UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Marcus Mariner

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL

OPERATION OF DJI F450 QUADCOPTER AND DJI F550 UNMANNED

AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Submitted on May 12 , 2015

Marcus Mariner

9715 W. Broward Blvd #192

Plantation, FL 33324

954-854-2898

 TABLE OF CONTENTS

 

Page

GLOSSARY OF ABBREVIATIONS....................................................................................

3

SUMMARY..........................................................................................................................

..4

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

BACKGROUND..................................................................................................................

..4

BASIS FOR 

PETITION.........................................................................................................5

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

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH Marcus Mariner
SEEKS EXEMPTION...............................................................................................8

THE EXTENT OF RELIEF Marcus Mariner SEEKS AND THE REASON

Marcus Mariner SEEKS THE RELIEF......................................................11

THE REASONS WHY GRANTING Marcus Mariner REQUEST

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

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

ADVERSELY AFFECT SAFETY..........................................................................19

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER......34

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS

AVAILABLE TO SUPPORT Marcus Mariner’s REQUEST......................34

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

35

APPENDICES.........................................................................................36

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate Of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss Of Link

NAS National Airspace System

NOTAM Notice To Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft
UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line Of Site

VMC Visual Meteorological Conditions

VTOL Vertical Take-Off and Landing

 SUMMARY

Marcus Mariner seeks exemption from the requirements of 14 C.F.R §§

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)

(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section

333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will

permit to operate an Unmanned Aircraft System (UAS) for the commercial purpose

of conducting aerial video and photography of construction sites, real estate and 

landscape

over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Marcus Mariner provides his clients with expertise and knowledge in advanced

cinematography solutions and graphic design to increase efficiency, productivity and 

effectiveness.

Marcus Mariner has over 4 years of experience in cinematography. He has over 5

years recreational and hobby experience in all aspects of aerial

video and photography. The objective of Marcus Mariner's aerial video and 

cinematography division is to provide high quality imaging for a variety of commercial,

public, and residential uses, specifically targeting:

· Construction sites before, after and during.

· Appraisals

· Real-estate marketing
· Aerial acquisitions used for inspections of public and private structures.

BACKGROUND

Marcus Mariner seeks an exemption to operate DJI F450 and DJI F550 systems 

for compensation or hire within the NAS. The DJI F450 and DJI F550 are vertical take 

off

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

Utilizing a 5.8 Ghz Remote Control system. The F450 has a maximum

gross weight of approximately 4 pounds 0 ounces, while having a width of 17.7

inches and a height of 9 inches, and a maximum speed of approximately 32 knots.

The F550 has a maximum gross weight of 10 pounds 0 ounces, a length of

20 inches, width of 21.6 inches, height of 14 inches, and a maximum speed of

Approximately 30 knots. The DJI F450 is equipped with 4 main rotors, and the DJI F550

with 8 main rotors; utilizing Lithium Polymer batteries to power the electric motors.

The DJI F450 and DJI F550 UAS's that will be operated by Marcus Mariner

will be registered in accordance with 49 U.S.C. 44103, Registration of

Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance

with 14 C.F.R. Part 45, Identification and Registration Marking.

BASIS FOR PETITION

Petitioner, Marcus Mariner , 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 the Administrator to commercially operate the DJI F450 and DJI F550

UAS's in the National Airspace System (NAS), and for an

exemption from the Unmanned Aircraft Systems: DJI F450 and DJI F550 UAS's 

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, Marcus Mariner operation of the DJI F450

and DJI F550 UAS's 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, Marcus Mariner 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.

Marcus Mariner submits that the requested relief is proper since an

equivalent level of safety will be ensured. Marcus Mariner will use experienced

personnel or technicians to perform maintenance, alterations, or preventive 

maintenance

on the UAS's using the methods, techniques, and practices prescribed in the operating

documents (i.e., Monthly Maintenance Log, and DJI F450 and DJI F550

Instruction Manual). Furthermore, Marcus Mariner will document and maintain

all maintenance records for the DJI F450 and DJI F550 UAS's.
 

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

pilot 

privileges and limitations: Pilot in command, is requested by Marcus Mariner 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 current requirements, that the PIC is able to safely operate the

DJI F450 and DJI F550 UAS's in a manner consistent with this exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures.

 Marcus Mariner seeks relief from Section 91.7(a), entitled Civil aircraft

airworthiness, because the DJI F450 and DJI F550 UAS's do not require

an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such,

Marcus Mariner submits that he will ensure that the DJI F450 and DJI F550 UAS's 

are in an airworthy condition, prior to every flight, by determining that the

UAS's are in compliance with the operating documents (i.e., Monthly Maintenance Log,

and DJI F450 and DJI F550 Instruction Manual), and that the aircraft are

in a condition for safe flight.

 Marcus Mariner also seeks an exemption from the requirements of Section 

91.121,
entitled Altimeter Settings, as the CDJI F450 and DJI F550 UAS's

will not have a typical barometric altimeter onboard. However, altitude information of the

DJI F450 and DJI F550 UAS's will be provided to the PIC via Global

Positioning System (GPS) equipment and radio communications telemetry data link,

which downlinks from the UAS to the GCS for active monitoring of the flight path. This

altitude information, combined with Marcus Mariner operation of the DJI F450 and DJI 

F550

UAS's within visual line of sight, at or below 400

feet AGL, will ensure a level of safety equivalent to Section 91.121.

