UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

APPLIED ART AND TECHNOLOGY, LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14

OF THE CODE OF FEDERAL REGULATIONS Part 21, subpart H, Part 27, Sections

45.23(b), 45.27(a), 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a) & (b), 61.113(a) &

(b), 61.315(a), 91.7(a), 91.9(b), 91.119(c), 91.121, 91.151(b), 91.203(a) and (b),

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

COMMERCIAL OPERATION OF DJI INSPIRE 1 UNMANNED AIRCRAFT SYSTEM

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112­95)

Submitted on July 7th, 2015

George Christ

Applied Art & Technology, LLC

2430 106th Street

Urbandale, IA 50322

(515) 331­7400
TABLE OF CONTENTS

GLOSSARY OF ABBREVIATIONS................................................................................ 2

SUMMARY...................................................................................................................... 3

INTRODUCTION AND INTERESTS OF PETITIONER.................................................. 3

UNMANNED AIRCRAFT SYSTEM: DJI INSPIRE 1 UAS.............................................. 4

BASIS FOR PETITION................................................................................................... 4

NAME AND ADDRESS OF PETITIONER .......................................................... 5

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH APPLIED ART &

TECHNOLOGY, LLC SEEKS EXEMPTION........................................................ 5

THE EXTENT OF RELIEF APPLIED ART & TECHNOLOGY, LLC SEEKS

AND THE REASON Applied Art & Technology, LLC SEEKS THE RELIEF.......

14

THE REASONS WHY GRANTING APPLIED ART & TECHNOLOGY, LLC’S

REQUEST WOULD BE IN THE PUBLIC INTEREST ........................................ 20

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

ADVERSELY AFFECT SAFETY ....................................................................... 23

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER......... 40

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE

TO SUPPORT APPLIED ART & TECHNOLOGY, LLC’S REQUEST.................

41

CONCLUSION ............................................................................................................. 41

APPENDICES............................................................................................................... 43

1
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 Takeoff and Landing

2
SUMMARY

Applied Art & Technology, LLC seeks exemption from the requirements of 14

C.F.R §§ Part 21, subpart H, Part 27, 45.23(b), 45.27(a), 61.23(a) and (c), 61.101(e)(4)

and (5), 61.113(a) & (b), 61.113(a) & (b), 61.315(a), 91.7(a), 91.9(b), 91.119(c), 91.121,

91.151(b), 91.203(a) and (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

Applied Art & Technology, LLC to operate an Unmanned Aircraft System (UAS) for the

commercial purpose of conducting aerial video and photography over areas of the

United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Applied Art & Technology, LLC provides its clients with expertise and knowledge

in the field of videography & photography. Applied Art & Technology, LLC has been in

business for 22 years and has worked with many agriculture and industrial and

corporate clients on instructional, informational and entertainment projects. Applied Art

& Technology, LLC is experienced in all aspects of high quality digital content and

videography. The objective of Applied Art & Technology, LLC aerial video and

photography operations is to provide high quality imaging for a variety of clients

included in but not limited to these fields:

● Agricultural equipment and farming industries

● Insurance industries

● Energy industries

● Travel and Tourism

● Marketing and advertising

● Technology and science fields and industries

● Communication companies

● Real estate and construction companies

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Applied Art & Technology, LLC has several highly creative departments that

serve clients in video production and post production, trade show production, interactive

content and displays and website production.

UNMANNED AIRCRAFT SYSTEM: DJI INSPIRE 1 UAS

Applied Art & Technology, LLC seeks an exemption to operate DJI UA systems

for compensation or hire within the NAS. The DJI Inspire 1 is a vertical takeoff and

landing Unmanned Aircraft with a Ground Control Station utilizing electronic tablet or

smart phone systems. The DJI 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 approximately 42 knots. The DJI Inspire 1 UA is equipped with four

main rotors; driven by Lithium Polymer battery powered electric motors.

BASIS FOR PETITION

Petitioner, Applied Art & Technology, LLC, pursuant to the provisions of the

Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and

Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft

Systems, hereby petitions the Administrator to commercially operate the DJI Inspire 1

UAS in the National Airspace System (NAS), and for an exemption from the

requirements of 14 C.F.R §§ Part 21, subpart H, Part 27, 45.23(b), 45.27(a), 61.23(a)

and (c), 61.101(e)(4) and (5), 61.113(a) & (b), 61.113(a) & (b), 61.315(a), 91.7(a),

91.9(b), 91.119(c), 91.121, 91.151(b), 91.203(a) and (b), 91.405(a), 91.407(a)(1),

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

The operations outlined herein, and in the Petitioner's manuals, clearly define

UAS operations in the NAS that are under appropriately controlled conditions and within

secure and sterile zones of operation and pose no significant safety risk to persons or

property on the ground, no risk to National Security, and would not constitute as an

invasion of any persons reasonable expectation of privacy.

4
A. Name And Address Of The Petitioner.

The name and address of the Petitioner and point of contact is:

George Christ

Applied Art & Technology, LLC

2430 106th Street

Urbandale, IA 50322

(515) 331­7400

Email: gchrist@appliedart.com

B. The Specific Sections Of 14 C.F.R. From Which Applied Art & Technology, LLC

Seeks Exemption.

1. Applied Art & Technology, LLC Seeks Exemption From The

Requirements Of 14 C.F.R. Part 21, Subpart H and Sections 91.203(a) and

91.203(b) and 14 C.F.R. Part 27.

Part 21, Subpart H, entitled Airworthiness Certificates, establishes the procedural

requirements for the issuance of airworthiness certificates as required by FAR

§91.203 (a) (1).

Section 91.203 entitled Civil aircraft: Certifications required, subsections (a) and

(b) state the following, in part:

(a) Except as provided in section 91.715, no person may operate a civil aircraft

unless it has within it the following, in part:

(1) An appropriate and current airworthiness certificate. Each U.S.

airworthiness certificate used to comply with this subparagraph (except a

special flight permit, a copy of the applicable operations specifications

issued under section 21.197(c) of this chapter, appropriate sections of the

air carrier manual required by parts 121 and 135 of this chapter containing

that portion of the operations specifications issued under section

21.197(c), or an authorization under section 91.611) must have on it the

registration number assigned to the aircraft under part 47 of this chapter.

However, the airworthiness certificate need not have on it an assigned

special identification number before 10 days after that number is first

affixed to the aircraft. A revised airworthiness certificate having on it an

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assigned special identification number that has been affixed to an aircraft

may only be obtained upon application to an FAA Flight Standards district

office.

