UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: Raid Zeidan 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 OPERAT ION OF DJI PHANTOM 3 PROFESSIONAL UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)

Submitted on May 5 th

, 2015

Raid F Zeidan

575 Whitefield Lane Bossier City, LA 71112 318

- 469

- 44622 TABLE OF CONTENTS

Page

GLOSSARY OF ABBREVIATIONS...................................................................................3

SUMMARY...................................................................................................................... .....4

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

BACKGROUND............ ........................................................................................................4

BASIS FOR PETITION.........................................................................................................5

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

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH RAID F. ZEIDAN SEEKS EXEMPTION........................................................................8

THE EXTENT OF RELIEF RAID F. ZEIDAN AND THE REASON RAID F. ZEIDAN SEEKS THE RELIEF................................................................11 THE REASONS WHY GRANTING RAID F. ZEIDAN’S REQUEST WOULD BE IN THE PUBLIC INTEREST .........................................................1 5

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY..........................................................................19

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

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT RAID F. ZEIDAN’S REQUEST...............................................................................................................34

CONCLUSION................................................................................................................... .35

APPENDICES........................................................................................37 GLOSSARY OF ABBREVIATIONS AGL Above Ground Level
AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization3

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 Landing4 SUMMARY
Raid F. Zeidan seeks exemption from the requirements of 14 C.F.R §§ 61.113(a)

& (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and

91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the

FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Raid F.

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

conducting aerial video and photography for wedding videography, real estate

photography, special events, film sets, and landscape over certain areas of the United

States.

INTRODUCTION AND INTERESTS OF TH E PETITIONER
Raid F. Zeidan provides its clients with expertise and knowledge in advanced technologies and solutions to increase efficiency, productivity and effectiveness. I also provides its clients with the highest quality digital content for use in th eir commercial, personal, and non

- profit multimedia projects. Raid F. Zeidan has over 3 years of professional experience in wedding and special event videography and photography and is recognized as an expert this field. Raid F. Zeidan has over 2 year s of recreational/hobby experience in all aspects of aerial video and photography. My objective is to provide safe high quality imaging for a variety of wedding, commercial, public, and residential uses, specifically targeting:

 Wedding Videography and Photogra phy

 Motion Picture Filming

 Special Event Filming

 Real Estate Photography

 Increase public knowledge of UAS and promote safe UAS operations.5 BACKGROUND
Unmanned Aircraft Systems: DJI Phantom 3 Professional Raid F. Zeidan seeks an exemption to operate DJI systems for compensation or hire

within the NAS. The DJI Phantom 3 Professional is a vertical takeoff and landing (VTOL)

Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet

or smart phone systems. The DJI Phantom 3 Pr ofessional has a maximum gross weight of

approximately 2 pounds 11 ounces, while having a length of 16 inches width of 16 inches,

height of 8 inches, and a maximum speed of approximately 29 knots. The DJI Phantom 3

Professional is equipped with four main rotors; driven by Lithium Polymer battery

powered electric motors.

The DJI Phantom 3 Professional UAS that will be operated by Raid F. Zeidan will

be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft , as well as 14

C. F.R Part 47, Aircraft Registration , and marked in accordance with 14 C.F.R. Part 45,

Identification and Registration Marking

.
BASIS FOR PETITION
Petitioner, Raid F. Zeidan, 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 Phantom 3 Professional UAS

in the

National Airspace System ( NAS), and for an exemption from the requirements of 14 C.F.R

§§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) &
(a)(2), and 91.417(a) & (b).
In consideration of the speed, weight, size, and limited operating area ass ociated

with the unmanned aircraft and its operation, Raid F. Zeidan’s operation of DJI Phantom 36

Professional UAS meets the conditions of FMRA Section 333 and therefore, will not

require an airworthiness certificate in accordance with 14 C.F.R. Part 21, S ubpart H.

Accordingly, Raid F. Zeidan requests relief from Sections 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for

maintenance that only apply to aircraft with an airworthiness certificate.

Raid F. Zeidan submits that the requested relief is proper since an equivalent level

of safety will be ensured. Raid F. Zeidan w ill use experienced personnel or technicians to

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

methods, techniques, and practices prescribed in the operating documents (i.e., Monthly

Maintenance Log, and DJI Phantom 3 Pro fessional Instruction Manual). Furthermore Raid F. Zeidan will document and maintain all maintenance records for the DJI Phantom 3 Professional UAS.

