1 UNITED STATES OF AMER ICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASH I NGTON, D. C

.

**IN THE MATTER OF THE PETITION FOR EXEMPTION OF: James Bollinger with**  **TVS Pro (TV Specialists, Inc.) 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 PHANTOM 2, DJI PHANTOM 3, DJI INSPIRE 1 AND** 

**DJI SPREADING WINGS S900 & S1000+ (W/ A2 FC) UNMANNED AIRCRAFT SYSTEMS**  **PURSUANT TO SECTION 333 OF**  **THE FAA**  **MODERNIZATION AND**  **REFORM ACT**  **OF 2012** 

**(PUBLIC LAW**  **112**
**- 95)** 

Submitted on J uly

8 th , 2015 James Bollinger TVS Pro (TV Specialists, Inc.) 180 East 2100 South Salt L ake Cit y, UT 84115 Tel: ( 801) 486

- 5757 Email: jamesb@tvspec.com2 

### Table of Contents

GLOSSARY OF ABBREVIATIONS

................................ ................................ ............................. 3

SUMMARY

................................ ................................ ................................ ................................ ..... 4

I N TRODUCT I ON AND IN TERESTS OF PETITIONER

................................ ............................. 4

BACKGROUND

................................ ................................ ................................ ............................. 4

BAS I S FOR PETITION

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

NAME AND ADDRESS OF PETITIONER

................................ ................................ ........... 6

THE SPEC IF I C SECTIONS OF 14 C.F.R. FROM WH ICH TVS PRO SEEKS EXEMPT ION

................................ ................................ ................................ ........................... 7

THE EXTENT OF RELIEF TVS PRO SEEKS AND THE TVS PRO SEEKS THE RELIEF

................................ ................................ ................................ ................................ .................. 9

THE REASONS WHY GRANTING TVS PRO’S REQUEST WOU L D BE IN THE PUBLIC INTEREST

................................ ................................ ................................ .............. 12

THE REASONS WHY GRANTING THE EXEMPT ION WOULD NOT ADVERSE L Y AFFECT SAFETY

................................ ................................ ................................ ................. 14

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REG I STER

.................... 25
ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMEN TS AVAILABLE TO SUPPORT TVS PRO’S REQUEST

................................ ................................ ...................... 25

CONC L USION

................................ ................................ ................................ .............................. 26

APPEND I CES

................................ ................................ ................................ ............................... 273 **GLOSSARY OF ABBREVIATIONS**

AG L Above Ground Level AO I Area of Interest ATC Air Traffic Control ATO Air Traffic Organization A V Aerial Vehicle CFR Code of Federal Regulati ons COA Certificate of Authorization FA A Fe deral Aviation Administration FA R Federal Aviation Regulation FC Flight Controlle r GCS Ground Control Station GPS Global Positioning S y stem LOL Lo ss of Link NA S National Airspace S ystem NOTAM Notice to Airman P I C Pilot I n Command RC Remote Control Section 333 FA A Modernization & Reform Act of 2012 (FMRA) Section 333 S O Safety Observer SOP Standard Operating Procedures TVS PRO TV Specialists, Inc. U A Unmanned Aircraft UA S Unmanned Aircraft S ystem VF R Visual Flight Rules VLOS Visual Line of Site VMC Visual Meteorological C on ditions VTOL Vertical Takeoff and L anding4 **SUMMARY**

TVS PRO 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 S ystem pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit James Bollinger, with TVS PRO, to operate an Unmanned Aircraft S ystem (UAS) for the commercial purpose of co n ducting aerial photography , videography , and cinematography for weddings, real estate, special events, film sets, television, public events, newsgathering, and land surveying, as well as create compan y photograph y and videograph y for promotional vid eos and training for UAS operations over certain areas of the United States.

**INTRODUCTION AND INTERESTS OF THE PETITIONER**
TVS PRO provides its c lients with expertise and knowledge in production and cinematograph y technologies as well provide audio/video solutions to present, produce, and educate. TVS PRO also provides its clients with the highest quality digital equipment for use in their commercial, pe r sonal, and non

- profit multimedia projects. TVS PRO has over 64 ye ars of professional audio, video and cinematograph y experience and is recognized as an expert in this field. TVS PRO has over 30 ye ars of aerial RC recreational/hobb y experience, and over 3 ye ars of professional aerial video and photograp h y. The objective of TVS PRO’s aerial video and photograph y operations is to provide high quality imaging for a variety of promotional, wedding, comm e rcial, public, and resi d ential uses, specifical l y targeting:

 Production and Motion Picture Filming
 Television/Film
 Wedding Videograp h y and Photograp h y  Real Estate Videography and Photograp h y  Land and Construction Surveying
 I n crease public knowledge of UAS
 Provide training and promote safe UAS operations for resale of DJ I products by doing promotional and training videos and flight demonstrations.

**BACKGROUND** Unmanned Aircraft Sy stems: DJIPhantom 2, DJ I Phantom 3, DJIInspire 1 , DJIS900 & S1000+ UASs TVS Pro seeks an exemption to operate DJ I sy stems for compensation or hire within the NAS. The DJ I Phantom 2 , DJIPhantom 3, DJ I In spire 1 , and DJ I Spreading Wings S900 & S1000+ are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone s ys tems. The DJ I Phantom 2 has a maximum gross wei ght of app roximately 2 pounds 13 ounces, while having a length of 16 inches width of 16 inches, height of 8 inches, and a maximum speed of approximately 29 knots.5

The DJ I Phantom 3 has a maximum gross weight of approximately 3 pounds , while having a length of 16 inc hes , width of 16 inches, height of 8 inches, and a maximum speed of approximately 31 knots. The DJ I Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of ap proximately

42 knots. The DJ I S900 has a maximum gross weight of 18 pounds , a length of approx. 50 inches , width of 50 inches, height of approx. 15 inches, and a maximum speed of approximately

42 knots. The DJ I S1000+ has a maximum gross weight of 24 pound s 4 ounces , a length of approx. 53 inches , width of 53 inches, height of approx. 16 inches, and a maximum speed of approxim ately

45 knots. The DJ I Phantom 2 , DJ I Phantom 3, and DJIInspire 1UA ’ s are equipped with four main rotors; driven b y Li thium Poly me r battery

powered electric motors. The DJ I S900 UA is equipped with 6 main rotors; driven by Li thium Poly mer battery powered electric motors

