June 8 , 2015

Exemption No. 11770

Regulatory Docket No. FAA

– 20 15

– 0895

Mr. Mark Ratcliff

Crosstimbers Video Partners LLC

2801 Surveyors Lane

Flower Mound, TX 75022

Dear Mr. Ratcliff :

This letter is to inform you that we have granted your request for exemption. It transmits our

decision, explains its basis, and gives you the conditions and limitations of the exemption,

including the date it ends.

By letter dated April 1, 20 15 , you petitioned the Federal Aviation Administration (FAA) on

behalf of Crosstimbers Video Partners LLC ( hereinafter petitioner or operator ) for an

exemption . The petitioner requested to operate an unmanned ai rcraft system (UAS) to

conduct real estate p hotography, videography, and aerial surveying for other commercial

industries

.

See Appendix A for the petition submitted to the FAA des cribing the proposed operations and

the regulations that the petitioner seeks an exemption

.

The FAA has determined that good cause exists for not publishing a summary of the petition

in the Federal Register because the requested exemption would not set a precedent, and any

delay in acting on this petition would be detrimental to the petitioner

.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Phantom 2

.

In accordance with the statutory criteria provided in Section 333 of P ublic Law 112

− 95 in

reference to 49 U

. S

. C

. § 44704, and in consideration of the size, weight, speed, and limited

operating area associated with the aircraft and its operation, the Secretary of Transportation2

has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA

finds that relief from 14 CFR part 21

, C ertification procedures for products and parts,

Subpart H

— Airworthiness Certificates , and any associated noise certification and testing

requirements of part 36, is not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection 1

. The FAA has issued grants of

exemption in circumstances similar in all material respects to those presented in your petition.

In Grants of Exemption No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352),

11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No.

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned

aircraft (UA) with the specifications described by the petitioner and carrying no p assengers or

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled

by this exemption is in the public interest.

Having reviewe d your reasons for requesting an exemption, I find that

—

• They are similar in all material respects to relief previously requested in Grant of

Exemption Nos. 11062, 11109, 11112, and 11213 ;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and

11213 also apply to the situation you present; and

• A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest.

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701,

delegated to me by the Administrator, Crosstimbers Video Partners LLC is granted an

exemption from 14 CFR §§ 61.23(a) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a)

, 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and

91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform

aerial data collection

. This exemption is subject to the conditions and limitations listed

below.

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA.

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF

analysis, etc.), chemical measurement (part iculate measurement, etc.), or any other gathering of data by

instruments aboard the UA.3

Conditions and Limitations

In this grant of exemption, Crosstimbers Video Partners LLC is hereafter referred to as

the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2

when weighing less than 55 pounds including payload. P roposed operations of any

other aircraft will require a new petition or a petition to amend this exemption

.

2. Operations for the purpose of closed

- set motion picture and television filming are

not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The

exemption holder may use either groundspeed or calibrated airspeed to determine

compliance with the 87 knot speed restriction. In no case will the UA be operated at

airspeeds greater than the maximum UA operating airsp eed recommended by the

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times.

This requires the PIC to be able to use human vision unaided by any device other than

corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate or

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used

to satisfy the VLOS requirement as long as the PIC always maint ains VLOS

capability. The VO and PIC must be able to communicate verbally at all times ;

e lectronic messaging or texting is not permitted during flight operations. The PIC

must be designated before the flight and cannot transfer his or her designation fo r the

duration of the flight. The PIC must ensure that the VO can perform the duties

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its

operations in accordance with the conditions and limitations stated in thi s grant of

exemption, are hereinafter referred to as the operating documents. The operating

documents must be accessible during UAS operations and made available to the

Administrator upon request. If a discrepancy exists between the conditions and

limita tions in this exemption and the procedures outlined in the operating documents,4

the conditions and limitations herein take precedence and must be followed.

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

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

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

documents to the Administrator or any law enforcement official upon request. The

operator must also present up dated and revised documents if it petitions for extension

or amendment to this grant of exemption. If the operator determines that any update

or revision would affect the basis upon which the FAA granted this exemption, then

the operator must petition for an amendment to its grant of exemption. The FA A’s

UAS Integration Office (AFS− 80) may be contacted if questions arise regarding

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS op eration

or flight characteristics, e.g.