(2) An effective U.S. registration certificate issued to its owner or, for

operation within the United States, the second copy of the Aircraft

registration Application as provided for in section 47.31(c), or a registration

certification issued under the laws of a foreign country

.

(b) No person may operate a civil aircraft unless the airworthiness certificate

required by paragraph (a) of this section or a special flight authorization issued

under section 91.715 is displayed at the cabin or cockpit entrance so that it is

legible to passengers or crew.

Part 27 sets forth the procedural requirements for airworthiness certification of

normal category rotorcraft.

2. Applied Art & Technology, LLC Seeks Exemption From The Requirement

Of Sections 91.9(b), 45.23(b) and and 45.27(a).

Section 91.9 entitled Civil aircraft flight manual, marking, and placard

requirements, subsection (b) states the following, in part:

(b) No person may operate a U.S.­registered civil aircraft­­

(1) For which an Airplane or Rotorcraft Flight Manual is required by

section 21.5 of this chapter unless there is available in the aircraft a

current, approved Airplane or Rotorcraft Flight Manual or the manual

provided for in section 121.141(b); and

(2) For which an Airplane or Rotorcraft Flight Manual is not required by

section 21.5 of this chapter, unless there is available in the aircraft a

current approved Airplane or Rotorcraft Flight Manual, approved manual

material, markings, and placards, or any combination thereof.

Section 45.23 entitled Display of marks; general, subsection (b), states the

following, in part:

6
(b) When marks include only the Roman capital letter "N" and the registration

number is displayed on limited, restricted or light­sport category aircraft or

experimental or provisionally certificated aircraft, the operator must also display

on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters

not less than 2 inches nor more than 6 inches high, the words "limited,"

"restricted," "light­sport," "experimental," or "provisional," as applicable.

Section 45.27(a), Rotorcraft, states:

Each operator of a rotorcraft must display on that rotorcraft horizontally on both

surfaces of the cabin, fuselage, boom, or tail the marks required by section

45.23.

3. Applied Art & Technology, LLC Seeks Exemption From The

Requirements Of Section 61.23(a).

Section 61.23(a), entitled Operations requiring a medical certificate:

Requirements and duration, subsection (a) prescribe the following, in relevant

part:

(f) Except as provided in paragraphs (d) and (i) of this section, a recreational pilot

may not act as pilot in command of an aircraft4. Applied Art & Technology, LLC Seeks Exemption From The

Requirements Of Section 61.101(e)(4) and (5).

Section 61.101, entitled Recreational pilot privileges and limitations: Pilot in

command, subsection (e)(4) and (5) prescribe the following, in relevant part:

(e) Except as provided in paragraphs (d) and (i) of this section, a recreational pilot may

not act as pilot in command of an aircraft­

(4) For compensation or hire; (5) In furtherance of a business;

5. ​Applied Art & Technology, LLC​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:

7
(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.

6. Applied Art & Technology, LLC Seeks Exemption From The

Requirements Of Section 61.315(a).

Section 61.315(a), entitled What are the privileges and limits of my sport pilot

certificate, subsection (a) prescribes the following in part:

(a) If you hold a sport pilot certificate you may act as pilot in command of a

light­sport aircraft, except as specified in paragraph (c) of this section

(c) You may not act as pilot in command of a light­sport aircraft:

(2) For compensation or hire.

(3) In furtherance of a business.

7. Applied Art & Technology, LLC 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.

8. Applied Art & Technology, LLC Seeks Exemption From The

Requirements Of Section 91.103.

Section 91.103, entitled Preflight action, states the following:

8
Each pilot in command shall, before beginning a flight, become familiar with all

available information concerning that flight. This information must include—

(a) For a flight under IFR or a flight not in the vicinity of an airport, weather

reports and forecasts, fuel requirements, alternatives available if the planned

flight cannot be completed, and any known traffic delays of which the pilot in

command has been advised by ATC;

(b) For any flight, runway lengths at airports of intended use, and the following

takeoff and landing distance information:

(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight

Manual containing takeoff and landing distance data is required, the

takeoff and landing distance data contained therein; and

(2) For civil aircraft other than those specified in paragraph (b)(1) of this

section, other reliable information appropriate to the aircraft, relating to

aircraft performance under expected values of airport elevation and

runway slope, aircraft gross weight, and wind and temperature.

9. Applied Art & Technology, LLC Seeks Exemption From The

Requirements Of Section 91.109(a).

Section 91.109(a), entitled Flight instruction prescribes that any civil aircraft

operated for the purpose of flight instruction must have fully functioning dual

controls, states the following, in part:

(a) No person may operate a civil aircraft (except a manned free balloon) that is

being used for flight instruction unless that aircraft has fully functioning dual

controls. However, instrument flight instruction may be given in an airplane that is

9
equipped with a single, functioning throwover control wheel that controls the

elevator and ailerons, in place of fixed, dual controls.

10. Applied Art & Technology, LLC Seeks Exemption From The

Requirements Of Section 91.119(c).

Section 91.119(c), entitled Minimum safe altitudes: (c) Over other than congested

areas, states the following, in part:

Except when necessary for takeoff or landing, no person may operate an aircraft

below the following altitudes:

(c) Over other than congested areas. An altitude of 500 feet above the surface,

except over open water or sparsely populated areas. In those cases, the aircraft

may not be operated closer than 500 feet to any person, vessel, vehicle, or

structure.

11. Applied Art & Technology, LLC Seeks Exemption From The

Requirements Of Section 91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in

part:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight

level of that aircraft, as the case may be, by reference to an altimeter that is set,

when operating­­

(1) Below 18,000 feet MSL, to­­

(i) The current reported altimeter setting of a station along the route

and within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph

(a)(1)(i) of this section, the current reported altimeter setting of an

appropriate available station; or

(iii) In the case of an aircraft not equipped with a radio, the

elevation of the departure airport or an appropriate altimeter setting

available before departure.

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12. Applied Art & Technology, LLC Seeks Exemption From The

Requirements Of Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions,

subsection (b), states the following:

(b) No person may begin a flight in a rotorcraft under VFR conditions unless

(considering wind and forecast weather conditions) there is enough fuel to fly to

the first point of intended landing and, assuming normal cruising speed, to fly

after that for at least 20 minutes.