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

privileges and limi tations: Pilot in command , is requested by Raid F. Zeidan to the extent

necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level

certificate, as well as an airman medical certificate, and who has demonstrated, by meeting

minimum flight

- hour and currency requirements, that the PIC is able to safely operate the

DJI Phantom 3 Professional UAS in a manner consistent with this exemption, including

evasive and emergency maneuvers and maintaining appropriate distances from people,

vesse ls, vehicles and structures.

Raid F. Zeidan seeks relief from Section 91.7(a), entitled Civil aircraft

airworthiness , because the DJI Phantom 3 Professional UAS does not require an

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

Zeidan submits that he will ensure that the DJI Phantom 3 Professional UAS is in an

airworthy condition, prior to every flight, by determining that the UAS is in compliance7

with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3

Professional

Instruction Manual), and that the aircraft is in a condition for safe flight.
Raid F. Zeidan also seeks an exemption from the requirements of Section 91.121,

entitled Altimeter Settings , as the DJI Phantom 3 Professional UAS will not have a typical

barometric altimeter onboard. However, altitude information of the DJI Phantom 3

Professional UAS will be provided to the PIC via Global Positioning System (GPS)

equipment and radio communications telemetry data link, which downlink s from the UA to

the GCS for active monitoring of the flight path. This altitude information, combined with

Raid F. Zeidan’s operation of the DJI Phantom 3 Professional UAS within visual line of

sight, at or below 400 feet AGL, will ensure a level of safet y equivalent to Section 91.121.

Additionally, Raid F. Zeidan seeks an exemption from the requirements of

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

. Raid F. Zeidan submits that safety will not be affected by operation of the DJI Phantom 3 Professional UAS during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration of approxima tely 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.

In accordance with 14 C.F.R. § 11.81, Raid F. Zeidan provides the following

information in support of its petition f or exemption: A. Name and Address of the

Petitioner.

The name and address of the Petitioner and point of contact is: Raid F. Zeidan 575 Whitefield Lane Bossier City, LA 71112 Raidzeidan@gmail.com 3184694462 B. The Specific Sections Of 14 C.F.R. From Which Raid F. Zeidan Seeks Exemption.
1. Raid F. Zeidan Seeks Exemption from The Requirements Of Section 61.113(a) And (b).8 Section 61.113, entitled Private pilot privileges and limitations: Pilot in command

, subsections (a) and (b) prescribe the following, in relevant part:
(a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, f or 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 aircr aft does not carry passengers or property for compensation or hire.

2. Raid F. Zeidan Seeks Exemption from The Requirements Of Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness , subsection (a), states the
following:
(a) No person may operate a civil aircraft unless it is in an airworthy condition.

3. Raid F. Zeidan Seeks Exemption From The Requirements Of Section 91.121.

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

part:
(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

-- (1) Below 18,000 feet MSL, to

-- (i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure.

4. Raid F. Zeidan Seeks Exemption From The Requirements Of Section 91.151(b).9 Section 91.151, entitled Fuel requirements for flight in VFR conditions , subsection

(b), states the following:

(b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.

5. Raid F. Zeidan 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

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

6. Raid F. Zeidan 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 und er § 43.7 of this chapter [.]

7. Raid F. Zeidan Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2).

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

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

--

(1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.10 8. Raid F. Zeidan Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b).

Section 91.417, entitled Maintenance records , subsections (a) and (b), state the
following:
(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include

-- (i) A description (or reference to data acceptabl e to the Administrator) of the work performed; and

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

(iii) The signature, and certificate number of the person approving the aircraft for return to service.

(2) Records containing the following information: (i) The total time in service of the airframe, each engine, each propeller, and each rotor.

(ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection prog ram 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 th e 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, propell ers, and appliances.11 (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 a fter 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

t his chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.

C. The Extent Of Relief Raid F. Zeidan Seeks And The Reason Raid F. Zeidan Seeks The Relief.

1. Extent Of Relief Raid F. Zeidan Seeks And T he Reason Raid F. Zeidan Seeks Relief From Section 61.113(a) And (b).

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

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

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

certificate, and who has met certain flight

- hour and currency requirements, to conduct the

proposed UAS flight operations for compensation or hire.

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

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

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

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

compensation or hire.