, replacement of a flight critical component, must undergo

a functional test flight prior to conducting further operations under this exemption.

Functional test flights may only be conducted by a PIC with a VO and mu st remain at

least 500 feet from other people. The functional test flight must be conducted in such

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it i s

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the

UAS is in a condition for safe flight. The pre

- flight inspection must account for all

potential discrepancies, e.g.

, inoperable comp onents, items, or equipment. If the

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is

prohibited from operating until the necessary maintenance has been performed and the

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul,

replacement, inspection, and life limit requirements for the aircraft and

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport,

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a

current FAA airman medical certificate or a valid U.S. driver’s license issued by a

state, the District of Col u mbia, Puerto Rico, a territory, a possession, or the Federal

government. The PIC must also meet the flight revi ew requirements specified in

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.5

14. The operator may not permit any PIC to operate unless the PIC demonstrates the

ability to safely operate the UAS in a manner consistent with how the UAS will be

operated under this exemption, including evasive and emergency maneuvers and

main taining appropriate distances from persons, vessels, vehicles and structures. PIC

qualification flight hours and currency must be logged in a manner consistent with

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs

(trai ni ng, proficiency, and experience

- building) and determining the PIC’s ability to

safely operate the UAS in a manner consistent with how the UAS will be operated

under this exemption are permitted under the terms of this exemption. However,

training operat ions may only be conducted during dedicated training sessions. During

traini ng, 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 accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All

operations must be conducted under visual meteorological conditions (VMC). Flights

under special visual f light rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not

denoted with an ARP, the center of the airport sym bo l as denoted on the current

FAA

- published aeronautical chart, unless a letter of agreement with that airport’s

management is obtained or otherwise permitted by a COA issued to the exemption

holder. The letter of agreement with the airport management must be made available

to the Administrator or any law enforcement official upon request.

17. 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.

18. If t he UAS loses communications or loses its GPS sign al, the UA must return to a

pre

- determined location within the pr ivate or controlled

- access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibit ed from beginning a flight unless (considering wind and forecast

weather conditions) there is enough available power for the UA to conduct the

intended operation and to operate after that for at least five minutes or with the reserve

power recommended by t he manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All

operations shall be cond ucted in accordance with an ATO

- issued COA. The

exemption holder may apply for a new or amended COA if it intends to con duct

operations that cannot be conducted under the terms of the attached COA

.6

22. All aircraft operated in accordance with this exemption must be identified by serial

number, registered in accordance with 14 CFR part 47, and have identification

(N− Number) mar kings in accordance with 14 CFR part 45, Subpart C. Markings must

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the

PIC at the Ground Control Station of the UAS any time the aircraft is operating.

These documents must be made available to the Administrator or any law enforcement

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and

activities at all times.

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

26. All Flight operations must be conducted at least 500 feet from all nonpartici pating

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 r emain under such protection. If a situation arises

where nonparticipating persons leave such protection and are within 500 feet of

the UA, flight operations must cease immediately in a manner ensuring the safety

of nonparticipating persons ; and

b. The owner/ controller of any vessels, vehicles or structures has granted permission

for operating closer to those objects and the PIC has made a safety assessment of

the risk of operating closer to those objects and determined that it does not

present an undue hazard

.

The PIC, VO, operator trainees or essential persons are not considered

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or control led

- access property with

permission from the property owner/controller or aut horized representative.

Permission from property owner/controller or authorized representative will be

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical

boundaries of the opera tional area as defined by the applicable COA must be reported

to the FA A's UAS Integration Office (AFS− 80) within 24 hours. Accidents must be

reported to the National Transportation Safety Board (NTSB) per instructions

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

.7

If this exemption permits operations for the purpose of closed

- set motion picture and

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM)

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this

exemption must submit a written Plan of Activities to the local Flight Standa rds

District Office (FSDO) with jurisdiction over the a rea of proposed filming. The 3

- day

notification may be waived with the concurrence of the FSDO. The plan of activities

must include at least the following:

a. Dates and times for all flights;

b. Name and p hone number of the operator for the UAS aerial filming conducted

under this grant of exemption;

c. Name and phone number of th e person responsible for the on

- scene operation of

the UAS;

d. Make, model, and serial or N− Number of UAS to be used;

e. Name and certifica te number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners

and/or local officials to conduct the filming production event; the list of those