 Additionally, Marcus Mariner seeks an exemption from the requirements

of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. Marcus 

Mariner 

submits that safety will not be affected by operation of the DJI F450 and DJI F550

UAS's during daylight hours in visual meteorological conditions

(VMC)under visual flight rules (VFR), with enough battery power to fly for a total 

duration of

approximately 10 minutes for the intended photo shoot and, assuming normal

cruising speed, to fly after that for at least 2.5 minutes for recovery and landing.

 In accordance with 14 C.F.R. § 11.81, Marcus Mariner provides the following

information in support of its petition for exemption:

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

Marcus Mariner

9715 W. Broward Blvd #192

Plantation, FL 33324

954-854-2898

Email: Exhaleaerialfilms@gmail.com

B. The Specific Sections Of 14 C.F.R. From Which Marcus Mariner seeks

Exemption

1. Marcus Mariner Seeks Exemption From The Requirements Of

Section 61.113(a) And (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command,

subsections (a) and (b) prescribe the following, in relevant part:

(a) No person who holds a private 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 employment if—

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

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

2.Marcus Mariner Seeks Exemption From The Requirements Of

Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the

following:
(a) No person may operate a civil aircraft unless it is in an airworthy condition.

3. Marcus Mariner 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 appropriate altimeter setting available before

departure.

4. Marcus Mariner 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. Marcus Mariner Seeks Exemption From The Requirement Of
Section 91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following:

Each owner or operator of an aircraft—

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall

between required inspections, except as provided in paragraph (c) of this

section, have discrepancies repaired as prescribed in part 43 of this chapter[.]

6. Marcus Mariner 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. Marcus Mariner Seeks Exemption From The Requirements Of

Sections 91.409(a)(1) And 91.409(a)(2).

Section 91.409, entitled Inspections, subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an

aircraft 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 for the issuance of an airworthiness certificate in accordance

with part 21 of this chapter.

8. Marcus Mariner Seeks Exemption From The Requirements Of

Sections 91.417(a) And 91.417(b).

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the

following:

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

registered owner or operator shall keep the following records for the periods

specified in paragraph (b) of this section:

 (1) Records of the maintenance, preventive maintenance, and alteration and

records of the 100-hour, annual, progressive, and other required or approved
inspections, as appropriate, for each aircraft (including the airframe) and

each engine, propeller, rotor, and appliance of an aircraft. The records must

include--

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

the work performed; and

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

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

aircraft for return to service.

(2) Records containing the following information:

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

each rotor.

(ii) The current status of life-limited parts of each airframe, engine,

propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which

are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the

last inspection required by the inspection program under which the

aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety

directives including, for each, the method of compliance, the AD or

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 Of Relief Marcus Mariner Seeks And The Reason Marcus Mariner

Seeks The Relief.

1. Extent Of Relief Marcus Mariner Seeks And The Reason Marcus Mariner

Seeks Relief From Section 61.113(a) And (b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and

limitations: Pilot in command, is requested to the extent necessary to allow a PIC 

holding a

private pilot or higher level certificate, as well as a current and valid airman medical

certificate, and who has met certain flight-hour and currency requirements, to conduct 

the

proposed UAS flight operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and

(b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in

connection with any business or employment if: (1) The flight is only incidental to that

business or employment; and (2) The aircraft does not carry passengers or property for

compensation or hire.

As set forth more fully below, Marcus Mariner submits that an equivalent

level of safety will be maintained because no PIC will be allowed to operate the DJI 

F450 and DJI F550 UAS's unless that PIC has met certain flight-hour and current 

requirements, demonstrating that the PIC is able to safely operate either theDJI F450 

and DJI F550 UAS's in a manner consistent with the operations specifications as 
described in this exemption, including evasive and emergency maneuvers, as well as 

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

Further, Marcus Mariner submits that all flights of the DJI F450 and DJI F550

UAS's, conducted by the PIC pursuant to the grant of this Petition: (1)

will be incidental to Marcus Mariner business; and (2) will not carry passengers or

property for compensation or hire.

2.Extent Of Relief Marcus Mariner Seeks And The Reason Marcus Mariner Seeks 

Relief From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the

extent required to allow Marcus Mariner to determine that the DJI F450 and DJI F550

UAS's are in airworthy condition prior to every flight by ensuring

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

Maintenance

Log and DJI F450 and DJI F550 manuals.

Marcus Mariner seeks the requested relief because the DJI F450 and DJI F550 

UAS's do not require an airworthiness certificate in accordance with 14

C.F.R. Part 21, Subpart H. Therefore, Marcus Mariner will ensure that the DJI F450 and 

DJI F550

UAS's are in airworthy condition based upon its compliance with the operating 

documents (i.e., Monthly Maintenance Log, and DJI F450 and DJI F550 Instruction 

Manual) prior to every flight, and further, determine that the aircraft are in condition for 
safe flight, as stated in the conditions and limitations below.