13. Applied Art & Technology, LLC Seeks Exemption From The

Requirement Of Section 91.405(a).

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

following:

Each owner or operator of an 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.

14. Applied Art & Technology, LLC Seeks Exemption From The

Requirements Of Section 91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive maintenance,

rebuilding, or alteration, subsection (a)(1), states the following:

(a) No person may operate any aircraft that has undergone maintenance,

preventive maintenance, rebuilding, or alteration unless­­

(1) It has been approved for return to service by a person authorized

under § 43.7 of this chapter[.]

15. Applied Art & Technology, LLC Seeks Exemption From The

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

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

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(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 section

43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in

accordance with part 21 of this chapter.

16. Applied Art & Technology, LLC Seeks Exemption From The

Requirements Of Sections 91.417(a) And 91.417(b).

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

following:

(a) Except for work performed in accordance with sections 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 100­hour, 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.

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(ii) The current status of life­limited 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.

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C. The Extent Of Relief Applied Art & Technology, LLC Seeks And The Reason

Applied Art & Technology, LLC Seeks The Relief.

1. Extent Of Relief Applied Art & Technology, LLC Seeks And The Reason

Applied Art & Technology, LLC Seeks Relief From 14 C.F.R. Part 21,

Subpart H and Sections 91.203(a) and 91.203(b) and 14 C.F.R. Part 27.

Given the size and limited operating area associated with the sUAS to be utilized

by the Petitioner, an exemption from Part 21 Subpart H meets the requirements of an

equivalent level of safety under Part 11 and Section 333 of the Reform Act.

The Federal Aviation Act (49 U.S.C.§ 44701(f)) and Section 333 of the Reform

Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness

certificate, upon consideration of the size, weight, speed, operational capability, and

proximity to airports and populated areas of the particular UAS. In all cases, an

analysis of these criteria demonstrates that the sUAS operated without an airworthiness

certificate, in the restricted environment and under the conditions proposed will be at

least as safe, or safer, than a conventional rotorcraft operating with an airworthiness

certificate without the restrictions and conditions of the proposed sUAS operations.

To the extent the Petitioner's sUAS would otherwise require certification under

Part 27, as a rotorcraft, Petitioner requests an exemption from Part 27's airworthiness

standards for the same reasons identified in the exemption request from 14 C.F.R. Part

21, Subpart H.

2. Extent Of Relief Applied Art & Technology, LLC Seeks And The Reason

Applied Art & Technology, LLC Seeks Relief From Sections 91.9(b),

45.23(b) and 45.27(a).

Exemption from section 45.23(b) is warranted because the DJI Inspire 1 UAS

has no entrance to the cabin, cockpit, or pilot station on which the word "Experimental"

can be placed. Moreover, given the size of the DJI Inspire 1 UAS, two­inch lettering

would be impossible. The word "Experimental" will be placed on the fuselage in

compliance with § 45.29(f). Given the nature of the specific relief sought by this

14
exemption request, Petitioner requires relief from the associated marking and

identification requirements of section 45.27(a) and section 91.9(c), which would require

compliance with section 45.23(b).

3. Extent Of Relief Applied Art & Technology, LLC Seeks And The Reason

Applied Art & Technology, LLC Seeks Relief From Section 61.23(a).

Relief from Section 61.23(a), entitled Operations requiring a medical certificate:

Requirements and duration, is requested to the extent required to necessary to allow a

PIC holding a sport pilot certificate or higher level certificate, as well as a current and

valid driver’s license, to conduct the proposed UAS flight operations for compensation

or hire.

This relief is requested since the limitations set forth in Section 61.23(a)

otherwise require the PIC of any flight for compensation or hire to hold a comprehensive

FAA issued medical certificate. In Exemption No. 11213 to Aeryon Labs, Inc., the FAA

“finds that, because of the risk mitigations established in the conditions and limitations

of this exemption, a person that holds a U.S. issued driver’s license who is operating a

UAS will not adversely affect safety. The FAA is granting relief from § 61.23(a) to allow

any pilot that holds one of the pilot’s certificates discussed above to operate a UAS

under this exemption with a U.S. issued driver’s license, in lieu of an FAA­issued

medical certificate. The FAA is also granting relief from § 61.23(c) to allow sport pilot

certificate holders to operate aircraft other than LSA with a U.S. issued driver’s license

under this exemption.”

4. Extent of Relief Applied Art & Technology, LLC Seeks And The Reason

Applied Art & Technology, LLC Seeks Relief From Sections 61.101(e)(4) &

(e)(5), 61.113(a), and 61.315(a).

Relief from sections 61.101(e)(4) & (e)(5), entitled Recreational pilot privileges

and limitations; section 61.113(a), entitled Private pilot privileges and limitations: Pilot in

command; and section 61.315(a), entitled What are the privileges and limits of my sport

pilot certificate, is requested to the extent necessary to allow a PIC holding a sport pilot,

15
recreational pilot, or private pilot certificate, as well as an airman medical certificate or

U.S. issued driver’s license, and who has met certain flight­hour and currency

requirements, to conduct the proposed UAS flight operations for compensation or hire,

subject to the conditions and limitations below.

This relief is requested since the limitations set forth in sections 61.101(e)(4) &

(e)(5) state that no person who holds a recreational pilot certificate may act as pilot in

command of an aircraft for compensation or hire or in furtherance of a business. Relief

is requested from 61.113(a) since the limitations set forth in that section state that no

person who holds a private pilot certificate may act as pilot in command of an aircraft

that is carrying passengers or property for compensation or hire; nor may that person,

for compensation or hire, act as pilot in command of an aircraft. Relief is requested from

61.315(a) since the limitations set forth in that section only allow a person who holds a

sport pilot certificate to act as pilot in command of a light­sport aircraft.

As set forth more fully below, Applied Art & Technology, LLC submits that an

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

the Inspire 1 UAS unless that PIC has met certain flight­hour and currency

requirements, demonstrating that the PIC is able to safely operate the Inspire 1 UAS in

a manner consistent with the operations specifications as set forth herein, including

evasive and emergency maneuvers, as well as maintaining appropriate distances from

people, vessels, vehicles, and structures.

Further, Applied Art & Technology, LLC submits that the additional airmanship

experience of a commercially certified pilot would not correlate to the airmanship skills

necessary for Applied Art & Technology, LLC’s specific proposed operations.