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city,

town, county, and/or state over which filming will be conducted and the altitudes

essentia l to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons

consenting to be involved and necessary for the filming production, as specified in the

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS

operations must comply with all applicable parts of 14 CFR including, but not limited to,

parts 45, 47, 61, and 91.8

This exemption terminates on June 30, 2017 , unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

EnclosuresOriginal 0 4 / 0 1 /2015 Page 1 

### Crosstimbers Video Partners LLC

April 1 , 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Petition under Section 333 of the FAA Modernization & Reform

Act, and Title 14 Part 11 of the Code of Federal Regulations (CFR)

14 CFR 61.113,

14 CFR 91. 7, 91.119, 91.121, 91.151

14 CFR 91 Subpart E ( 91.40 5, 91.407, 91.409, 91.417)

Dear Sir or Madam,

Pursuant to Section 333 of the FAA Modernization & Reform Act and 14 C.F.R. Part 11,

Crosstimbers Video Partners LLC (Crosstimbers) hereby applies for the grant of

exemption from certain Federal Aviation Regulations for Phantom II (Phantom)

Unmanned Aircraft manufactured by DJI Co.,Ltd. of China

.

The requested exemption would support an application for a commercial Certifica te of

Authorization (COA) to use the Phantom to support real estate p hotography

,

v ideography , and aerial surveying for other commercial industries

.

The Phantom Unmanned Aircraft System (UAS) consists of a lightweight ( 4 lb) battery

operated q uadcopter unmanned aircraft, onboard cameras, and assoc iated

communications equipment.

The Phantom Unmanned Aircraft (UA) has previously demonstrated to have

successfully met the safety and operational requirements resulting in previous grants of

s ection 333 exemption requests by other commercial UAS operators.

The Phantom UA carries an onboard camera system that allows it to perform a erial

photography, videography , and surveying

.

By appro ving the exemption, the Crosstimbers’ UAS operations will create benefits to

both the economy and the environment which are ultimately in the public interest.

The aircraft will be operated wi th both a Pilot in Command and a Visual Observer in

accordance with the following additional restrictions:Original 0 4 / 0 1 /2015 Page 2

- All operations will occur a t no more than 400' AGL

- The aircraft will be operated with the permission of the property owner

- When necessary, applicable permits will be acquired from local authorities

- The aircraft will not be operated over urban or populated areas

- The aircraft will not be operated at air shows or over an open

- air assembly of people

- The aircraft will not be operated over he avily trafficked roads

- Operations will be limited to day, visual meteorological conditions

- Aircraft will remain within Visual Line of Sight at no greater than 1/2 NM of the PIC at

all time

- While the aircraft is airborne, the VO will be positioned wit hin voice distance to the PIC

- When necessary and applicable, Crosstimbers will file a NOTAM providing

radial/DME, radius, and a date/time group for each operation

F or certain complex operations, Crosstimbers may assign one or two sensor/software

operato rs to assist the operations.

We submit that the combination of ;

- Phantom UAV’s lig ht weight and historically demonstrated safe operation and

receiving approval s of multiple section 333 petitions

- Fully qualified flight crew

- Restricted operation s under the guidelines established within the grant

, t he FAA can have confidence that Crosstimbers’ UAS the operation s will have

an equivalent or greater level of safety of manned aircraft performing the same mission.

We are prepared to modify or amend any part of this request to satisfy the need for an

equivalent level of safety. Additional documents supporting this petition will be

submitted following this request.

We look forward to working with your office.

Please contact us at any time if you require additional information or clarification.

Respectfully,

Mark Ratcliff

Crosstimbers Video Partners LLC

2801 Surveyors Lane

Flower Mound, Texas 75022

Tel : 972

- 567

- 8989

Email : markratcliff@verizon.netOriginal 0 4 / 0 1 /2015 Page 3 

## TABLE OF CONTENTS

NAME, ADDRESS CONTACT INFORMATION OF PETITIONER .......................Page 4

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH CROSSTIMBERS

SEEKS EXEMPTION.