3. Extent Of Relief Marcus Mariner Seeks And The Reason Marcus Mariner

Seeks Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow

flight operations of theDJI F450 and DJI F550 AP UAS's, which utilize a

barometric pressure sensor, GPS equipment, and a radio communications telemetry 

data

link to downlink altitude information from the UA to the PIC at the ground control station

(GCS). Since the FAA requires that any altitude information concerning UAS operations 

be

reported to air traffic control (ATC) in feet above ground level (AGL), Marcus Mariner

seeks the requested relief because the DJI F450 and DJI F550 UAS’s altimeter may be 

set on the ground to zero feet AGL, rather than the local barometric pressure or field 

altitude, before each flight.

Considering the limited altitude of the proposed operations, relief from 14 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 will

be maintained since the DJI F450 and DJI F550 UAS's 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 PIC with

altitude information of the UA on the heads-up display of the GCS.
4. Extent Of Relief Marcus Mariner Seeks And The Reason Marcus Mariner

Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR

conditions, is requested to the extent required to allow flights of the battery powered DJI 

F450 and DJI F550 UAS's during daylight hours in visual meteorological conditions 

(VMC), under visual flight rules (VFR), for a total duration of 10 minutes to the first point 

of intended landing and, assuming normal cruising speed, to fly after that for at least 2.5 

minutes. Marcus Mariner seeks the requested relief because without an exemption from 

Section 91.151(b), the flight time duration of the battery powered DJI F450 and DJI 

F550 UAS's will severely constrain the practicality of any aerial video or still photo flight 

operations that Marcus Mariner proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the DJI F450 and 

DJI F550

UAS's, the DJI F450 and DJI F550 operating documents and Marcus Mariner proposed 

operating limitations, ensure that Marcus Mariner will safely operate the battery 

powered DJI F450 and DJI F550 UAS's during daylight hours in visual meteorological 

conditions (VMC), under visual flight

rules (VFR), with enough battery power to fly for a total duration of 10 minutes to the 

first

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

least

2.5 minutes.

5. Extent Of Relief Marcus Mariner Seeks And The Reason Marcus Mariner
Seeks Relief From Sections 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), And 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & 

(b)

only apply to aircraft with an airworthiness certificate, Marcus Mariner requests

relief from these Sections because the DJI F450 and DJI F550 UAS's do

not require airworthiness certificates. As set forth more fully below, the DJI F450 and DJI 

F550

UAS's meet the conditions of FMRA Section 333 for operation

without an airworthiness certificate. Accordingly, Marcus Mariner will use trained 

technicians

to perform maintenance, alterations, or preventive maintenance on the UAS's

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

documents

(i.e., the Aerial Operations Manual, Monthly Maintenance Log, and DJI F450 and DJI 

F550 

Instruction Manual). Furthermore, Marcus Mariner will document

and maintain all maintenance records for the DJI F450 and DJI F550 UAS's.

D. The Reasons Why Granting Marcus Mariner Request Would Be In The

Interest; That Is, How It Would Benefit The Public As A Whole.

Granting the present Petition will further the public interest by allowing Marcus 

Mariner

to safely, efficiently, and economically perform aerial video and
photography of construction sites, real estate, and landscape over certain areas of the

United States. Additionally, use of the DJI F450 and DJI F550 UAS's will

decrease congestion of the NAS, reduce pollution, and provide significant benefits to 

the

the economy. Notably, the benefits of Marcus Mariner proposed operation of the

DJI F450 and DJI F550 UAS's will be realized without implicating any privacy issues.

1.The Public Will Benefit From Decreased Congestion Of The NAS.

 The DJI F450 and DJI F550 UAS's are battery powered and serve

as a safe, efficient, and economical 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 allowing the use of the DJI F450 and DJI F550

UAS's would reduce the amount of manned aircraft in the NAS, reduce noise and air

pollution, as well as increase the safety of life and property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS,

congestion around airports caused by arriving and departing aircraft will be reduced. 

The

DJI F450 and DJI F550 UAS's do not require an airport to takeoff or

land. Likewise, a reduction of manned aircraft conducting aerial video and photography

missions would result in fewer aircraft that must be handled by air traffic control during

the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The DJI F450 and DJI 
F550

UAS's.

Conducting aerial acquisitions with the DJI F450 and DJI F550

UAS's instead of manned aircraft, will greatly benefit the public by drastically reducing

the levels of air and noise pollution generated during traditional aerial video and still

photography flight operations. By using battery power and electric motors, the DJI F450 

and DJI F550

UAS's 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 F450 and DJI F550 UAS's, while 

reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as 

the UA's are propelled by battery powered electric motors, rather than an internal 

combustion engine.

 By using the DJI F450 and DJI F550 UAS's 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 F450 and DJI F550 UAS's (weighing approximately 7 

pounds 0 ounces and 4 pounds 0 ounces respectively, at their maximum gross weights 

with respectively (and with no fuel on board) has less physical potential for collateral 

damage to life and property on the ground, and in the air, compared to the manned 
aircraft that typically conduct similar operations (weighing approximately 6,000 pounds, 

and a fuel capacity of 180 gallons.