. The DJ I S1000+ UA is equipped with 8 main rotors; driven by Li thium Poly mer battery powered electric motors **BAS IS FOR PETITION**  Petitioner, TVS Pro , pursuant t o 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 Sy stems, hereby petitions the Administrator to commerciall y o perate the DJIPhantom 2 , DJ I Phantom 3, DJIInspire 1 , DJI Spreading Wings S900 & S1000+ UAS ’ s in the National Airspace Sy stem (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 9 1.7(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, TVS Pro ’s operation of DJ I Phantom 2 , DJIPhantom 3, DJ I Inspire 1 , and DJ I Spreading Wings S900 & S1000+ 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. Accordingl y, TVS Pro 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 onl y apply to aircraft with an airworthiness certificate. TVS Pro submits that the requested relief is proper since an equivalent level of safet y will be ensured. TVS Pro 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 L og, an d DJI Phantom 2, DJIPhantom 3, DJII nspire 1 , DJ I Spreading Wings S900 & S1000+ Instruction Manuals). Furthermore, TVS Pro will document and maintain all maintenance records for the DJIPhantom 2 , DJ I Phantom 3, DJII nspire 1 , and DJISpreading Wings S900 & S1000+ UAS ’ s. Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested b y TVS Pro to the extent necessary to allow a Pilot in Command (PI C) holding a private pilot or higher level certificate, as well as an airman medical certificate, and who has demonstr ated, b y meeting minimum flight

- hour and currency requirements, that the PI C is able to safely operate the DJ I Phantom 2 , DJIPhantom 3, DJII nspire 1 , DJ I Spreading Wings S900 & S1000+ UAS ’ s in a manner consistent with this6

exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structure s. TVS Pro seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the DJ I Phantom 2 , DJ I Phantom 3, DJII nspire 1 , DJISpreading Wings S900 & S1000+ UAS ’ s do not require an airworthiness certificate in accordance with 14 C.F. R. Part 21, Subpart H. As such, TVS Pro submits that he will ensure that the DJ I Phantom 2 , DJ I Phantom 3, DJIInspire 1 , DJISpreading Wings S900 & S1000+ UAS ’ s are in an airworthy condition, prior to every

flight, by determining that the UASs are in compliance with the operating documents (i.e., Monthly Maintenance Lo g, and DJIPhantom 2 , DJ I Phantom 3, DJIInspire 1 , DJ I Spreading Wings S900 & S1000+ Instruction Manual s ), and that the aircraft are in a condition for safe flight. TVS Pro also seeks an exemp tion from the requirements of Section 91.121, entitled Altimeter Settings, as the DJIPhantom 2 , DJ I Phantom 3, DJIInspire 1 , DJI Spreading Wings S900 & S1000+ UA ’ s will not have a ty pical barometric altimeter onboard. However, altitude information of the DJ I Phantom 2 , DJIPhantom 3, DJIInspire 1 , DJ I Spreading Wings S900 & S1000+ UA ’ s will be provided to the PI C via Global Positioning Sy stem (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active m onitoring of the flight path. This altitude information, combined with TVS Pro ’s operation of the DJ I Phantom 2 , DJ I Phantom 3, DJII nspire 1 , DJISpreading Wings S900 & S1000+ UAS ’ s within visual line of sight, at or below 500 feet AGL, will ensure a level of safet y equivalent to Section 91.121. Additionall y, TVS Pro seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions . TVS Pro submits that safet y will not be affected b y operation of th e DJ I Phantom 2, DJ I Phantom 3, DJIInspire 1 , DJISpreading Wings S900 & S1000+ UAs during da y light hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to f l y fo r a total duration of approximately 13 minutes to the first point of intended landing and, assuming normal cruising speed, to f l y after that for at least 4.5 minutes. In accordance with 14 C.F.R. § 11.81, TVS Pro 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: James Bollinger TVS Pro 180 East 2100 South Salt L ake Cit y, UT Tel: (801) 486

- 5757 Email: jamesb@tvspec.com **B. The Speci fic Sections Of 14 C.F.R. From W**  **hich TVS Pro seeks Exemption.**  **1. TVS Pro**  **Seeks Exemption From The Requirements Of Section 61.113(a) And (b).** 7

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 (PI C) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PI C of an aircraft. (b) A private pilot may , for compensation or hire, act as PI C of an aircraft in connection with any business or employ

ment if

— (1) The flight is only

incidental to that business or employ ment; and (2) The aircraft does not carry pas sengers or property

for compensation or hire. **2. TVS Pro**  **Seeks Exe mption 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 unles s it is in an airworthy condition. **3. TVS Pro**  **Seeks Exe mption 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 cruis ing 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 m iles 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. TVS Pro**  **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 cruis ing speed, to fly after that for at least 20 minutes

. **5. TVS Pro**  **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

—8

(a) Shall have that aircr a ft 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. TVS Pro**  **Seeks Exem ption 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 un dergone ma intenance, 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. TVS Pro**  **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 se ction, 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 b y 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. TVS Pro**  **Seeks Exemption From The Requirements Of Sections 91.417(a) And**  **91.417(b).** Section 91.417, entitled Maintenance records, sub sections (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, p rogressive, 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 acceptab le to the Administrator) of the work performed; and9 (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 infor mation: (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 i nstalled 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 safet y directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms prescribed b y § 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 b y other work or for 1 ye ar after the work is perform ed. (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 TVS Pro Seeks And The Reason TVS Pro**  **Seeks The Relief. 1. Extent Of Relief**  **TVS Pro Seeks And The Reason**  **TVS Pro Seeks Relief From S**  **ection 61.113(a) And (b).** Relief from Section 61.113(a) and (b) entitled Private pilot privi leges and limitations:10

Pilot in command, is requested to the extent necessary to allow a PIC ho lding a private pilot or higher level certificate, as well as a current and valid airman medic al 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) stat e That a private pilot may , for compensation or hire, act as PIC of an aircraft in connection with any business or employ

ment if: (1) The flight is only incidental to that business or employ ment; and (2) The aircraft does not carry pa ssengers or property

f or compensation or hire. As set forth more full y below, TVS Pro submits that an equivalent level of safet y will be maintained because no PI C will be all owed to operate the DJ I Phantom 2 , DJIPhantom 3, DJII nspire 1 , and DJ I Spreadi ng Wings S900 & S1000+ UAS ’s unless that PI C has met c ertain flight