5. Extent Of Relief Applied Art & Technology, LLC Seeks And The Reason

Applied Art & Technology, LLC 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 Applied Art & Technology, LLC to determine that the DJI Inspire

1 UAS is in airworthy condition prior to every flight by ensuring that the UAS is in

16
compliance with the operating documents (i.e., the Applied Art & Technology, LLC

Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction

Manual).

Applied Art & Technology, LLC seeks the requested relief because the DJI

Inspire 1 UAS does not require an airworthiness certificate in accordance with 14 C.F.R.

Part 21, Subpart H. Therefore, Applied Art & Technology, LLC will ensure that the DJI

Inspire 1 UAS is in airworthy condition based upon its compliance with the operating

documents (i.e., the Applied Art & Technology, LLC Aerial Operations Manual, Monthly

Maintenance Log, and DJI Inspire 1 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.

6. Extent Of Relief Applied Art & Technology, LLC Seeks And The Reason

Applied Art & Technology, LLC Seeks Relief From Section 91.103.

Relief from Section section 91.103 is requested, as FAA approved rotorcraft flight

manuals will not be used. In the absence of the flight manuals the PIC will take all

pre­flight actions, including reviewing weather, flight battery requirements, landing and

takeoff distances, and aircraft performance data before starting a flight.

7. Extent Of Relief Applied Art & Technology, LLC Seeks And The Reason

Applied Art & Technology, LLC Seeks Relief From Section 91.109(a).

Relief from Section section 91.109a is requested, as sUAS and remotely piloted

aircraft, by their design do not have fully functional dual controls. Instead, flight control is

accomplished through the use of a control box that communicates with the sUAS via

radio communications.

8. Extent of Relief Applied Art & Technology, LLC Seeks And The Reason

Applied Art & Technology, LLC Seeks Relief From Section 91.119(c).

17
Relief from Section 91.119(c), entitled Minimum safe altitudes: (c) Over other

than congested areas, is required because all proposed operations of the Inspire 1 UAS

will take place at an altitude at or below 400 feet AGL. This relief is requested since the

limitations set forth in Section 91.119(c) state that no person may operate an aircraft

below 500 feet above the surface. As set forth more fully below, Applied Art &

Technology, LLC submits that a level of safety equivalent to Section 91.119(c) will be

maintained because operations will be conducted in areas with controlled access and

under the safety provisions contained within this petition and the Inspire 1 operating

documents.

Additionally, relief from Section 91.119(c) is requested to the extent necessary to

allow operations to be conducted closer than 500 feet to persons, vessels, vehicles, or

structures, under certain conditions. This relief is requested since the limitations set

forth in Section 91.119(c) prohibit operating an aircraft closer than 500 feet to a person,

vessel, vehicle, or structure. As set forth more fully below, Applied Art & Technology,

LLC submits an equivalent level of safety will be maintained because operations closer

than 500 feet to a person, vessel, vehicle, or structure will first require that the operator

receive permission from any nonparticipating persons or the person who owns/controls

the property. In addition, barriers or structures will be in place to sufficiently protect

nonparticipating persons from debris in the event of an accident and all nonparticipating

persons will be required to remain under such protections for the duration of the

operation.

9. Extent Of Relief Applied Art & Technology, LLC Seeks And The Reason

Applied Art & Technology, LLC Seeks Relief From Section 91.121.

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

flight operations of the DJI Inspire 1 UAS, which utilize a barometric pressure sensor,

GPS equipment, and a radio communications telemetry data link to downlink altitude

information from the UA to the PIC at the ground control station (GCS). Since the FAA

requires that any altitude information concerning UAS operations be reported to air

18
traffic control (ATC) in feet above ground level (AGL), Applied Art & Technology, LLC

seeks the requested relief because the DJI Inspire 1 UA’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 Inspire 1 UA is 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 heads­up display of the GCS.

10. Extent Of Relief Applied Art & Technology, LLC Seeks And The Reason

Applied Art & Technology, LLC 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

Inspire 1 UA during daylight hours in visual meteorological conditions (VMC), under

visual flight rules (VFR), for a total duration of 13.5 minutes to the first point of intended

landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

Applied Art & Technology, LLC seeks the requested relief because without an

exemption from Section 91.151(b), the flight time duration of the battery powered DJI

Inspire 1 UA will severely constrain the practicality of any aerial video or still photo flight

operations that Applied Art & Technology, LLC proposes to conduct pursuant to this

Petition.

Significantly, as set forth below, the technical specifications of the DJI Inspire 1

UAS, the DJI Inspire 1 operating documents, and Applied Art & Technology, LLC’s

proposed operating limitations, ensure that Applied Art & Technology, LLC will safely

operate the battery powered DJI Inspire 1 UA during daylight hours in visual

meteorological conditions (VMC), under visual flight rules (VFR), with enough battery

19
power to fly for a total duration of 13.5 minutes to the first point of intended landing and,

assuming normal cruising speed, to fly after that for at least 4.5 minutes.

11. Extent Of Relief Applied Art & Technology, LLC Seeks And The Reason

Applied Art & Technology, LLC 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, Applied Art & Technology, LLC

requests relief from these Sections because the DJI Inspire 1 UAS does not require

airworthiness certificates. As set forth more fully below, the DJI Inspire 1 UAS meets

the conditions of FMRA Section 333 for operation without an airworthiness certificate.

Accordingly, Applied Art & Technology, LLC will use trained technicians to perform

maintenance, alterations, or preventive maintenance on the UAS using the methods,

techniques, and practices prescribed in the UAS operating documents (i.e., the Applied

Art & Technology, LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI

Inspire 1 Instruction Manual). Furthermore, Applied Art & Technology, LLC will

document and maintain all maintenance records for the DJI Inspire 1 UAS.

D. The Reasons Why Granting Applied Art & Technology, LLC’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 by allowing Applied

Art & Technology, LLC to safely, efficiently, and economically perform aerial

videography and photography for its clients over certain areas of the United States.

Additionally, use of the DJI Inspire 1 UAS will decrease congestion of the NAS,

reduce pollution, and provide significant benefits to the economy. Notably, the benefits

of Applied Art & Technology, LLC’s proposed operation of the DJI Inspire 1 UAS will be

realized without implicating any privacy issues.

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

20
The DJI Inspire 1 UA is 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 a DJI Inspire 1 UAS 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 Inspire 1 UA

does 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

Inspire 1 UAS.