.............................................................................. ....................Page 4

THE EXTENT OF RELIEF CROSSTIMBERS SEEKS AND THE REASON S

CROSSTIMBERS SEEKS THE RELIEF

.......................................... ................ ....... Pages 4 to 6

THE REASONS WHY GRANTING CROSSTIMBERS ’S REQUEST WOULD

BE IN THE PUBLIC INTEREST ..................................................

........................... . Page 7

THE REASONS WHY GRANTING CROSSTIMBERS THE EXEMPTION WOULD

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

.............................. ... Page 8

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER..........

. .... Page 9

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS

AVAILABLE TO SUPPORT CROSSTIMBERS ’S R EQUEST...

.............. .......... ...... Page 10

ACR ONYMS...............................................................

......... .... Page s 11 & 12Original 0 4 / 0 1 /2015 Page 4

NAME, ADDRESS AND CONTACT INFORMATION OF PETITIONER

Mark Ratcliff

Crosstimbers Video Partners LLC

2801 Surveyors Lane

Flower Mound, Texas 75022

Tel : 972

- 567

- 8989

Email : markratcliff@verizon.net

THE SPECIFIC SECTIONS OF 1 4 CFR TO BE RELIEVED FROM

14 CFR 61.113,

14 CFR 91.7, 91.119, 91.121, 91.151

14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417)

THE EXTENT OF RELIEF CROSSTIMBERS SEEKS AND THE REASONS

CROSSTIMBERS SEEKS THE RELIEF

14 CFR 61.113 Private pilot privileges and limitations:

Part 61.113 provides that no person that holds a private pilot certificate may act as pilot

in command of an aircraft for compensation or hire. Subparagraph (b) allows a private

pilot to act as pilot in command of an aircraft in connection with any business or

employment if;

(1) flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire

.

Since the aircraft cannot carry passengers or property, we request to be relieved from

this regulation if our pilots at minimum,

(1) hold at least a current private pilot certificate and,

(2) hold a current third class medical certificate.

By meeting conditions (1) and (2), we believe that equivalent level of safety can be

achieved by complying with 61.113 Subparagraph (b) even though the intent of this

application is to conduct a business.

14 CFR 91.7 Civil Aircraft Airworthiness.

14CFR 9 1.7 (a) states

,

“ No person may operate a civil aircraft unless it is in an airworthy condition

. ”

T his rule prohibits the operation of an aircraft without an airworthiness certificate.

Since there is no such existing certificate that is applicable for the Phantom UAS to

properly comply with the FARs, we request that Crosstimbers to be relieved from this

regulation.

To provide equivalent level of safety, we will ensure that the Phantom UAS is inOriginal 0 4 / 0 1 /2015 Page 5

airworthy condition prior to every flight by following safety procedures described

in our operating documents.

14 CFR 91.119 Minimum safe altitudes: Genera l

This regulation provides that over sparsely populated areas the aircraft cannot be

operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the

aircraft will be operating at a maximum of 400 feet AGL, we cannot comply with this

requirement.

To provide an equivalent level of safety we will only fly over private property with the

permission of the land owner. The land owner will be briefed of the expected route of

flight and the associated risks to persons and property on the ground. We maintain that

due to the small size of the Phantom , the hazard to persons, vessels, vehicles, and

structures is not comparable to manned aircraft and should be considered in granting

the exemption.

14 CFR 9 1. 121 Altimeter Settings

Th is regulation provides that aircraft shall maintain cruising altitudes by reference to an

altimeter setting available within 100 nautical miles of the aircraft.

The Phantom aircraft will fly below 400 feet AGL and will not need to maintain

hemispherical cruising altitudes in order to de

- conflict with other aircraft.

To provide an equivalent level of safety, the PIC will check and confirm the Phantom’s

GPS altitude read out before each flight.

14 CFR 91.1 51 Fuel requirem ents for flight in VFR conditions.

The regulation provides that no person may begin a flight in an airplane under day

VFR conditions unless there is enough fuel to fly to the first point of intended landing

and to fly after that for at least 30 minutes. We believe the intention of this rule is to

provide a reserve of energy as a safety buffer for go

- arounds and other delays to

landing.

The Phantom UAS is battery operated and the maximum duration of flight with full

payload, from a single batte ry charge is a pproximately 25 minutes.