As set forth more fully below, Raid F. Zeidan submits that an equivalent level of

safety will be maintained because no PIC will be allowed to operate the DJI Phantom 3

Professional UAS unless that PIC has met certain flight

- hour and currency requirements,

demonstrating that the PIC is able to safely operate the DJI Phantom 3 Professional UAS in12

a manner consistent with the operations specifications as described in this exemption,

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

from people, vessels, vehicles and structures.

Further, Raid F. Zeidan submits that all flights of the DJI Phantom 3 Professional

UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to

Raid F. Zeidan busines s; and (2) will not carry passengers or property for compensation

or hire.

2. Extent Of Relief Raid F. Zeidan Seeks And The Reason Raid F. Zeidan

Seeks Relief From Section 91.7(a).

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

extent required to allow Raid F. Zeidan to determine that the DJI Phantom 3 Professional

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

compliance with the operating documents (i.e., Monthly Maintenance L og, and DJI

Phantom 3 Professional Instruction Manual).

Raid F. Zeidan seeks the requested relief because the DJI Phantom 3 Professional

UAS does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21,

Subpart H. Therefore, Raid F . Zeidan will ensure that the DJI Phantom 3 Professional UAS

is in airworthy condition based upon its compliance with the operating documents (i.e.,

Monthly Maintenance Log, and DJI Phantom 3 Professional Instruction Manual) prior to

every flight, and furt her, determine that the aircraft is in condition for safe flight, as stated

in the conditions and limitations below.

3. Extent Of Relief Raid F. Zeidan Seeks And The Reason Raid F. Zeidan Seeks Relief From Section 91.121.

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

flight operations of the DJI Phantom 3 Professional UAS , which utilize a barometric13

pressure sensor, GPS equipment, and a radio communications telemetry data link to

downlink altitude information from the U A to the PIC at the ground control station (GCS).

Since the FAA requires that any altitude information concerning UAS operations be

reported to air traffic control (ATC) in feet above ground level (AGL), Raid F. Zeidan

seeks the requested relief because th e DJI Phantom 3 Professional UAS 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 wi ll

be maintained since the DJI Phantom 3 Professional UAS 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 heads

- up display of the GCS.

4. Extent Of Relief Raid F. Zeidan Seeks And The Reason Raid F. Zeidan Seeks Relief From Section 91.151(b).

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

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

Phantom 3 Professional 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. Raid F. Zeidan seeks the requested relief because without an exemption from14

Section 91.151(b), the flight time duration of the battery powere d DJI Phantom 3

Professional UAS will severely constrain the practicality of any aerial video or still photo

flight operations that Raid F. Zeidan proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specificati ons of the DJI Phantom 3

Professional UAS , the DJI Phantom 3 Professional operating documents, and Raid F.

Zeidan’s proposed operating limitations, ensure that Raid F. Zeidan will safely operate the

battery powered DJI Phantom 3 Professional UAS during day light hours in visual

meteorological conditions (VMC), under visual flight rules (VFR), 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.

5. Extent Of Relief Raid F. Zeidan Seeks And The Reason Raid F. Zeidan 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), an d 91.417(a) & (b)

only apply to aircraft with an airworthiness certificate, Raid F. Zeidan requests relief from

these Sections because the DJI Phantom 3 Professional UAS does not require airworthiness

certificates. As set forth more fully below, the DJI Phantom 3 Professional UAS meets the

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

Accordingly, Raid F. Zeidan 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., Monthly Maintenance Log, and

DJI Phantom 3 Professional ). Furthermore, Raid F. Zeidan will document and maintain all

maintenance records for the DJI Phantom 3 Professi onal UAS

.

D. The Reasons Why Granting Raid F. Zeidan’s Request Would Be In The Public Interest; That Is, How It Would Benefit The Public As A Whole.15 Granting the present Petition will further the public interest by allowing Raid F. Zeidan too safely, efficiently, and economically perform aerial video and photography for wedding films, real estate, special events, film sets, and landscape over certain areas of the United States.

Additionally, use of the DJI Phantom 3 Professional UAS will decrease cong estion

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

benefits of Raid F. Zeidan’s proposed operation of the DJI Phantom 3 Professional UAS

will be realized without implicating any privacy issues.