- hour and currency requirements, demonstrating that the PIC is able to safel y oper ate either the DJ I Phantom 2 DJIPhantom 2 , DJIPhantom 3, DJ I Inspire 1 , and DJ I Spreading Wings S900 & S1 000+ UAS s in a manner consistent with the operations specifications as described in this exemption, including evasive and e mergency maneuvers, as well as maintaining appropriate distances fro m people, vessels, vehicles and structures. Further, TVS Pro submits that all flights of the DJI Phantom 2, DJ I Phantom 3, DJI Inspire 1 , and DJ I Spreading Wings S900 & S1000+ UASs, c onducted b y the PI C pursuant to the grant of this Petition: (1) will be incidental to TVS Pro ’s business; and ( 2) will not carry passenge rs or property

for compensation or hire. **2. Extent Of Relief TVS Pro Seeks And The Reason TVS Pro Seeks Relief From**  **Section 91.7(a).** Relief from Section 91.7(a) entitled Civil aircraft airworthines s , is requested to the extent required to allow TVS Pro to determine that the D J I Phantom 2, DJ I Phantom 3, DJIInspire 1 , and DJ I Spreading Wings S900 & S1000+ UAS’s are in airworth y condition prior to every flight b y ensuring that the UAS is in compliance with the operating documents (i.e., the TVS Pro Aeria l Operations Manual, Monthly Maint enance Log, and D J I Phantom 2, DJIPhantom 3, DJ I Inspire 1 , and DJ I Spreading Wings S900 & S1000+ I nstruction Manuals). TVS Pro seeks the requested r elief because the DJI Phantom 2, DJ I Phantom 3, DJI Inspire 1 , and DJ I Spreading Wings S900 & S1000+ UAS ’ s do not require an airworthiness ce rtificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, TVS Pro will ensure that the DJ I Phantom 2, DJ I Phantom 3, DJII nspire 1 , and DJ I Spreading Wings S900 & S1000+ UAS ’ s are in airworth y condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJ I Phantom 2 , DJIPhantom 3, DJ I Inspire 1 , and DJ I Spreading Wings S900 & S1000+ Instruction Manual s ) prior to every flight, and furth er, determine that the aircraft are in condition for safe flight, as stated in the conditions and limitations below. **3. Extent Of Relief TVS Pro**  **Seeks And The Reason TVS Pro**  **Seeks Relief From Section 91.121.** 11

Relief from Section 91.121, entitled Altimet er settings, ma y be required to allow flight operations of the DJ I Phantom 2, DJIPhantom 3, DJIInspire 1 , and DJ I Spreading Wings S900 & S1000+ UAS’s, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data li nk to downlink altitude information from the UA to the P IC at the ground control station (GCS). Since the FAA requires that a n y altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), TVS Pr o seeks the requested relief because the D J I Phantom 2, DJ I Phantom 3, DJI Inspire 1 , and DJ I Spreading Wings S900 & S1000+ UA’s altimeter may be set on the ground to zero feet AG L , rather than the local barometric pressure or field altitude, before each f light. Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to compl y with the applicable conditions and limitations stated below. As more ful l y set forth herein, an equivalent level of s afe t y will be maintained since the DJI Phantom 2, DJ I Phantom 3, DJII nspire 1 , and DJISpreading Wings S900 & S1000+ UA’s are equipped with a barometric pressure sensor and GPS equipment, which automatical l y ensures that a ground level pressure setting wi ll be established prior to each flight, and provides th e P I C with altitude information of the UA on the head s - u p displa y of the GCS. **4. Extent Of Relief TVS Pro Seeks And The Reason TVS Pro 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 DJ I Phantom 2, DJI Phantom 3, DJII nspire 1 , and DJ I Spreading Wings S900 & S1000+ UA ’ s durin g daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a to tal duration of 14.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fl y after that for at least 5.5 minutes. TVS Pr o seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered DJ I Phantom 2 , DJIPhantom 3, DJ I In spire 1 , and DJ I Spreading Wings S900 & S1000+ UA ’ s will severely constrain the practicali ty

of any aerial video or still photo flight operations that TVS Pro proposes to conduct pursuant to this Petition. Significantl y, as set forth below, the technical specifications of the DJ I Phantom 2 , DJI Phantom 3, DJII nspire 1 , and DJ I Spreading Wings S900 & S1000+ UAS ’ s, the DJ I Phantom 2 , DJIPhantom 3, DJ I Inspire 1 , and DJ I Spreading Wings S900 & S1000+ operating documents, and TVS Pro ’s proposed operating limitations, ensure that TVS Pro will safely operate the battery powered DJ I Phantom 2 , DJIP hantom 3, DJIInspire 1 , and DJ I Spreading Wings S900 & S1000+ UA ’ s during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly

for a tota l duration of 14 .5 minutes to the first point o f intended landing and, assuming normal cruising speed, to fl y after that for at least 5 .5 minutes. **5. Extent Of Relief TVS Pro Seeks And The Reason TVS Pro Seeks Relief Fro m**  **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) onl y apply to aircraft with an airworthiness certificate, TVS Pro requests relief from these Sections because the DJ I Phantom 2, DJIPhantom 3, DJ I Inspire 1 , and DJ I Sprea ding Wings S900 &12