Conducting aerial acquisitions with the DJI Inspire 1 UAS, 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 Inspire 1 UAS produce no air

pollution, and is the most viable environmentally conscious alternative to the cabin

class, six cylinder internal combustion engine aircraft that are typically utilized for aerial

video and photography, while burning approximately 20­30 gallons per hour of leaded

aviation fuel. The DJI Inspire 1 UAS, while reducing the carbon footprint of aerial

acquisitions, also eliminates noise pollution, as the UAs are propelled by battery

powered electric motors, rather than an internal combustion engine.

By using the DJI Inspire 1 UAS to perform aerial acquisitions, the substantial risk

to life and property in the air and on the ground, which is usually associated with

traditional manned aircraft flight operations, will be substantially reduced or completely

eliminated. Aside from the lack of flight crew members located onboard the aircraft, the

21
DJI Inspire 1 UA (weighing approximately 6 pounds 7.5 ounces at its maximum gross

weight with length of 17.3 inches, width of 17.7 inches, height of 11.8 inches 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 with a wingspan of

approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations With The DJI

Inspire 1 UAS Will Benefit The Economy.

In addition to being safe and efficient, the DJI Inspire 1 UAS is also an

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

such, operation of the DJI Inspire 1 UAS will allow United States based companies, like

Applied Art & Technology, LLC, 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 Inspire 1 UAS is one such

technology that not only allows companies greater operational flexibility compared to

manned aircraft, but provides such flexibility without the high operational cost of a

traditional manned aircraft.

By operating the DJI Inspire 1 UAS, companies such as Applied Art &

Technology, LLC, 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 Inspire 1 UAS, 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.

22
Similar to the manned aerial acquisition flight operations that have been

conducted for decades, Applied Art & Technology, LLC’s proposed operation of the DJI

Inspire 1 UAS will not implicate any privacy issues. Specifically, the DJI Inspire 1 UAS

will be operated only in compliance with operating documents (i.e., the Applied Art &

Technology, LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire

1 Instruction Manual) 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 Applied Art & Technology, LLC Seeks

Exemption.

1. Reasons Why The DJI Inspire 1 UA 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, Applied Art & Technology, LLC’s operation

of the DJI Inspire 1 UAS meets 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.­­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.

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(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, Applied Art & Technology, LLC submits that the DJI

Inspire 1 UAS can operate safely in the NAS pursuant to FMRA Section 333, as

demonstrated by: (a) the characteristics of the DJI Inspire 1 UAS; (b) the pilot

certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The DJI Inspire 1 UAS Demonstrate Its

Characteristics.

The DJI Inspire 1 UAS does 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 Inspire 1 UAS.

The technical specifications of the DJI Inspire 1 Specifications and Data Sheet

can be found in APPENDIX ­ A.

24
ii. The DJI Inspire 1 UAS Autonomous Flight And Navigation Modes

Enable The UASs To Remain Within A Defined Operational Area.

The DJI Inspire 1 UAS may be operated in both manual and fully autonomous

flight modes. A complete description of the flight and navigational modes of the DJI

Inspire 1 UAS is provided at pages 12­16 and 45­50 of the DJI Inspire 1 User Manual,

which can be downloaded from the DJI website at this link:

http://www.dji.com/product/inspire­1/download.

iii. The DJI Inspire 1 UA Is 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 Inspire 1 UA will remain stationary, in flight,

for 3 seconds or more. If, after 3 seconds, the DJI Inspire 1 UA does not reacquire

control link data from the GCS, the UA will assume that the Control Link is lost and the

UA 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 DJI Inspire 1 at pages 13

through 15 of the DJI Inspire 1 User Manual, which can be downloaded from the DJI

website at this link: http://www.dji.com/product/inspire­1/download.

iv. The DJI Inspire 1 GCS And Its Operation.

A complete description of the operation and specifications of the Inspire 1 GCS

and flight control software is provided at pages 40 through 47 of the DJI Inspire 1 User

Manual, which can be downloaded from the DJI website at this link:

http://www.dji.com/product/inspire­1/download.

b. Flight Operations Of DJI Inspire 1 UAS Is Limited To The Line Of Sight Of

A Certificated Pilot in Command With A Safety Observer.

25
Applied Art & Technology, LLC will only utilize certificated pilots to act as a pilot

in command (PIC) of the DJI Inspire 1 UAS. Additionally, a safety observer will assist all

pilots during flight time.

c. Flights Of DJI Inspire 1 UAS Will Be Conducted Pursuant To Specific

Operating Limitations.

In seeking this exemption, Applied Art & Technology, LLC proposes to commercially

operate DJI Inspire 1 UAS for the special purpose of conducting aerial video and

photography over certain areas of United States, pursuant to the following specific

operating limitations:

1. Operations authorized by this grant of exemption will be limited to the following

aircraft described in the operating documents, rotorcraft UASs weighing less than

55 pounds maximum gross weight: DJI Inspire 1 Unmanned Aircraft System.

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 UAs may not be flown at an indicated airspeed exceeding 20 knots.

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 by ATC. All altitudes

reported to ATC must be in feet AGL.

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

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

device other than corrective lenses, as specified on the PIC’s FAA­issued 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.

26
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 (AFS­80) 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.

27
12. The pre­flight 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 UASs operated under this exemption must comply with all

manufacturer's 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 sport pilot 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 PICs are permitted

under the terms of the exemption. However, training operations may only be

conducted during dedicated training sessions. During training, proficiency, and

experience­building 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. §

19.1. 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.

28
20. The UA may not operate within 5 nautical miles of an airport reference point

as denoted on a current FAA­published 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 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 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 UA must comply with the Federal Communications

29
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 UA must remain clear and yield the right of way to all manned aviation

operations and activities at all times.

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

31. Flight operations must be conducted at least 500 feet from all

nonparticipating persons (persons other than the PIC, SO, operator trainees or

essential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect

nonparticipating persons from the UA and/or debris in the event of an

accident. The operator must ensure that nonparticipating persons remain

under such protection. If a situation arises where nonparticipating persons

leave such protection and are within 500 feet of the UA, flight operations

must 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 controlled­access 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.

30
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 (AFS­80) 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 14 C.F.R. Part

21, Subpart H and Sections 91.203(a) and 91.203(b) and 14 C.F.R. Part 27

Would Not Adversely Affect Safety.

