States. G. Any Additional Information, Views, Or Arguments Available To Support Aardvark Video & Media Productions , LLC 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 ifcertain UAS may operate safely in the NAS. As such, Aardvark Video & Media Productions , LLC request for exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above.
FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without
airworthiness certification. As discussed in detail above, Aardvark Video & Media Productions , LLC will operate the DJI Phantom ser ies UAS safely in the National Airspace System (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, Aardvark Video & Media Productions , LLC seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI Phantom series UAS commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography over certain areas of the United States. By granting this 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 p ublic, by allowing Aardvark Video & Media Productions , LLC to safely, efficiently, and economically operate the DJI Phantom series UAS commercially within
the National Airspace System (NAS)

.

Wherefore , in accordance with the Federal Aviation Regulations and the FAAModernization and Reform Act of 2012, Section 333, Aardvark Video & Media Productions , LLC respectfully requests that the Administrator grant this Petition for an exemption from the requirem ents 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 Aardvark Video & Media Productions , LLC to operate the DJI Phantom series UAS commercially for the purpos e of conducting aerial video and photography over
certain areas of the United States.
Dated: July 6, 2015

Respectfully submitted: Richard DePaso, Manager Aardvark Video & Media Productions, LLC 17 Winding Rd Henderson, NV 89052