S1000+ UAS ’ s do not require airworthiness certificates. As set forth more fully below, the DJ I Phantom 2, DJIPhantom 3, DJII nspire 1 , and DJ I Spreading Wings S900 & S1000+ UAS ’ s meet the conditions of FMRA Section 333 for operation with out an airworthiness certificate. Accordingl y, TVS Pro will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the TVS Pro Ae rial Operations Manual, Monthly Maintenance Lo g, and DJIPhantom 2, DJ I Phantom 3, DJIInspire 1 , and DJISpreading Wings S900 & S1000+ Instruction Manual s ). Furthermore, TVS Pro will document and maintain all maintenance records for the DJ I Phantom 2, DJ I Phantom 3, DJIInspire 1 , and DJ I Spreading Wings S900 & S1000+ UASs. **D. The Reasons Why Granting TVS Pro**  **’s Request Would Be In The Public Interest; That Is, How It Would Benefit The Public As A Whole.**  Granting the present Petition will further the public interest b y allowing TVS Pro to safel y, efficientl y, and economically perform aerial video and photograph y for wedding films, real estate, special events, film sets, and landscape over certain areas of the United States. Additionally , use of the DJIPhantom 2, DJ I Phantom 3, DJIInspire 1 , and DJISpreading Wings S900 & S1000+ UAS ’ s will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy . Notably , the benefits of TVS Pro ’s proposed operatio n of the DJ I Phantom 2, DJIPhantom 3, DJIInspire 1 , and DJ I Spreading Wings S900 & S1000+ UAS ’ s will be realized without implicating an y privacy issues. **1. The Public Will Benefit From Decreased Congestion Of The NAS.** The DJ I Phantom 2, DJ I Phantom 3, DJIInspire 1 , and DJ I Spreading Wings S900 & S1000+ UA ’ 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 neede d to perform aerial acquisitions, an exemption allowing the use of a DJ I Phantom 2, DJIPhantom 3, DJII nspire 1 , and DJ I Spreading Wings S900 & S1000+ UAS ’s would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safet y of life and propert y in the air and on the ground. Furthermore, b y reducing the number of manned aircraft operating in the NAS, congestion around airports caused b y arriving and departing aircraft will be reduced. The DJ I Phantom 2, DJ I Phantom 3, DJII nspire 1 , and DJ I Spreading Wings S900 & S1000+ UA ’ 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 handl ed b y air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations. **2. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 &**  **S1000** + **UAS ’**  **s.** Conducting aerial acquisitions with the DJIPhantom 2, DJIPhantom 3, DJ I Inspire 1 , and DJ I Spreading Wings S900 & S1000+ UAS ’ s, instead of manned aircraft, will greatl y benefit the public b y drastically reducing the levels13

of air and noise pollution generated during traditional aerial video and still photography flight operations. By

using battery

power and electric motors, the DJ I Phantom 2, DJIPhantom 3, DJ I Inspire 1 , and DJ I Spreading Wings S900 & S1000+ UAS ’ s produce n o air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are t ypicall y utilized for aerial video and photograph y, while burning approximately

20

- 30 gallons per h our of leaded aviation fuel. The DJIPhantom 2, DJ I Phantom 3, DJII nspire 1 , and DJ I Spreading Wings S900 & S1000+ UAs, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAs are propelled by battery powere d electric motors, rather than an internal combustion engine. By using the DJ I Phantom 2, DJIPhantom 3, DJ I Inspire 1 , and DJ I Spreading Wings S900 & S1000+ UASs 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 DJIPhantom 2, DJ I Phantom 3, D JII nspire 1 , and DJ I Spreading Wings S900 & S1000+ UAs (weighing approximately only 2 pounds 11 ounces to 24 pounds respectivel y, at their maximum gross weights , with lengths of 16 inches to 53 inches respectivel y, widths of 16 inches to 53 inches respect ivel y, and with no fuel on board), has less phy sical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that ty picall y conduct similar operations (weighing approximately

6,000 pounds with a w ingspan of approximately 42 feet, a length of 34 feet, and a fuel capacit y of 180 gallons). **3. Performing Aerial Video and Photography Operations With The DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UASs Will**  **Benefit The Economy.**  In addition to being safe and efficient, the DJ I Phantom 2, DJIPhantom 3, DJIInspire 1 , and DJ I Spreading Wings S900 & S1000+ UASs are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJ I Phantom 2, DJIPhantom 3, DJ I Inspire 1 , and DJ I Spreading Wings S900 & S1000+ UASs will allow United States based companies, like TVS Pro , to remain competitive and contribute to growth of the U.S. econom y. Specifically, with the risi ng 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 DJ I Phantom 2, DJIPhantom 3, DJ I Inspire 1 , and DJ I Spreading Wings S900 & S1000+ UASs is one such technology that not only

allows companies greater operational flexibility

compared to manned aircraft, but provides such flexibility without the hi gh operational cost of a traditional manned aircraft. By operating the DJ I Phantom 2, DJIPhantom 3, DJIInspire 1 , and DJ I Spreading Wings S900 & S1000+ UASs, companies such as TVS Pro , can remain competitive and profitable, and therefore, provide greater job stability to employ ees and contractors, which will ultimately contribute to growth of the U.S. econom y. Improved financial performance of U.S. companies, through commercial use of the DJ I Phantom 2, DJI Phantom 3, DJ I Inspire 1 , and DJ I Spreading Wings S900 & S1000+ UASs, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and devel opment in order to remain competitive both in the United States and abroad.14

**4. There Are No Privacy Issues.**
Similar to the manned aerial acquisition flight operations that have been conducted for decades, TVS Pro’s proposed operation of the D J I Phantom 2, DJIPhantom 3, DJIInspire 1 , and DJ I Spreading Wings S900 & S1000+ UASs will not implicate any privac y issues. Specifical l y , th e D J I Phantom 2, DJIPhantom 3, DJIInspire 1 , and DJ I Spreading Wings S900 & S1000+ UASs will be operated onl y in compliance with operating documents (i.e., the TVS Pro Aerial Operations Manual, Monthly Maintenance Lo g, and D J I Phantom 2, DJ I Phantom 3, DJII nspire 1 , and DJ I Spreading Wings S900 & S1000+ Instruction Manuals) which requires proper

t y owner involvem e nt 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 Exe mption Would Provide A Level O**  **f Safety At Least Equal To That Provided By The Rule From Which**  **TVS Pro Seeks Exemption.**  **1. Reasons Why The DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and DJI**  **Spreading Wings S900 & S1000+ UASs 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, TVS Pro’s operation of the DJI Phantom 2, DJ I Phantom 3, DJ I Inspire 1 , and DJ I Spreading Wings S900 & S1000+ UASs meet the conditions of FMRA Section 333, and will not require an airworthi ness certificate in accordance with 14 C.F.R.Part 21, Subpart H. Section 333 provides authority for a UAS t o operate without airworthiness certification and sets forth requirements for considering whe ther a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security . Specificall y, FMRA Section 333 states the following, in part: (a ) In General.

--Notwithstanding 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 rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act. (b ) Assessment of Unmanned Aircraft Systems.