The Inspire 1 UAS is less than 55 lbs. fully loaded, carries neither a pilot nor

passenger, and carries no explosive materials or flammable liquid fuels. Unlike other

civil aircraft, the proposed operations in this petition for exemption will be controlled and

monitored by the operator in accordance with the Manuals’ requirements. These safety

enhancements, which already apply to civil aircraft operated in connection with existing

inspection operations, provide a greater degree of safety to the public and property

owners than conventional operations conducted with airworthiness certificates issued

under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria

demonstrates that there is no credible threat to national security posed by the sUAS,

due to its size, speed of operation, location of operation, lack of explosive materials or

flammable liquid fuels, and inability to carry a substantial external load.

To the extent of Part 27's airworthiness standards, Safety for not be adversely be

affected for the same reasons identified in the response from 14 C.F.R. Part 21,

Subpart H.

3. Reasons Why An Exemption From The Requirements Of Sections

91.9(c), 45.23(b) and 45.27(a) Would Not Adversely Affect Safety.

An equivalent level of safety for exemptions to the aircraft marking and

identification requirements of sections 91.9(c), 45.23(b) and 45.27(a), will be provided

by having the DJI Inspire 1 UAS marked on its fuselage as required by §45.29(f) where

the pilot, observer, and others working with the sUAS will see the identification of the

UAS as "Experimental." Additionally, Petitioner will ensure compliance with any

requests of sUAS marking by the FAA.

31
4. Reasons Why An Exemption From The Requirements Of Sections

Section 61.23(a) Would Not Adversely Affect Safety.

In Exemption No. 11213 to Aeryon Labs, Inc., the FAA “finds that, because of the

risk mitigations established in the conditions and limitations of this exemption, a person

that holds a U.S. issued driver’s license who is operating a UAS will not adversely affect

safety. The FAA is granting relief from § 61.23(a) to allow any pilot that holds one of the

pilot’s certificates discussed above to operate a UAS under this exemption with a U.S.

issued driver’s license, in lieu of an FAA­issued medical certificate. The FAA is also

granting relief from § 61.23(c) to allow sport pilot certificate holders to operate aircraft

other than LSA with a U.S. issued driver’s license under this exemption.”

5. Reasons Why An Exemption From The Requirements Of Sections

61.101(e)(4) & (e)(5), 61.113(a), and 61.315(a) Would Not Adversely Affect

Safety.

Applied Art & Technology, LLC submits that an equivalent level of safety

established by Sections 61.101(e)(4) & (e)(5), 61.113(a), and 61.315(a) will be

maintained because no PIC will be allowed to operate the Inspire 1 UAS unless that PIC

has demonstrated, by meeting minimum flight­hour and currency requirements, that the

PIC is able to safely operate the Inspire 1 UAS in a manner consistent with the

exemption, including evasive and emergency maneuvers and maintaining appropriate

distances from people, vessels, vehicles, and structures.

Considering Applied Art & Technology, LLC’s proposed area of operations, and

the operating limitations set forth above; the parallel nature of sport pilot, recreational

pilot, and private pilot aeronautical knowledge requirements, with respect to the

proposed operations, to those of commercial pilot requirements (See Exemption Nos.

11062 and 11213); and the airmanship skills necessary to safely operate the Inspire 1

UAS, Applied Art & Technology, LLC submits that the additional manned airmanship

32
experience of a commercially certificated pilot would not correlate to the airmanship

skills necessary for Applied Art & Technology, LLC’s specific proposed flight operations.

The DJI Inspire 1 has been the subject of previous Grants of Exemption from

Sections 61.101(e)(4) & (e)(5) (Exemption No. 11224), Section 61.61.113(a)

(Exemption Nos. 11204 and 11224), and Section 61.315(a) (Exemption No. 11224).

The FAA has previously granted relief from Sections 61.101(e)(4) & (e)(5) and

61.315(a) specific to UAS, in circumstances similar, in all material respects, to those

presented herein (e.g. Exemption Nos. 11213, 11221, 11222, 11223, 11224, 11225,

11226, 11227, 11228, 11229, 11230, 11237, 11238, 11239, 11240, 11241).

Additionally, the FAA has previously granted relief from Section 61.113(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,

11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161, 11170, 11171,

11172, 11174, 11176, 11177, 11178, 11184, 11185, 11188, 11189, 11191, 11192,

11193, 11194, 11195, 11204, 11206, 11208, 11209, 11213, 11215, 11216, 11217,

11218, 11220, 11221, 11222, 11223, 11224, 11225, 11226, 11227, 11228, 11229,

11230, 11237, 11238, 11239, 11240, 11241).

Applied Art & Technology, LLC will not allow any PIC to operate the Inspire 1

UAS unless that PIC has demonstrated, by meeting minimum flight­hour requirements

or the Inspire 1 UAS training and currency requirements, that the PIC is able to safely

operate the Inspire 1 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 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).

33
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 Applied Art & Technology, LLC’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 multi­rotor 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 multi­rotor 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 flight­hour

requirements in Exemption No. 11062 are appropriate to practice and build

proficiency in the skills necessary to safely conduct Applied Art & Technology,

LLC’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 experience­building 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, Applied Art & Technology, LLC will ensure safe operations by not

allowing any PIC to operate the Inspire 1 UAS unless that PIC has demonstrated, by

meeting minimum flight­hour and currency requirements, that the PIC is able to safely

operate the Inspire 1 UAS in a manner consistent with the exemption, including evasive

34
and emergency maneuvers and maintaining appropriate distances from people,

vessels, vehicles and structures.

35
6. 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, Applied Art & Technology, LLC will ensure that the DJI

Inspire 1 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).

7. Reasons Why An Exemption From The Requirements Of Section 91.103

Would Not Adversely Affect Safety.

An equivalent level of safety will be provided by following the Aircraft Operations

Manual comprehensive preflight checklist. The PIC will take all actions, including

reviewing weather, flight battery requirements, landing and takeoff distances, and

aircraft performance data, before initiation of flight.

8. Reasons Why An Exemption From The Requirements Of Section

91.109(a).Would Not Adversely Affect Safety.

Given the size and speed of the sUAS, an equivalent level of safe training can

still be performed without dual controls because no pilot or passengers are aboard the

sUAS, and all persons will be a safe distance away should the sUAS experience any

difficulties during flight instruction.

9. Reasons Why An Exemption From The Requirements Of Section

91.119(c) Would Not Adversely Affect Safety.