 3. Performing Aerial Video and Photography Operations With The DJI F450 and 

DJI F550

UAS's Will Benefit The Economy.

 In addition to being safe and efficient, the DJI F450 and DJI F550 UAS's are also 

an economical alternative to using manned aircraft to conduct similar aerial operations. 

As such, operation of the DJI F450 and DJI F550 UAS's will allow United States based 

companies, like Marcus Mariner to remain competitive and contribute to growth of the 

U.S. economy. Specifically, with the rising cost of aviation

fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out 

leaded aviation fuels, U.S. owned and operated companies must adopt new and 

alternative technology in order to remain competitive. Operating the battery powered 

DJI F450 and DJI F550 UAS's 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 F450 and DJI F550 UAS's, companies such as Marcus Mariner

can remain competitive and profitable and therefore, provide greater job stability to 

employees and contractors, which will ultimately contribute to growth of the U.S. 

economy. Improved financial performance of U.S. companies, through commercial use 

of the DJI F450 and DJI F550 UAS's, provides a stable

workforce that increases consumer spending, improves local, state, and federal tax

revenues and allows companies to invest in research and development in order to 

remain
competitive both in the United States and abroad.

 4.There Are No Privacy Issues.

 Similar to the manned aerial acquisition flight operations that have been 

conducted for

decades, Marcus Mariner's proposed operation of the DJI F450 and DJI F550 UAS's will 

not implicate any privacy issues. Specifically, the DJI F450 and DJI F550 UAS's will be 

operated only in compliance with operating documents documents ( i . e . Aerial 

Operations Manual, Monthly Maintenance Log, and the DJI F450 and DJI F550 

Instruction Manual's) which requires property owner involvement as

well as local law enforcement notification, and in accordance with the Federal Aviation

Regulations, including the minimum altitude requirements of 14 C.F. R. § 91.119.

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

Or How The Exemption Would Provide A Level Of Safety At Least Equal To That

Provided By The Rule From Which Marcus Mariner Seeks Exemption.

 1. Reasons Why The DJI F450 and DJI F550 UAS's 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, Marcus Mariner operation of the DJI F450 

and DJI F550 UAS's meet the conditions of FMRA Section 333, and will not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21,

Subpart H.

 Section 333 provides authority for a UAS to operate without airworthiness

certification and sets forth requirements for considering whether a UAS will create a
hazard to users 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.--Not withstanding 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 system before completion of the plan

and rule making 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 determine, 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 system or the public or pose a

threat to national security; and

 (2) whether a certificate of waiver, certificate of authorization, or

airworthiness certification under section 44704 of title 49, United States

Code, is required for the operation of unmanned aircraft systems

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 requirements for the safe

operation of such aircraft systems in the national airspace system.

In seeking this exemption, Marcus Mariner submits that the DJI F450 and DJI 

F550

UAS's can operate safely in the NAS pursuant to FMRA Section 333,

as demonstrated by: (a) the characteristics of the DJI F450 and DJI F550

UAS's; (b) the pilot certification requirement; and (c) the specific operating limitations.

 a. The Specifications of The DJI F450 and DJI F550 UAS's

Demonstrate Its Safe Characteristics.
The DJI F450 and DJI F550 UAS's do not create a hazard to users of the

NAS or the public, or otherwise pose a threat to national security considering its size, 

weight,

speed, and operational capability.

 i. Technical Specifications of The DJI F450 and DJI F550 UAS's.

 The technical specifications of the CDJI F450 and DJI F550 UAS's

are set forth by the DJI F450 and DJI F550 Specifications and Data Sheet,

attached here to as Exhibit A and B.

 ii. The DJI F450 and DJI F550 UAS's Autonomous

Flight And Navigation Modes Enable The UAS's To Remain Within A

Defined Operational Area.

 The DJI F450 and DJI F550 may be operated in manual flight mode only. A 

complete description of the flight and navigational modes of the DJI F450 and DJI F550

UAS's is

provided at pages 16-22 of the DJI Naza V2 User Manuals, attached hereto as Exhibit 

C.

 iii. The DJI F450 and DJI F550 UAS's Are Designed For

Automatic Return To Home Point Or Hover In The Event Of Loss Of

The Control Link Or Navigation.

 When the Control Link is lost, the DJI F450 and DJI F550 will remain stationary in 

flight, for 3 seconds or more. If, after 3 seconds, the DJI F450 and DJI F550 due not 

reacquire control link data from the GCS, the UAS will assume that the Control Link is 

lost and the UAS will return to the home position (i.e., failsafe mode) via GPS, and will 
descend to the takeoff position and shutdown.

 

 A complete description of the Failsafe Functions of the Naza V2 on both DJI 

F450 and DJI F550 UAS's are set forth at page 16 User Manuals, attached hereto as 

Exhibit C.

 iv. The DJI F450 and DJI F550 GCS And Its Operation.