We believe that equivalent level of safety can be achieved by limiting our flight time to

20 minutes with reserve energy 20 % ( 5 minutes) on the battery.Original 0 4 / 0 1 /2015 Page 6

14 CFR 91 Subpart E ( 91. 405, 91.407, 91.409, 91.417 )

Maintenance, Preventive Maintenance, and Alterations

The regulation provides that the operator is primarily responsible for maintaining the

aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs

91.407 and 91.409 require that the aircraft be "approved for return to service by a

person authorized under 43.7" after maintenance and inspection. It is our intention that

the PIC, VO or authorized personnel to perform maintenance and inspection of the

aircraft and "be authorized to approve the air craft for return to service."

Crosstimbers requests that exemptions to the regulations under conditions below;

(1) Crosstimbers will follow Phantom’s manufacturer maintenance instructions

, techniques and procedures

(2) Crosstimbers will designate, t rain, and document the personnel who will be

authorized to perform Inspection, Maintenance and Alterations by means of above

stated maintenance instructions

. Such designated personnel may include PIC, VO or other equivalent trained persons

(3) To en sure equivalent level of safety, PIC will inspect the UA before each flight

looking for any structural or mechanical malfunctions

Due to the small size, light weight and simplicity of the Phantom UAS, we believe that

the equivalent safety will be achiev ed by permitting any of the PIC , VO or equivalent

trained personnel, to perform maintenance

, inspection and alterations of the aircraft

and " be authorized to approve the aircraft for return to service. "Original 0 4 / 0 1 /2015 Page 7

THE REASONS WHY GRANTING CROSSTIMBERS ’S REQUEST WOULD BE IN THE

PUBLIC INTEREST

We believe that granting our exemption request from,

14 CFR Part 21.191

14 CFR Part 45.23, 45.29

14 CFR 61.113 , 61.133

14 CFR 91.9, 91.119

, 91.121

, 91.151

14 CFR 91 Subpart E ( 91 .405, 91.407, 91.409, 91.417) , is in the public’s interest and

will benefit the public as a whole for the following reasons.

1

- Phantom is battery operated and free from the harmful emissions associated

with the manned aircraft that are currently used for aerial photo graphy and

videography.

As recently proven by several grants of section 333 petitions, UASs offer

equivalent level of safety while reducing environmental impacts, which is in the

public interest.

2

- Crosstimbers’ UAS operation s will contribute to a po sitive aggregate e conomic

i mpact resulting in creation of jobs both direct and indirectly. Economic

Research estimates that the UAS market will grow from $6 billion to $ 94 billion

over the next decade resulting in a new workforce development

. Because C rosstimbers ’ operations will create new jobs such as pilots, flight

operation staff, and administrative supporting staff, it will directly cause positive

economic impact , hence granting Crosstimbers ’ petition will benefit the public

as a whole.

3

- Congress has already proclaimed that it is in the public’s interest to integrate

Commercially flown UAS (s) into the national airspace system, hence the passing

of the FAA Modernization and Reform Act of 2012.

Granting Crosstimbers ’ petition furthers the public ’s interest as a demonstrated

progression of integrating Unmanned Aircraft Systems into National Air Space

, thus it will benefit public as a whole

.Original 0 4 / 0 1 /2015 Page 8

THE REASONS WHY GRANTING CROSSTIMBERS THE EXEMPTION WOULD

NOT ADVERSELY AFFECT SAFETY

Crosstimbers believes that the grant of exemption from,

14 CFR 61.113,

14 CFR 91.7, 91.119, 91.121, 91.151

14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417),

will not adversely affect safety by a combination of the reasons listed below.

(a) We have st ated in the above section “ THE EXTENT OF RELIEF

CROSSTIMBERS SEEKS AND THE REASONS CROSSTIMBERS SEEKS THE

RELIEF ” by describing how we intend to mitigate risk and accomplish FAA

equivalent and acceptable level of safety for each 14 CFR part.

(b) As a result of Phantom unmanned aircraft’s size, weight, speed, operational

capability, proximity to airports and populated areas, operation within visual line

of sight combined with the implementation Crosstimbers’ of safety procedures

, we believe that grantin g Crosstimbers’ exemption request will not adversely

affect safety.

(c) DJI Phantom II has demonstrated to satisfy necessary safety risk mitigation by

FAA thus resulting in multiple grants of section 333 petitions.