36
The equivalent level of safety established by Section 91.119(c) will be maintained

because in any operation to be conducted closer than 500 feet from any

nonparticipating persons, barriers or structures will be present to sufficiently protect any

nonparticipating persons from debris in the event of an accident during operation of the

Inspire 1 UA, which weighs less than eight (8) pounds and will be operated below an

altitude of 400 feet AGL. The nonparticipating persons will be required to remain in the

area of protection, and if any nonparticipating person leaves the area of protection and

is within 500 feet of the Inspire 1 UA, flight operations will cease immediately.

Additionally, any operation to be conducted closer than 500 feet from persons,

vessels, vehicles, and structures would first require the permission of the land

owner/controller and a safety assessment of the risk of operating closer to those objects

by the PIC.

The Inspire 1 has been the subject of a previous Grants of Exemption from

Section 91.119(c) (Exemption Nos. 11204 and 11224). Additionally, the FAA has

previously granted relief from Section 91.119(c) 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, 11111, 11112, 11114,

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161, 11166,

11167, 11170, 11171, 11172, 11174, 11176, 11177, 11178, 11184, 11185, 11188,

11189, 11191, 11192, 11193, 11194, 11195, 11204, 11206, 11208, 11209, 11213,

11215, 11216, 11217, 11218, 11220, 11221, 11222, 11223, 11224, 11225, 11226,

11227, 11228, 11229, 11230, 11237, 11238, 11239, 11240, 11241).

10. 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 Inspire 1 UA 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

37
information, combined with Applied Art & Technology, LLC’s operation of the DJI Inspire

1 UA within visual 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 generated by GPS

equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation

point is automatically established by the UAS at ground level.

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).

11. 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

Inspire 1 UAS; (2) the limitations on the proposed flight operations; and (3) the location

of the proposed flight operations. Accordingly, Applied Art & Technology, LLC will

ensure that it will safely operate the battery powered DJI Inspire 1 UA during daylight

hours in VFR conditions, with enough battery power to fly for a total duration of 13.5

minutes to the first point of intended landing and, assuming normal cruising speed, to fly

after that for at least 4.5 minutes.

Here, as in Exemption No. 11109, the technical specifications of the DJI Inspire 1

UAS; the limitations on the proposed flight operations; and the location of the proposed

operations, will ensure an equivalent level of safety established by 14 C.F.R. Section

91.151(b). Furthermore, safety will be ensured as the DJI Inspire 1 UAS provide audible

and visual warnings to the PIC at the GCS when the UAs 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 Inspire 1 UAS will descend and land automatically.

38
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).

12. 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, Applied Art & Technology, LLC submits that the

equivalent level of safety with regard to the regulatory maintenance and alteration

requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2),

and 91.417(a) &(b) will be met because Applied Art & Technology, LLC will use trained

technicians to perform maintenance, alterations, or preventive maintenance on the

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

documents (i.e., the Applied Art & Technology, LLC Aerial Operations Manual, Monthly

Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, Applied Art &

Technology, LLC will document and maintain all maintenance records for the DJI Inspire

1 UAS.

Since the DJI Inspire 1 UAS will be inspected as prescribed by the operating

documents, Applied Art & Technology, LLC will maintain the equivalent level of safety

established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). The DJI Inspire 1

User Manual can be downloaded from the DJI website at this link:

http://www.dji.com/product/inspire­1/download.; a copy of the DJI Inspire 1 UAS Monthly

Maintenance LOG can be found in APPENDIX ­ C.

39
Likewise, the exemption sought will not adversely affect safety because Applied

Art & Technology, LLC 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 Inspire 1 UAS 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 Applied Art & Technology, LLC’s proposed operating

limitations, the operating documents, and the technical aspects of the DJI Inspire 1

UAS, Applied Art & Technology, LLC 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).

13. 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, Applied Art &

Technology, LLC requests that the FAA prescribe special conditions for the intended

operation of the DJI Inspire 1 UAS, which contain such safety standards that the

Administrator finds necessary to establish a level of safety equivalent to that established

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

40
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 UAs 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 Inspire 1 UAS, since the airworthiness

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

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

entitled 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, he prescribes special conditions and amendments thereto for

the product. The special conditions are issued in accordance with Part 11 of this

chapter and contain such safety standards for the aircraft, aircraft engine or

propeller as the 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 Applied Art & Technology, LLC’s intended

operation of the DJI Inspire 1 UAS, which contain such safety standards that the

Administrator finds necessary to establish a level of safety equivalent to that established

by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R 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).

41
F. A Summary That Can Be Published In The Federal Register, stating: The Rules

From Which Applied Art & Technology, LLC Seeks Exemption:

Applied Art & Technology, LLC seeks exemption from the requirements of 14 C.F.R

Part 21, subpart H, Part 27, 45.23(b), 45.27(a), 61.23(a) and (c), 61.101(e)(4)

and (5), 61.113(a) & (b), 61.113(a) & (b), 61.315(a), 91.7(a), 91.9(b), 91.119(c),

91.121, 91.151(b), 91.203(a) and (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 Applied Art &

Technology, LLC Seeks:

This exemption will permit Applied Art & Technology, LLC 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

Applied Art & Technology, LLC’s 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, Applied Art & Technology, LLC’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 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, Applied Art & Technology, LLC will operate the DJI

Inspire 1 UAS 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

42
As set forth herein, Applied Art & Technology, LLC seeks an exemption pursuant

to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012

(FMRA), which will permit safe operation of the DJI Inspire 1 UAS commercially, without

an airworthiness certificate, for the limited purpose of conducting aerial video and

photography over certain areas of the United States. By granting this Petition, the FAA

Administrator will be fulfilling the Congressional mandate of the FAA Modernization and

Reform Act of 2012, while also advancing the interests of the public, by allowing Applied

Art & Technology, LLC to safely, efficiently, and economically operate the DJI Inspire 1

UAS commercially within the NAS.

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

Modernization and Reform Act of 2012, Section 333, Applied Art & Technology, LLC

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

requirements of 14 C.F.R Part 21, subpart H, Part 27, 45.23(b), 45.27(a), 61.23(a) and

(c), 61.101(e)(4) and (5), 61.113(a) & (b), 61.113(a) & (b), 61.315(a), 91.7(a), 91.9(b),

91.119(c), 91.121, 91.151(b), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(1) &

(a)(2), and 91.417(a) & (b), and permit Applied Art & Technology, LLC to operate the

DJI Inspire 1 UAS commercially for the purpose of conducting aerial video and

photography over certain areas of the United States.