 A complete description of the operation and specifications of the DJI F450 and 

DJI F550

GCS and flight control software is provided at pages 7-8 on the Naza V2 User Manual. 

DJI F450 and DJI F550 User Manuals are attached

hereto as Exhibits C.

 b. Flight Operations of DJI F450 and DJI F550 UAS's

Are Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety 

Observer.

 Marcus Mariner 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 F450 and 

DJI F550

UAS's. Additionally, a safety observer will assist all pilots during

flight time.

 c. Flights of DJI F450 and DJI F550 UAS's Will Be Conducted Pursuant To 

Specific Operating Limitations.

In seeking this exemption, Marcus Mariner proposes to commercially

operate DJI F450 and DJI F550 UAS's 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's weighing less

than 55 pounds maximum gross weight: DJI F450 and DJI F550 Unmanned Aircraft 

Systems. Proposed operations of any other aircraft will

require a new petition or a petition to amend this grant.

2. UAS operations under this exemption will be limited to conducting operations

for the purpose of aerial video and photography.

3. The UA may not be flown at an indicated airspeed exceeding 20 knots.

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

ground

level (AGL), as indicated by the procedures specified in the operating

documents unless a special request is made and approved by ATC. All altitudes

reported to ATC must be in feet AGL.

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

times. This requires the PIC to be able to use human vision unaided by any

device other than corrective lenses, as specified on the PIC’s FAA-issued airman

medical certificate.

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not

permitted.

7. All operations must utilize a safety observer (SO). The SO may be used to 

satisfy

the VLOS requirement as long as the PIC always maintains VLOS capability.

The SO and PIC must be able to 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.

8. The SO must not perform any other duties beyond assisting the PIC with 

seeing

and avoiding other air traffic and other ground based obstacles/obstructions and

is not permitted to operate the camera or other instruments.

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

during

UAS operations and made available to the Administrator upon request. If a
discrepancy exists between the conditions and limitations contained in the grant

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

conditions and limitations contained in the grant of exemption take precedence

and must be followed. Otherwise, the operator must follow the procedures as

outlined in its operating documents. The operator may update or revise its

operating documents. It is the operator’s responsibility to track such revisions

and present updated and revised documents to the Administrator upon request.

The operator must also present updated and revised documents if it petitions for

extension or amendment to the grant of exemption. If the operator determines

that any update or revision would affect the basis upon which the FAA granted

the exemption, then the operator must petition for amendment to its grant of

exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if

questions arise regarding updates or revisions to the operating documents.

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a

condition for safe flight. If the inspection reveals a condition that affects the

safe operation of the UAS, the aircraft is prohibited from operating until the

necessary maintenance has been performed and the UAS is found to be in a

condition for safe flight. The Ground Control Station must be included in the

preflight inspection. All maintenance and alterations must be properly

documented in the aircraft records.

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

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

component, must undergo a functional test flight. The PIC who conducts the

functional test flight must make an entry in the aircraft records.

12. The pre-flight inspection must account for all potential discrepancies, e.g.

inoperable components, items, or equipment, not already covered in the

relevant sections of the operating documents.

13. The operator must follow the UAS manufacturer’s aircraft/component,

maintenance, overhaul, replacement, inspection, and life limit requirements.

14. The operator must carry out its maintenance, inspections, and record keeping

requirements, in accordance with the operating documents. maintenance,

inspection, alterations, and status of 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 authorized person returning the

UAS to service.

15. Each UAS's operated under this exemption must comply with all 

manufacturer

Safety Bulletins.

16. The authorized person must make an entry in the aircraft record of the

corrective action taken against discrepancies discovered between inspections.
17. The PIC must possess at least a private 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 demonstrates the ability to safely operate

the UAS in a manner consistent with how the UAS will be operated under the

exemption, including evasive and emergency maneuvers and maintaining

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

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 PIC's 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 accordance 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 made 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 aeronautical 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 must return to a 

predetermined

location within the planned operating area and land or be recovered

in accordance with the operating documents.

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

emergencies in accordance with the operating documents.

24. The 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 UAS with 25% battery power

remaining.
25. The 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 requirements.

26. All aircraft operated in accordance with the exemption must be identified by

serial number, registered in accordance with 14 C.F.R. part 47, and have

identification (N-Number) markings in accordance with 14 C.F.R. part 45,

Subpart C. Markings must be as large as practicable.

27. Before conducting operations, the radio frequency spectrum used for 

operation

and control of the UAS 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 upon request.

29. The UAS 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 UAS and/or debris in the event of an accident. The operator must 

ensure that nonparticipating persons remain under such protection. If a situation arises 

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

flight operations must cease

immediately and/or;

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

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

permission and the PIC has made a safety assessment of the risk of

operating closer to those objects and determined that it does not present
an undue hazard, and;

 c. Operations nearer to the PIC, SO, operator trainees or essential 

persons

do not present an undue hazard to those persons per § 91.119(a).

32. All operations shall be conducted over private or controlled-access property

with permission from the land owner/controller or authorized representative.

Permission from land owner/controller or authorized representative will be

obtained for each flight to be conducted.