--In making the dete rmination 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 populated15 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 authorizat ion, 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 Se cretary 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 air space system. In seeking this exemption, TVS Pro submits that the DJ I Phantom 2 and DJIInspire 1 UASs can operate safel y in the NAS pursuant to FMRA Section 333, as demonstrated by : (a) the characteristics of the DJIPhantom , DJ I Phantom 3, DJIInspir e 1 , and DJISpreading Wings S900 & S1000+ UASs; (b) the p ilot certification re quirement; and (c) the specific operating limitations. **a. The Specifications Of The DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+**  **UASs De**  **monstrate Its Safe Characteristics.** The DJ I Phantom 2, DJ I Phantom 3, DJIInspire 1 , and DJ I Spreading Wings S900 & S1000+ UASs 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 DJ I Phantom 2, DJI Phantom 3, DJI**  **Inspire 1, and DJI Spreading Wings S900 & S1000+ UASs**  **, and DJI A2 FC .**  The technical specifications of the DJ I Phantom 2, DJIPhantom 3, DJ I Inspire 1 , and DJISpreading Wings S900 & S1000+ UASs are set forth by the DJ I Phantom 2, DJI Phantom 3, DJII nspire 1 , and DJ I Spreading Wings S900 & S1000+ Specifications and Data Sheet, attached hereto as Appendices A, B , C, D, E and F

.

**ii. The DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UASs Autonomous Flight And Navigation Modes Enable The**  **UASs To Remain Within A Defined Operational Area.** The DJ I Phantom 2, DJ I Phantom 3, DJIInspire 1 , and D JISpreading Wings S900 & S1000+ UASs may

be op erated in both manual and fully autonomous flight modes. A complete description of the flight and navigational modes of the DJ I Phantom 2, DJI Phantom 3, DJII nspire 1 , and DJ I Spreading Wings S900 & S1000+ UA Ss is provided at pages 25

- 35 of the DJ I Phantom 2, page 11

- 14 of the DJ I Phantom 3, pages 12

- 16 and 45

- 50 of the DJ I Inspire 1, and pages 23, 30

- 31 and 33

- 37 of the A2 FC (used for the DJ I Spreading Wings S900 & S1000+ UAVs) User Manuals, attached hereto as Appendices G, H, I, J, K16

and L

. **iii. The DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UASs Are Designed For Automati**  **c Return To Home Point Or Hover**  **In The Event Of Loss Of The Control Link Or Navigation.** W hen the Control L ink is lost, the DJIPhantom 2, DJIPhantom 3, DJ I Inspire 1 , and DJISpreading Wings S900 & S1000+ UAs will remain stationary , in flight, for 3 seconds or more. If, after 3 seconds, the DJ I Phantom 2, DJ I Phantom 3, DJIInspire 1 , and DJ I Spreading Wings S900 & S1000+ UAs do not reacquire control link data from the GCS, the UAs will assume that the Control L ink is lost and the UAs w ill return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and s hutdown. A complete description of the Failsafe Functions o f the DJ I Phantom 2 UAS are set forth at pages 27

- 29 , pages 12

- 14 for the DJ I Phantom 3, pages 13

- 15 for the DJ I Inspire 1, and pages 30

- 31 of the A2 FC (used for the DJ I Spreading Wings S900 & S1000+ UAVs) User Manuals, attached hereto as Appendices G, H, I, J, K and L

. **b. Flight Operations Of DJI Phantom 2, DJI Phantom 3, DJI Inspire 1,**  **and DJI Spreading Wings S900 & S1000+**  **UASs Are Limited To The Line Of Sight Of A Certificated PIC With A**  **Safety Observer.** James Bollinger is a current private pilot, and TVS Pro will only utilize certificated pilots who possess a current and valid airman medical certificate to act as a pilot in command (PI C) of the D J I Phantom 2, DJIPhantom 3, DJ I Inspir e 1 , and DJ I Spreading Wings S900 & S1000+UASs. Additionall y, a safe t y observer will assist all pilots during flight time. **c. Flights Of DJI Phantom 2, DJI Phantom 3, DJI Inspire 1 , and DJI Spreading**  **Wings S900 & S1000+**  **UASs Will Be Conducted Pursuant To Specific Operating**  **Limitations.** In seeking this exemption, TVS Pro proposes to c ommercially operate DJ I Phantom 2, DJIPhantom 3, DJ I In spire 1 , and DJ I Spreading Wings S900 & S1000+ UASs for the special purpose of conducting aerial video and photograp hy over certain areas of United States, pursuant to the following specific operating limitations: 1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: DJ I Phantom 2, DJIPhantom 3, DJ I In spire 1 , and DJ I Spreading Wings S900 & S1000+ UASs . 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 , photograph y and cinematograph y . 3. The UAs may

not be flown at an indicated airspeed exceeding 20 knots.17

4. The UA must be operated at an altitude of no more than 500 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved b y ATC. All altitudes reported to ATC must be in feet AGL. 5. The UAs must be operated within visual l ine of sight (VLOS) of the PI C at all times. This requires the PIC to be able to use human vision unaided by an y device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate. 6 . All operations must utilize a safet y observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC alway s maintains VL OS capability . The SO and PI C must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operatio ns. The PIC must be designated before the flight and cannot transfer his or her d esignation for the duration of the flight. The PI C must ensure that the SO can perform the functions prescribed in the operating documents. 7 . The SO must not perform any other duties bey ond assisting the PI C with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is not permitted to operate the camera or other instruments. 8 . The operating documents and the grant of exemption must be acc essible 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 an d 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 an y 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 questio ns arise regarding updates or revisions to the operating documents. 9 . Prior to each flight the PI C 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. 10 . Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component,18 must undergo a functional test flight. The PI C who conducts the functional test flight must make an entry in the aircraft records. 11 . The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not alread y covered in the relevant sections of the operating documents. 12 . The operator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. 13 . 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 co mponent 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. 14 . Each UASs operated under this exemption mu st comply with all manufacturer Safety Bulletins. 15 . The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections. 16 . The PI C must possess at least a private pilot certificate and at least a current third

class medical certificate. 17 . The operator may

not permit any

PIC to operate unless the PI C meets the operator’s qualification criteria and demonstrates the ability to safel y 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 m anner consistent with 14 C.F.R. § 6 1.51(b). Flights for the purposes of training the operator’s PICs are permitted under the terms of the exemption. However, training operations may onl y be conducted during dedicated training sessions. During training, proficiency , and experience

- building f

lights, all persons not essential for flight operations are considered nonparticipants, and the PI C must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119. 18 . UAS operations may

not be conducted during night, as defined i n 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 speci al visual flight rules (SVFR) are not authorized.19