1. The Public W ill Benefit From Decreased Congestion Of The NAS.

The DJI Phantom 3 Professional UAS is battery powered and serves as a safe,

efficient, and economical alternative to the manned aircraft traditionally utilized to obtain

aerial imagery. By reducing the am ount of manned aircraft needed to perform aerial

acquisitions, an exemption allowing the use of a DJI Phantom 3 Professional UAS would

reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as

increase the safety of life a nd 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 Phantom 3 Professional UAS does not requi re 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 landi ng phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 3 Professional UAS

.
Conducting aerial acquisitions with the DJI Phantom 3 Professional UAS , instead

of manned aircraft, will greatly benefit the public by drastically reducing the levels of air16

and noise pollution generated during traditional aerial video and still photography flight

operations. By using battery power and electric motors, the DJI Phantom 3 Professional

UAS produces no air pollution , and is the most viable environmentally conscious

alternative to the cabin class, six cylinder internal combustion engine aircraft that are

typically utilized for aerial video and photography, while burning approximately 20

- 30

gallons per hour of leaded a viation fuel. The DJI Phantom 3 Professional 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 usin g the DJI Phantom 3 Professional 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 access methods, will be substantially reduced or completely eliminated

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

3 Professional UAS (weighing approximately 2 pounds 11 ounces, at its maximum gross

weight with a length of 16 inches, widths of 16 inches, and with no fuel on boar d), 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 fee t, a length of 34 feet,

and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations With The DJI Phantom 3 Professional UAS Will Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 3 Professional UAS is also

an economical alternative to using manned aircraft to conduct similar aerial operations. As17

such, operation of the DJI Phantom 3 Professional UAS will allow United States based

companies, like Raid F. Zeidan’s, to remain competitive and contrib ute 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 Phantom 3 Professional UAS s is

one such technology that not only allows companies greater operational flexibility

compared to manned aircraft, but provides such flexibility withou t the high operational

cost of a traditional manned aircraft.

By operating the DJI Phantom 3 Professional UAS , companies such as Raid F.

Zeidan’s, can remain competitive and profitable, and therefore, provide greater job stability

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

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

the DJI Phantom 3 Professional UAS , provides a stable workforce that increases consumer

spending; improves lo cal, state, and federal tax revenues; and allows companies to invest

in research and development in order to remain competitive both in the United States and

abroad.

4. There Are No Privacy Issues.
Similar to the manned aerial acquisition flight operations that have been conducted for

decades, Raid F. Zeidan’s proposed operation of the DJI Phantom 3 Professional UAS will

not implicate any privacy issues. Specifically, the DJI Phantom 3 Professional U AS will be

operated only in compliance with operating documents (i.e., Monthly Maintenance Log,

and DJI Phantom 3 Professional ) which requires property owner involvement as well as18

local law enforcement notification, and in accordance with the Federal Avia tion

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 Rul e From Which Raid F. Zeidan Seeks Exemption.

1. Reasons Why The DJI Phantom 3 Professional UAS Meets The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333.

In consideration of the size, weight, speed, and limited operati ng area associated

with the unmanned aircraft and its operation, Raid F. Zeidan’s operation of the DJI

Phantom 3 Professional 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 nationa l 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 dete rmine 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 Air craft 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 airspac e 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 States19 Code, is required for the operation of unmann ed 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 esta blish requirements for the safe operation of such aircraft systems in the national airspace system.

In seeking this exemption, Raid F. Zeidan submits that the DJI Phantom 3

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

demonstrated by: (a) the characteristics of the DJI Phantom 3 Professional UAS ; (b) the

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

a. The Specifications Of The DJI Phantom 3 Professional UAS Demonstrate Its Safe Charact eristics.

The DJI Phantom 3 Professional 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 Phantom 3 Professional UAS

.
The technical specification of the DJI Phantom 3 Professional UAS is set forth by the

DJI Phantom 3 Professional Specifications and Data Sheet, attached hereto as Exhibit A.

ii. The DJI Phantom 3 Professional UAS Autonomous Flight And Navigation Modes Enable The UAS To Remain Within A Defined Operational Area.