Dated: July 7th, 2015

Respectfully submitted,

George Christ

43
Applied Art & Technology, LLC

2430 106th Street

Urbandale, IA 50322

(515) 331­7400

gchrist@appliedart.com

Appendices:

A. DJI Inspire 1 Specifications Data

B. DJI Inspire 1 Manufacturer’s User Manual

C. Monthly Maintenance Log

APPENDIX – A

DJI INSPIRE 1 PROFESSIONAL TECHNICAL SPECIFICATIONS

Applied Art & Technology, LLC only utilizes safe and reliable UASs. DJI is an industry

leader in small UAS production. DJI 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 real­time altitude and location information to the PIC via the linked

monitor (smart phone/tablet devices

Aircraft

Model:

T600

Weight (Battery Included):

2935 g

Hovering Accuracy (GPS Mode):

Vertical: 0.5 m

Horizontal: 2.5 m

44
Max Angular Velocity:

Pitch: 300°/s

Yaw: 150°/s

Max Tilt Angle:

35°

Max Ascent Speed:

5 m/s

Max Descent Speed:

4 m/s

Max Speed:

22 m/s (ATTI mode, no wind)

Max Flight Altitude:

4500 m

Max Wind Speed Resistance:

10 m/s

Max Flight Time:

Approximately 18 minutes

Motor Model:

DJI 3510

Propeller Model:

DJI 1345

Indoor Hovering:

Enabled by default

Operating Temperature Range:

­10° to 40° C

Diagonal Distance:

559 to 581 mm

Dimensions:

438x451x301 mm

45
Gimbal

Model:

ZENMUSE X3

Output Power (With Camera)

Static: 9 W

In Motion: 11 W

Operating Current:

Station: 750 mA

Motion: 900 mA

Angular Vibration Range:

±0.03°

Mounting:

Detachable

Controllable Range:

Pitch: ­90° to +30°

Pan: ±320°

Mechanical Range:

Pitch: ­125° to +45°

Pan: ±330°

Max Controllable Speed

Pitch: 120°/s

Pan: 180°/s

Camera

Name:

X3

Model:

FC350

Total Pixels:

12.76M

Effective Pixels:

12.4M

46
Image Max Size:

4000x3000

ISO Range:

100­3200 (video) 100­1600 (photo)

Electronic Shutter Speed:

8s ­ 1/8000s

FOV (Field Of View):

94°

CMOS:

Sony EXMOR 1/2.3”

Lens:

20mm (35mm format equivalent)f/2.8 focus at ∞ 9 Elements in 9 groups

Anti­distortion

Still Photography Modes:

Single shoot

Burst shooting: 3/5/7 frames

Auto Exposure Bracketing (AEB):

3/5 bracketed frames at 0.7EV Bias Time­lapse

Video Recording Modes:

UHD (4K): 4096x2160p24/25, 3840x2160p24/25/30

FHD: 1920x1080p24/25/30/48/50/60

HD: 1280x720p24/25/30/48/50/60

Max Bitrate Of Video Storage:

60 Mbps

Supported File Formats:

FAT32/exFAT

Photo: JPEG, DNG

Video: MP4/MOV (MPEG­4 AVC/H.264)

Supported SD Card Types:

Micro SD. Max capacity: 64 GB. Class 10 or UHS­1 rating required.

Operating Temperature Range

0° to 40° C

47
Remote Controller

Name:

C1

Operating Frequency:

922.7~927.7 MHz (Japan Only)

5.725~5.825 GHz

2.400~2.483 GHz

Transmitting Distance (Outdoor And Unobstructed):

2 km

EIRP:

10dBm@900m, 13dBm@5.8G, 20dBm@2.4G

Video Output Port:

USB, mini­HDMI

Power Supply:

Built­in battery

Charging:

DJI charger

Dual User Capability:

Host­and­Slave connection

Mobile Device Holder:

Tablet or Phone

Max Mobile Device Width:

170mm

Output Power:

9W

Operating Temperature Range:

­10° to 40° C

Storage Temperature Range:

48
Less than 3 months: ­20° to 45° C

More than 3 months: 22° to 28° C

Charging Temperature Range 0­40° C

Battery:

6000 mAh LiPo 2S

Charger

Model

A14­100P1A

Voltage

26.3 V

Rated Power

100 W

Battery (Standard)

Name:

Intelligent Flight Battery

Model:

TB47

Capacity:

4500 mAh

Voltage:

22.2 V

Battery Type:

LiPo 6S High voltage battery

Energy:

99.9 Wh

Net Weight:

570 g

49
Operating Temperature Range:

­10° to 40° C

Storage Temperature Range:

Less than 3 months: ­20° to 45° C More than 3 months: 22° C to 28° C Charging Temperature Range

0° to 40° C

Max Charging Power:

180 W

Battery (Optional)

Name:

Intelligent Flight Battery

Model:

TB48

Capacity:

5700 mAh

Voltage:

22.8 V

Battery Type:

LiPo 6S

Energy:

129.96 Wh

Net Weight:

670 g

Operating Temperature Range:

­10° to 40° C

Storage Temperature Range:

Less than 3 months: ­20 to 45° C More than 3 months: 22° to 28° C Charging Temperature Range

0° to 40° C

Max Charging Power:

180 W

50
Vision Positioning

Velocity Range:

Below 8 m/s (2 m above ground)

Altitude Range:

5­500 cm

Operating Environment:

Brightly lit (lux > 15) patterned surfaces

Operating Range:

0­250 cm

DJI Pilot App

Mobile Device System Requirements:

iOS 8.0 or later

Android 4.1.2 or later

Supported Mobile Devices:

Compatible with iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air Wi­Fi + Cellular, iPad mini 2, iPad

mini 2 Wi­Fi + Cellular, iPad Air 2, iPad Air 2 Wi­Fi + Cellular, iPad mini 3, and iPad mini 3 Wi­Fi + Cellular.

This app is optimized for iPhone 5s, iPhone 6, and iPhone 6 Plus.

Compatible with Samsung S5, Note 3, Sony Xperia Z3, Google Nexus 7 II, Google Nexus 9, Mi 3, Nubia Z7

mini. (Note: Support for additional devices available as testing and development continues.)

51
APPENDIX – B

Monthly Maintenance Log

UAS#____ Date Issue Maintenance

Performed

Initials

Firmware

Check

Frame

Engines

Propellers

Camera

Gimbal

Landing

Gear

Vibration

Other:

52