19 . 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 obta ined, and the operation is conducted in accordance with a NOTAM as required b y the operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request. 20 . The UA may

not be operated less than 500 f eet below or less than 2,000 feet horizontally

from a cloud or when visibility is less than 3 statute miles from the PI C. 21 . If the UA loses communications or loses its GPS signal, it must return to a pre

determined location within the planned operating area and land or be recovered in accordance with the operating documents. 23. The PI C must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents. 24. The PI C is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 25% battery power remaining. 25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting an y 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 COA 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 co nducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 29. The UA must remain clear and yi eld the right of way to all manned aviation operations and activities at all times. 30. The UAS may

not be operated b y the PIC from any moving device or vehicle.20

31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (pers ons other than the PI C, SO, operator trainees or essential persons), vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediatel y and/or; b. The airc raft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PI C has made a safet y 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 PI C, 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 p roperty 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 b y t he 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 Safet y 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.**  TVS Pro submits that the equivalent level of safety e stablished by

Section 61.113(a) and (b) will be maintained because no PIC will be allowed t o operate the DJI Phantom 2, DJ I Phantom 3, DJII nspire 1 , and DJ I Spreading Wings S900 & S1000+ UASs unless that PI C has demonstrated, b y meeting minimum flight

- hour and curr ency requirements, that the PI C is able to safel y operate the DJ I Phantom 2, DJ I Phantom 3, DJIInspire 1 , and DJ I Spreading Wings S900 & S1000+ UAS in a manner consistent with the exemption, includi ng evasive and emergency maneuvers and maintaining appropriate distances from people, ves sels, vehicles and structures. Considering TVS Pro ’s proposed area of operations, an d the operating limitations set forth

- above; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No.11 062); and the airmanship skills necessary to safel y operate the DJ I Phantom 2, DJI Phantom 3, DJ I Inspire 1 , and DJISpreading Wings S900 & S1000+ UAS, TVS Pro sub mits that the additional manned21

airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for TVS Pro ’s specific proposed flight operations. The FAA has previously

granted relief from Sectio n 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). TVS Pro will not allow any PIC to operate the DJ I Phantom 2, DJIPhantom 3, DJI Inspire 1 , and DJ I Spreading Wings S900 & S1000+ UAS un less that PI C has demonstrated, by meeting minimum flight

- h our requirements or the DJ I Phantom 2, DJ I Phantom 3, DJI Inspire 1 , and DJ I Spreading Wings S900 & S1000+ UAS training and currency requirements, that the PIC is able to s afel y operate the DJ I Phantom 2 or DJII nspire 1 UAS in a manner consistent with thi s exemption, i ncluding evasive and emergency maneuvers and maintaining appropriate distances fro m people, vessels, vehicles and structures. Specificall y, the PI C must have accumulated and logg ed, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorc raft pilot (with a minimum of 5 hours of those hours as a UAS pilot operating the same m ake and model of UAS to be used for operations under the exemption). In addition to the hour requirements, th e PI C must accomplish 3 takeof

fs and landings in the preceding 90 day s (for currency purposes). As in Exemption Nos. 11062, 11138, and 11153, pri or documented flight experience that was obtained in compliance with applicable regulations will ensure an equi valent level of safet y during TVS Pro ’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 pr ior t o conducting operations for the purpose of motion picture filming (or similar operations), the PI C must have accumulated and logged, in a manner consistent wi th 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 ho urs logged as a UAS pilot with a multi

- rotor UAS. Prior to operations und er Exemption No. 11062, the PI C must also have accumulated and logged a mi nimum of 5 hours as a UAS pilot operating the same make and model of UAS to b e used for operations under the exemption. For clarification, the FAA considers the se 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 additio n to the hour requirements, the PI C must accomplish 3 takeoffs and landing s in the preceding 90 day s (for currency purposes). The FAA finds that at a minimum, the flight

- hour requirements in Exemption No. 11062 are appropriate to practice and build profici ency in the skills necessary

to safel y conduct the petitioner’s proposed operations . The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satis fy this requirement. Traini ng, 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

- b uilding flights the PI C is required to oper ate the UA with appropriate distances in accordance with 14 C.F.R 91.119.22

Exemption No. 11138 at page 15. Accordingl y, TVS Pro will ensure safe operat ions by not allowing an y P IC to operate the DJ I Phantom 2, DJIPhantom 3, DJ I In spire 1 , and DJ I Spreadin g Wings S900 & S1000+ UAS unles s that PI C has demonstrated, by meeting minimum flight

- hour and currency requir ements, that the PI C is able to safely operate the DJ I Phantom 2, DJIPhantom 3, DJII nspire 1 , and DJ I Spreading Wings S900 & S1000+ UAS in a man ner consistent with the exemption, including evasive and emergency maneuv ers 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 Affe**  **ct Safety** The equivalent level of safet y established b y Sec tion 91.7(a) will be maintained because prior to every

flight, TVS Pro will ensure that the DJ I Phantom 2, DJIPhantom 3, DJII nspire 1 , and DJ I Spreading Wings S900 & S1000+ UAS is in an airworth y 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 f

rom 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 safet y established b y Se ction 91.121 will be maintained because the altitude information of the DJ I Phantom 2, DJIPhantom 3, DJ I Inspire 1 , and DJ I Spreading Wing s S900 & S1000+ UAs will be provided to the PI C via GPS equipment and a radio communications telemetry data link, which downl inks from the UA to the GCS for active monitoring of the flight path and altitude. This alti tude information, combined with TVS Pro ’s operation of the DJ I Phantom 2, DJ I Phantom 3, DJIInspire 1 , and DJ I Spreading Wings S900 & S1000+ UAs within vis ual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information will be g enerated by

GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatic ally established by

the UASs at ground level. The FAA has previously

granted relief from Sec tion 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, 110 80, 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 sp ecifications of the DJ I Phantom23

2, DJIPhantom 3, DJ I In spire 1 , and DJ I Spreading Wings S900 & S1000+ UASs; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly , TVS Pro will ens ure that it will safely operate the battery

powered DJIPhantom 2, DJ I Phantom 3, DJII nspire 1 , and DJISpreading Wings S900 & S1000+ U As during day light hours in VFR conditions, with enough battery power to fly

for a total durati on of 13.5 minutes to the first point of intended landing an d, assuming normal cruising speed, to fl y after that for at least 4.5 minutes. Here, as in Exemption No. 11109, the technical specifications of the DJ I Phantom 2, DJIPhantom 3, DJ I Inspire 1 , and DJ I Spreading Wings S900 & S1000+ UASs; the limitations on the proposed flight operations; and the locat ion of the proposed operations, will ensure an equivalent le vel of safety established by