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

vertical boundaries of the operational area as defined by the applicable COA

must be reported to the FAA's UAS Integration Office (AFS-80) within 24

hours. Accidents must be reported to the National Transportation Safety Board

(NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

2. Reasons Why An Exemption From The Requirements Of Section 

61.113(a)

And (b) Would Not Adversely Affect Safety.

 Marcus Mariner submits that the equivalent level of safety established by

Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate

the DJI F450 and DJI F550 UAS's unless that PIC has demonstrated, by

meeting minimum flight-hour and currency requirements, that the PIC is able to safely

operate the DJI F450 and DJI F550 UAS in a manner consistent with the

exemption, including evasive and emergency maneuvers and maintaining appropriate

distances from people, vessels, vehicles and structures.

 Considering Marcus Mariner's proposed area of operations, and the

operating limitations set forth-above; the parallel nature of private pilot aeronautical

knowledge requirements to those of commercial pilot requirements (See Exemption No. 

11062); and

the airmanship skills necessary to safely operate the DJI F450 and DJI F550
UAS, Marcus Mariner submits that the additional manned airmanship experience

of a commercially certificated pilot would not correlate to the airmanship skills necessary

for Marcus Mariner's specific proposed flight operations.

 The FAA has previously granted relief from Section 61.113(a) and (b) specific to

UAS, in circumstances similar, in all 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).

 Marcus Mariner will not allow any PIC to operate the DJI F450 and DJI F550

UAS unless that PIC has demonstrated, by meeting minimum

flight-hour requirements of theDJI F450 and DJI F550 UAS training and

currency requirements, that the PIC is able to safely operate the DJI F450 and DJI F550

UAS in a manner consistent with this exemption, including evasive

and emergency maneuvers and maintaining appropriate distances from people, 

vessels,

vehicles and structures.

 Specifically, the PIC must have accumulated and logged, in a manner consistent

with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a

minimum of 5 hours of those hours as a UAS pilot operating the same make and model 

of

UAS to be used for operations under the exemption). In addition to the hour 
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 Marcus Mariner's proposed operations. The

Administrator has held that prior documented flight experience that was obtained in

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

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

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

accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of

total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS

pilot with a multi-rotor UAS. Prior to operations under Exemption No. 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 inclusive 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 petitioner’s proposed operations. The FAA

also finds that prior documented flight experience that was obtained in compliance

with applicable regulations would satisfy this requirement. Training, proficiency,

and experience-building flights can also be conducted under the 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. 11138 at page 15.

 Accordingly, Marcus Mariner will ensure safe operations by not allowing

any PIC to operate the DJI F450 and DJI F550 UAS unless that PIC has
demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC

is able to safely operate the DJI F450 and DJI F550 UAS in a manner

consistent with the exemption, including evasive and emergency maneuvers and

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

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

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.7(a) will be maintained

because prior to every flight, Marcus Mariner will ensure that the DJI F450 and DJI F550

UAS is in an airworthy condition based upon the UAS’s

compliance with its operating documents and as stated in the conditions and limitations

herein. Additionally, the FAA has previously granted relief from Section 91.7(a) specific

to UAS, in circumstances similar, in all material respects, to those presented herein (e.g.

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

11112,

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

4. Reasons Why An Exemption From The Requirements Of Section 91.121

Would Not Adversely Affect Safety.

 The equivalent level of safety established by Section 91.121 will be maintained

because the altitude information of the DJI F450 and DJI F550 UAS's will

will be provided to the PIC via GPS equipment and a radio communications telemetry 

data

link, which downlinks from the UA to the GCS for active monitoring of the flight path and

altitude. This altitude information, combined with Marcus Mariner's operation of the
DJI F450 and DJI F550 UA's within visual line of sight, at or below 400

feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude

information will be generated by GPS equipment installed on board the aircraft. Prior to

each flight, a zero altitude initiation point is automatically established by the UAS's at

ground level.

The FAA has previously granted relief from Section 91.121 specific to UAS, in

circumstances similar, in all material respects, to those presented herein (e.g. 

Exemption

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 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 

F450 and DJI F550 UAS's; (2) the limitations on the proposed flight operations; and (3) 

the location of the proposed flight operations. Accordingly, Marcus Mariner will ensure 

that he will safely operate the battery powered DJI F450 and DJI F550 UA's during 

daylight hours in VFR conditions, with enough

battery power to fly for a total duration of 10 minutes to the first point of intended

landing and, assuming normal cruising speed, to fly after that for at least 2.5 minutes.

 Here, as in Exemption No. 11109, the technical specifications of the DJI F450 
and DJI F550

UAS's 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 F450 and DJI F550 UAS's 

provide audible and visual warnings to the PIC at the GCS when the UA's experiences 

low battery voltage, the first warning occurring at

approximately 33% remaining battery power, and again at approximately 10% remaining

battery power. At the critically low battery level, the DJI F450 and DJI F550

UAS's 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, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156,

11157, 11158, 11159, 11160, 11161).