Because of t he combination of Phantom’s proven success and the conditions

and limitations of our operations, we believe granting Crosstimbers request will

not adversely safety.

.Original 0 4 / 0 1 /2015 Page 9

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER

Department of Transportation

Federal Aviation Administration

Petitioner: Crosstimbers Video Partners LLC

Petition of exemption from section s of ;

14 CFR 61.113,

14 CFR 91.7, 91.119, 91.121, 91.151

14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417)

Description of relief sought;

Crosstimbers se eks an exemption for commercial operati on of the Phantom u nmanned

aircraft manufactured by DJI Co, Ltd. of China

. The Phantom unmanned aircraft system has an onboard camera system capable of

acquiring hig h resolution data.

Proposed operations will offer real estate aerial photography, videography and aerial

surveying services for other commercial industries.Original 0 4 / 0 1 /2015 Page 10

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO

SUPPORT CROSSTIMBERS ’S REQUEST



## Phantom II Unmanned Aircraft System

General Features

 Ready to Fly, Multifunctional Quad

- rotor System

 Customized H3

- 2D and H3

- 3D Gimbal Support

 Precision Flight and Stable Hovering

 25min Flight Time & Smart Battery

 Auto Return

- to

- Home & Landing

 Advanced Power Management

 Intelligent Orientation Control (IOC)

 Easy Battery Replacement

 Self

- tightening Propeller

 Video Downlink Support

 CAN

- Bus Expansion Module

 Control Link radio operating frequency 2.4 GHz ISM

 Operating Distance 0.65 miles



### Aircraft Performance

Empty Weight 2.5 lbs

Max Take

- off Weight 4 lbs

Max Flight Speed 30 Knots

Hover Accuracy (Ready to Fly) Vertical: 0.8m; Horizontal: 2.5m

Max Yaw Angular Velocity 200°/s

Max Tilt Angle 35°

Max Ascent / Descent Speed Ascent: 6m/s; Descent: 2m/s

Diagonal Length 350mm

Flight Time 25 min ute s



### N o Privacy Issues

Crosstimbers ’ proposed operations will create no privacy issues because the Phantom

UAS will be operating in rural areas within the boundaries of the propert ies with the

land owner’s permission.

Crosstimbers will also obtain any permits or authorizations from local authorities when

necessary.Original 0 4 / 0 1 /2015 Page 11 ACRONYMS

AGL Above Ground Level

ALoS Acceptable Level of Safety

AMOC Alternative Method of Compliance

ASI Aviation Safety Inspector

ATC Air Traffic Control

ATCAA Air Traffic Control Assigned Airspace

ATS Air Traffic Service

AVS Aviation Safety

CFR Code of Federal Regulations

COA Certificate of Waiver or Authorization

CRM Crew Resource Management

CS Control Station

CRS Certified Repair Station

DCP Divert/Contingency Point

DHS Department of Homeland Security

DME Distance Measuring Equipment

DOD Department of Defense

DSA Detect, Sense, and Avoid System

FAA Federal Aviation Administration

FCC Federal Communications Commission

FA Rs F ederal Aviation Regulations

FIR Flight Information Region

FL Flight Level

FSIMS Flight Standards Information Management

System

FTP Flight Termination Point

FTS Flight Termination System

Crosstimbers Crosstimbers Video Partners LLC

G Hz Gigahertz

GCS G round Control Station

MHz Megahertz

MTOW M aximum Takeoff Weight

NAS National Airspace System

NM Nautical Mile

N O TA M N otice To A irman

OPA Optionally Piloted Aircraft

PIC Pilot in Command

Phantom Phantom Unmanned Aircraft System

Phantom Phantom Unmanned Aircraft

R&D Research and Development

RF Radio FrequencyOriginal 0 4 / 0 1 /2015 Page 12

RM Risk Management

RNAV Area Navigation

RTB Return to Base

RVSM Reduced Vertical Separation Minimum

TAS Traffic Advisory Systems

TC Type Certificate

UA Unmanned Aircraft

UAS Unmanned Aircraft System (s)

UAV Unmanned Aerial Vehicle

VFR Visual Flight Rules

VMC Visual Meteorological Conditions

VO Visual Observer