14 C.F.R. Section 91.151(b). Furthermore, safet y will be ensured as the DJ I Phantom 2 and DJ I Inspire 1 UASs provide au dible and visual warnings to the PIC at the GCS when the UAs experiences low battery voltage, the first warning occurring at approximately 3 3% remaining battery

power, and again at approximately

10% remaining battery

power. At the cr iticall y low battery le vel, the DJIPhantom and DJ I Inspire 1 UASs will descend and land automaticall y. Significantl y, previous exemptions granted b y th e FAA concerning Section 91.151 establish that safet y is not adversel y affected when the technica l characteristics and operat ing limitations of the UAS are considered. Reli ef 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 S ection 91.151 specific to UAS, in circumstances similar, in all material resp ects, to those presented herein (e.g. Exemption Nos. 8811, 108 08, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 111 36, 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, TVS Pro submits that the equivalent level of safety with regard to the regulatory

maintenance and alteration requi rements 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 TVS Pro will use trained technicians to perform maintena nce, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., the TVS Pro Aerial Operati ons Manual, Monthly Maintenance Lo g , and DJ I Phantom 2, DJIPhantom 3, DJ I Inspire 1 , and DJ I Spreading Wings S900 & S1000+ In struction Manual). Furthermore, TVS Pro will document and maintain all maintenance records for the DJ I Phantom 2, DJ I Phantom 3, DJI Inspire 1 , and DJ I Spreading Win gs S900 & S1000+ UASs. Since the DJ I Phantom 2, DJIPhantom 3, DJ I Inspire 1 , and DJ I Spreading Wings S900 & S1000+ UASs wil l be inspected as prescribed by the operating documents, TVS Pro will maintain the equivalent level of safet y established by Se cti ons 91.405(a), 91.409(a)(1), and 91.409(a)(2). A cop y of the DJ I Phantom 2, DJIPhantom 3, DJ I Inspire 1 , and DJ I Spreading Wings S900 & S1000+ User Manuals are attach ed hereto as Appendices A, B , C, D, E and F; a cop y of the DJI Phantom 2 and DJ I Inspire 1 UAS Mainte nance LOG is24

attached hereto as Appendix G

. Likewise, the exemption sought will not adversel y affect safety because TVS Pro will use trained technicians to perform maintenance, alterations o r preventive maintenance o n the UAS using the methods, techniques, and practices prescribed b y the operating documents. Furthermore, the exemption sought would maintai n an equivalent level of safet y established by

Sections 91.407, 91.417(a) and 91.417(b), bec ause all maintenance of the DJ I Phantom 2, DJIPhantom 3, DJII nspire 1 , and DJ I Spreading Wings S900 & S1000+ UASs will be performed b y t rained technicians. Maintenance wi ll be documented and maintained utilizing the monthly

maintenance log. Significantl y, previous exemptio ns 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 safet y is not adversel y affected when the technical characteristics and operating limitations of the UAS are considered. In consi deration of TVS Pro ’s proposed operating limitations, the operating documents, and the technical aspects of the DJ I Phantom 2, DJIPhantom 3, DJIInspire 1 , and DJ I Spreading Wings S900 & S1000+ UASs, TVS Pro submits that safety will not be adversel y affected b y granting exemption from 14 C.F.R. S ections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FA A has previousl y granted relief specific to UAS in circumstances similar, in all material resp ects, to those presented her ein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 110 66, 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 Moder nization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, TVS Pro requests that the FAA prescribe special conditions for the intended operation of the DJ I Phantom 2, DJIPhantom 3, DJII nspire 1 , and DJ I Spreading Wings S900 & S1000+ UASs, which contain such safet y 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 s pecial conditions will permit safe operation of the UAs for th e limited purpose of conducting aerial video and photography over certain areas of the United S tat es for compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS w ill create a hazard to users of the NAS or the public, or otherwise pose a threat to national securit y; and further, provides the authority for such UA S to operate without airworthiness certification in accordance with an y requirements that must be established fo r 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 op eration of the DJ I Phantom 2, DJ I Phantom 3, DJIInspire 1 , and DJ I Spreading Wings S900 & S1000+ UASs, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standar ds, 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 subchapte r do not contain adequate or appropriate safet y standards for an aircraft , aircraft engine, or pro peller25

because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance w ith 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 safet y equivalent to that establi shed 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 James Bollinger, with TVS Pro intend ed operation of the DJIPhantom 2, DJ I Phantom 3, DJII nspire 1 , and DJISpreading Wings S900 & S1000+ UASs, which contain such safet y standards that the Administrator finds ne cessary to establish a level of safet y equivalent to that established by 14 C.F.R. Part 21, S ubpart H, and 14 C.F.R Sections 61 .113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.40 7(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 TVS Pro**  **Seeks Exemption:** TVS Pro seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.1 51(b), 91.405(a), 91.407( a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). **A Brief Description Of The Nature Of Th e Exemption**  **TVS Pro Seeks:**  This exemption will permit TVS Pro to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video , photography and cinematography including photo and/or video for television, public events, newsgathering, real estate and land surveying over certain areas of the United States. As well as assist with company promotional videos and training demonstrations for UAS operations. **G. Any Additional Information, Views, Or Arguments Available To Support TVS Pro’s Request.**  This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transpo rtation to determine if certain UAS may operate safely

in the NAS. As such, TVS Pro’s 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 othe rwise pose a threat to national securit y; and further, provides the authority for such UAS t o operate without airworthiness certification. As discus sed in detail above, TVS Pro will operate the DJ I Phantom 2, DJ I Phantom 3, DJII nspire 1 , and DJ I Spreading Wings S900 & S1000+ UASs safel y in the NAS, without creating a hazard to users of the NAS, or the public, or othe rwise pose a threat to national se curit y.26 **CONCLUSION** As set forth herein, TVS Pro 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 DJ I Phantom 2, DJI Phantom 3, DJI