6. Reasons Why An Exemption From The Requirements Of Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) &(b)

Would Not Adversely Affect Safety.
 In seeking this exemption, Marcus Mariner 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 Marcus Mariner will use trained technicians to perform maintenance,

alterations, or preventive maintenance on the UAS's using the methods, techniques, 

and

practices prescribed in the operating documents i.e., the Operations Manual, Monthly

Maintenance Log, and DJI F450 and DJI F550 Instruction Manual.

Furthermore, Marcus Mariner will document and maintain all maintenance records

for the DJI F450 and DJI F550 UAS's. 

Since theDJI F450 and DJI F550 UAS's will be inspected as

prescribed by the operating documents, Marcus Mariner will maintain the equivalent

level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A 

copy

of the DJI F450 and DJI F550 User Manuals are attached here to as

Exhibit C and D; a copy of the DJI F450 and DJI F550 UAS Maintenance LOG is 

attached hereto as Exhibit E.

 Likewise, the exemption sought will not adversely affect safety because Marcus 

Mariner will use trained technicians to perform maintenance, alterations or preventive 

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

 Furthermore, the exemption sought would maintain an equivalent level of safety

Established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of 

the

DJI F450 and DJI F550 UAS's will be performed by trained technicians.

Maintenance will be documented and maintained utilizing the monthly maintenance log.

Significantly, previous exemptions granted by the FAA concerning Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety 

is

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

UAS are considered.

 In consideration of Marcus Mariner's proposed operating limitations, the

operating documents, and the technical aspects of the DJI F450 and DJI F550

UAS's, Marcus Mariner submits that safety will not be adversely affected by

granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 

91.409(a)

(2), and 91.417(a) and (b). The FAA has previously granted relief specific to UAS in

circumstances similar, in all material respects, to those presented herein (e.g. 

Exemption

Nos. 11062, 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, Marcus Mariner requests

that the FAA prescribe special conditions for the intended operation of the DJI F450 and 

DJI F550, 

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, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe 

operation of the UA's for the limited purpose of

conducting aerial video and photography over certain areas of the United States for

compensation or hire. FMRA Section 333 sets forth the requirements for 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 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 DJI F450 and DJI F550 UAS's, since the

airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate

safety standards, due to the novel or unusual design features of the aircraft. Section 
21.16,

entitled Special Conditions, states the following:

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

contain

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

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

propeller, it may prescribe special conditions and amendments thereto for the product.

The special conditions are issued in accordance with Part 11 of this chapter and

contain such safety standards for the aircraft, aircraft engine or propeller as the

FAA finds necessary to establish a level 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 Marcus Mariner's intended operation of the DJI 

F450 and DJI F550 UAS's, which contain such safety standards that the administrator 

finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. 

Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

F. A Summary That Can Be Published In The Federal Register stating: The 

Rules

From Which Marcus Mariner Seeks Exemption:

 Marcus Mariner seeks exemption from the requirements of 14 C.F.R Sections

61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) &

(a)(2), and 91.417(a) & (b).

A Brief Description Of The Nature Of The Exemption Marcus Mariner

Seeks:

 This exemption will permit Marcus Mariner to commercially 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

Marcus Mariner
Request.

 This Petition is made pursuant to the FAA Modernization and Reform Act of 2012

(FMRA) Section 333, which directs the Secretary of Transportation to determine if 

certain

UAS may operate safely in the NAS. As such, Marcus Mariner 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, Marcus Mariner will operate the DJI F450 and DJI F550

UAS's safely in the NAS, without creating a hazard to

users of the NAS, or the public, or otherwise pose a threat to national security.

 CONCLUSION

 As set forth herein, Marcus Mariner 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 F450 and DJI F550 UAS's 

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 public, by allowing Marcus Mariner to safely, efficiently, and 

economically operate the DJI F450 and DJI F550 UAS's commercially within the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA

Modernization and Reform Act of 2012, Section 333, Marcus Mariner respectfully

requests that the Administrator grant this Petition for an exemption from the 

requirements

of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)

(1),

91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Marcus Mariner to operate the

DJI F450 and DJI F550 UAS's commercially for the purpose of conducting

aerial video and photography over certain areas of the United States.

Dated: May 12, 2015

 

 Respectfully submitted,

 Marcus Mariner

 9715 W. Broward Blvd #192

 Plantation, FL 33324

 954-854-2898

 Exhalefilms@gmail.com
APPENDICES:

A - DJI F450 Specifications

B – DJI F550 Specifications

C - Naza V2 User Manual

D – Monthly Maintenance Log

 APPENDIX –A

 DJI F450 w/ Naza V2 TECHNICAL SPECIFICATIONS

Marcus Mariner only utilizes safe and reliable UAS's. DJI is an industry leader in

small UAS production. DJI UAS's are loaded with ground breaking software enabling 

the

user to set parameters which will not allow flight into controlled airspace. Parameters 

can

also be set to limit flight to no higher than a predetermined and set altitude as well as 

limit

flight to a predetermined and set distance. In addition, DJI software provides real-time

altitude and location information to the PIC via the linked monitor, Spektrum DX9 Radio

Control Transmitter.

1.1 DJI F450

1.1.1 Aircraft

1.1.1.1 Batteries –(1) Zippy Compact 5000mAH LiPo Battery

1.1.1.2 Weight, Flight –6 lbs 10oz (3005g)

1.1.1.3 Hover Accuracy–Vertical: +/-.5m; Horizontal: +/-2m

1.1.1.4 Max Tilt Angel -35deg

1.1.1.5 Max Ascent/Descent Speed –6m/s

1.1.1.6 Max Flight Speed –21m/s (NOT RECOMMENDED)

1.1.2 Gimbal

1.1.2.1 GLB 

1.1.2.2 Controller – GLB Version 3 Gimbal 3 Axis Control Board

1.1.2.3 Battery 10000mAh 3s

1.1.2.4 Pan - Controllable 0 deg

1.1.2.5 Pitch - Controllable -90deg

1.1.2.6 Horizon – Automatic

1.1.3 Transmitter FPV 

1.1.3.1 Immersion RC 5.8GHz AV

1.1.3.2 Power Out-put 250mW

1.1.3.3 Frequencies 5740, 5760, 5780, 5800, 5820, 5840 and 5860MHz
1.1.4 Camera

1.1.4.1 GoPro 4

1.1.4.2 Silver

.1.4.4 Operating Temperature Range -32deg F / 104deg F

1.1.4.3 Effective Pixels –12 MP

1.1.5 Transmitter 1 Aircraft & Gimbal

1.1.5.1 Spektrum DX9

1.1.5.2 Operating Frequency 2.400GHz – 2.4835GHz

1.1.5.3 Communication Distance (unobstructed) FCC Compliance 800m

1.1.5.4 Transmitter Power FCC Compliance 100mW

1.1.5.5 Battery 4000mAh Li-lon 2S

1.1.5.6 Operating Temperature -14deg to 104deg F

APPENDIX –B

DJI F550 TECHNICAL w/ Naza V2 SPECIFICATIONS

Marcus Mariner only utilizes safe and reliable UAS's. DJI is an industry leader in

small UAS production. DJI UAS's are loaded with ground breaking software enabling 

the

user to set parameters which will not allow flight into controlled airspace. Parameters 

can

also be set to limit flight to no higher than a predetermined and set altitude as well as 

limit

flight to a predetermined and set distance. In addition, DJI software provides real-time

altitude and location information to the PIC via the linked monitor, Spektrum DX9 Radio

Control Transmitter.

2.2 DJI F5550

2.2.1 Aircraft

2.2.1.1 Battery – Multistar 6600 mAh LiPo

2.2.1.2 Weight (Battery Included) – 7lbs 8oz (3401g)

2.2.1.3 Hover Accuracy–Vertical: +/-.5m; Horizontal: +/-2m

2.2.1.4 Max Angular Velocity –Pitch: 3000/s; Yaw: 1500/s

2.2.1.5 Max Tilt Angle -350

2.2.1.6 Max Ascent Speed –5m/s

2.2.1.7 Max Descent Speed –4m/s

2.2.1.8 Max Speed –22m/s (ATTI mode, no wind) 

2.2.1.9 Max Flight Altitude –4500m

2.2.1.10 Max Wind Resistance –10m/s

2.2.1.11 Max Flight Time –Approximately 10 minutes

2.2.2 Gimbal

2.2.2.1 Controller – GLB Version 3 Gimbal 3 Axis Control Board
2.2.2.2 Controllable Range 0 deg to -90deg

2.2.2.3 Horizon - Automatic

2.2.2.4 Operating Temp -32deg to 140 F

2.2.3 Camera

2.2.3.1 Name – GoPro 4

2.2.3.2 Model – Hero Silver 

2.2.3.3 Pixel 11MP

2.2.4 Transmitter

2.2.4.1 Spektrum DX9

2.2.4.2 Operating Frequency 2.400GHz to 2.4835 GHz

2.2.4.3 Communication Distance (unobstructed) FCC Compliance 800M

2.2.4.4 Transmitter Power FCC Compliance 100mW

2.2.4.5 Battery 1000mAh 3S Li-poly 3S

2.2.4.6 Operating Temperature -14deg to 104deg F

2.2.5 Transmitter FPV

2.2.5.1 Immersion RC 5.8GHz AV2.2.5.2

2.2.5.2 Power Out-put 250mW 

2.2.5.3 Frequencies 5740, 5760, 5780, 5800, 5820, 5840 and 5860MHz40

APPENDIX – C

DJI Naza V2 – Manufacturer's User Manual

http://download.dji-innovations.com/downloads/nazam-v2/

en/NAZA-M_Quick_Start_Guide_v1.26_en.pdf

http://download.dji-innovations.com/downloads/

flamewheel/en/F550_User_Manual_v1.9_en.pdf

http://download.dji-innovations.com/downloads/

flamewheel/en/F450_User_Manual_v2.1_en.pdf

APPENDIX - E

Marcus Mariner

Monthly Maintenance and Repair Log

Aircraft:

Hours:

Date:

Date Issue Date Issue Issue Description/Maintenance Conducted Repair/
Maintenance

Discovered Resolved Performed By

Airframe

Motors

Propellers

Flight Control

Update

Gimbal

Misc