Inspire 1 , and DJ I Spreading Wings S900 & S1000+ UASs commercially , without an airworthine ss certificate, for the limited purpose of conducting aerial video and photography over cert ain areas of the United States. By granting this Petition, the FAA Administrator wil l be fulfi lling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the inter ests of the public, by allowing TVS Pro to safel y, efficiently, and econo mically operate the DJ I Phantom 2, DJI Phantom 3, DJ I In spire 1 , and DJ I Spreading Wings S900 & S1000+ UASs commerciall y within the NAS. **WHEREFORE** , in accordance with the Federal A viation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, TVS Pro respectfull y requests that the Administrator grant this Petition for an exemption fr om 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 James Bollinger to operate the DJ I Phantom 2, DJI P hantom 3, DJI

Inspire 1 , and DJ I Spreading Wings S900 & S1000+ UASs commerciall y for the purpose of conducting aerial video and photograph y over cert ain areas of the United States. Dated: July 8th , 2015

Respectfully submitted, TVS Pro

_______ _ _______________________

James Bollinger TVS Pro 180 E 2100 S Salt L ake Cit y, UT 84115

(801) 486

- 5757 jamesb@tvspec.com27

Appendices: A

– DJ I Phantom 2 Specifications Data Sheet B

– DJ I Phantom 3 Specifications Data Sheet C

– DJII nspire 1 Specifications Data Sheet D

– DJ I S900 Specifications Data Sheet E

– DJ I S1000+ Specifications Data Sheet F

– DJ I A2 Flight Controller Data Sheet G

– DJ I Phantom 2 Manufacturer’s User Manual H

– DJ I Phant om 3 Manufacturer’s User Manual I

– DJ I Inspire 1 Manufacturer’s User Manual J

– DJ I S900 Manufacturer’s User Manual K

– DJ I S1000+ Manufacturer’s User Manual L

– DJ I A2 FC Manufacturer’s User Manual M

– Monthly

Maintenance Log

APPENDIX

– A **DJI PHANTOM 2 TECHNICAL SPECIFICATIONS** TVS Pro only

utilizes safe and reliable UASs. DJ I is an industry leader in small UAS production. DJ I UASs are loaded with ground breaking software enabling the user to set parameters which will not allow fl ight 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 PI C via the linked monitor (smart phone/tablet devices) 1.1 DJIPhantom 2 1.1.1 Aircraft 1.1.1.1 Supported Battery

– DJ I 5200mAH LiPo Battery 1.1.1.2 Weight (Battery

& Propellers Included)

– 2lbs 11.810oz (1242g) 1.1.1.3 Hover Accuracy

(Ready to Fl y)

– Vertical: .8m; Horizontal: 2.5m 1.1.1.4 Max Yaw Angular Velocit y - 200 0 /s 1.1.1.5 Max Tilt Angel

- 35 0 1.1.1.6 Max Ascent Speed

– 6m/s 1.1.1.7 Max Descent Speed

– 2m/s 1.1.1.8 Max Flight Speed

– 15m/s (NOT RECOMMENDED) 1.1.2 Gimbal 1.1.2.1 Working Current

– Static: 750mA; Dy nam ic: 900mA 1.1.2.2 Control Accuracy

- ±0.03 0 1.1.2.3 Controllable Range

– Pitch:

- 90 0

- 0 0 1.1.2.4 Maximum Angular Speed

– Pitch: 90 0 /s28 APPENDIX

– B **DJI PHANTOM 3 TECHNICAL SPECIFICATIONS**  TVS Pro only

utilizes safe and reliable UASs. DJ I is an industry leader in small UAS production. DJ I UASs 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 PI C via the linked monitor (smart phone/t ablet devices)29

2.2 DJI Phantom 330 APPENDIX

– C **DJI INSPIRE 1 TECHNICAL SPECIFICATIONS**  TVS Pro only

utilizes safe and reliable UASs. DJ I is an industry leader in small UAS production. DJ I UASs 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 predetermine d and set distance. In addition, DJIsoftware provides real

- time altitude and location information to the PI C via the linked monitor (smart phone/tablet devices)31

3.3 DJII nspire 1323334 APPENDIX

– D **DJI SPREADING WINGS S900**  **TECHNICAL SPECIFICATIONS** TVS Pro only

utilizes safe and reliable UASs. DJ I is an industry leader in small UAS production. DJ I UASs are loaded with ground breaking software enabling the user to set parameters which will not allow flight into control led 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 P IC via the linked monitor (smart phone/tablet devices)3536 APPENDIX

– E **DJI SPREADING WINGS S1000+ TECHNICAL SPECIFICATIONS**  TVS Pro only

utilizes safe and reliable UASs. DJ I is an industry leader in small UAS production. DJ I UASs 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 predetermine d and set distance. In addition, DJIsoftware provides real

- time altitude and location information to the PI C via the linked monitor (smart phone/tablet devices)3738 APPENDIX

– F **DJI A2 FLIGHT CONTROLLER TECHNICAL SPECIFICATIONS**  **(USED AS THE**  **FC FOR DJI SPREADING WINGS S900 & S1000+)**  TVS Pro only

utilizes safe and reliable UASs. DJ I is an industry leader in small UAS production. DJ I UASs 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 t o the PI C via the linked monitor (smart phone/tablet devices)3940 APPENDIX

– G DJIPhantom 2 Manufacturer’s User Manual41 APPENDIX

– H DJIPhantom 3 Manufacturer’s User Manual42 APPENDIX

– I DJII nspire 1 Manufacturer’s User Manual43 APPENDIX

– J DJI Spreading Wings S900 Manufacturer’s User Manual44 APPENDIX

– K DJISpreading Wings S1000+ Manufacturer’s User Manual45 APPENDIX

– L DJIA2 Flight Controller Manufacturer’s User Manual46 APPENDIX

– M

MONTHLY MAINTENANCE LOG

**U A**  **S :**  **$** D a t e I s s u e D is c o v e r e d D a t e I s s u e

A dd r e s s e d I ss u e D e s cr i p t i on & M a i n t e n a n c e C o n du c te d M a i n t e n a n c e P e r fo rm e d By: ( P r i n t & S i g n )
S oft w a re ( U pd a t e s )

A i r f r a m e

En g i n e s

P r op e l l e r s

C a m e r a ( G i m b a l )

L a nd i n g ( G e a r )

V i b r a t i on ( D a m p e n i n g )

O t h er :