The DJI Phantom 3 Professional UAS may be operated in both manual and fully

autonomous flight modes. A complete description of the flight and navigation al modes of

the DJI Phantom 3 Professional UAS is provided at pages 25

- 35 of the DJI Phantom 3

Professional and pages 12

- 16 User Manual, attached hereto as Exhibit B .

iii. The DJI Phantom 3 Professional UAS is Designed For Automatic Return To Home Point Or H over In The Event Of Loss Of The Control Link Or Navigation.20 When the Control Link is lost, the DJI Phantom 3 Professional UAS will remain

stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 3

Professional UAS does not re acquire control link data from the GCS, the UAs will assume

that the Control Link is lost and the UAs will return to the home position (i.e., failsafe

mode) via GPS, and will descend to the takeoff position and shutdown.

A complete description of the Fai lsafe Functions of the DJI Phantom 3 Professional

UAS are set forth at pages 27 through 29 of the DJI Phantom 3 Professional User Manual,

attached hereto as Exhibit B.

iv. The DJI Phantom 3 Professional GCS And Its Operation.

A complete description of the operation and specifications of the DJI Phantom 3

Professional GCS and flight control software is provided at pages 32 through 43 of the DJI

Phantom 3 Professional User Manual. DJI Phantom 3 Professional User Manual is

attac hed hereto as Exhibits B.

b. Flight Operations Of DJI Phantom 3 Professional UAS is Limited To The Line Of Sight Of A Pilot in Command With A Safety Observer.

Raid F. Zeidan will only utilize pilots who possess a current and valid medical

certificate to act as a pilot in command (PIC) of the DJI Phantom 3 Professional UAS

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

c. Flights Of DJI Phantom 3 Professional UAS Will Be Conducted Pursuant To Specific Operating Limitations.

In seeking this exemption, Raid F. Zeidan proposes to commercially operate DJI

Phantom 3 Professional UAS for the special purpose of conducting aerial video and

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

operating limitations:

1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UAS weighing less than 55 pounds maximum gross weight: DJI Phantom 321 Professional Unmanned Aircraft Systems. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant.

2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photography.

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

4. The UA must be operated at an altitude of no more th an 400 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved by ATC. All altitudes reported to ATC must be in feet AGL.

5. The UA must be operated within visual lin e 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.

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

7. All operatio ns must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permitt ed 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 docu ments, 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 docum ents. 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 gr ant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted22 the exemption, then the operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the

sa fe 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 ma intenance and alterations must be properly documented in the aircraft records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraft records.

12. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents.

13. The operator must follow the UAS manufacturer’s aircraft/c omponent, 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, alter ations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature of the authorized person returning the UAS to service.

15. Each UAS opera ted under this exemption must comply with all manufacturer Safety Bulletins.

16. The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections.

17. The PIC must possess a t least a current medical certificate.

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be oper ated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC23 qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flight s for the purposes of training the operator’s PICs are permitted under the terms of the exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

- building flights, all per sons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119.

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized.

20. The UA may not operate within 5 nautical miles of an airport reference point as denoted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request.

21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cl oud 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 pre

determined location within the planned operating area and land or be recovered in accordance with the ope rating 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 m ust 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 accordance24 with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requirements.

26. A ll 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 la rge as practicable.

27. Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made available to the Administrator or any law enforcement official upon re quest.

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 sufficie ntly 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 mad e 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 person s per § 91.119(a).25 32. All operations shall be conducted over private or controlled

- access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obta ined for each flight to be conducted.

33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS

- 80 ) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

.
2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety.

Raid F. Zeidan submits that the equivalent level of safety established by Section

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

Phantom 3 Professional UAS unless that PIC has demonstrated, by meeting minimum

flight hour and currency requirements, that the PIC is able to safely operate the DJI

Phantom 3 Professional UAS in a manner consistent with the exemption, including evasive

and emergency maneuvers and maintaining appropriate distances from people, vessels,

vehicles and structures.

Considering Raid F. Zeidan’s proposed area of operations, and the operating

limitations set forth

- above; the parallel nature of private pilot aeronautical knowledge

requirements to those of commercial pilot requirements (See Exemption No. 11062); and

the airmanship skills necessary t o safely operate the DJI Phantom 3 Professional UAS

, Raid F. Zeidan submits that the additional manned airmanship experience of a

commercially certificated pilot would not correlate to the airmanship skills necessary for

Raid F. Zeidan’s specific proposed flight operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to26

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).

Raid F. Zeidan will not allow any PIC to operate the DJI Phantom 3 Professional

UAS unless that PIC has demonstrated, by meeting minimum flight

- hour requirements or

the DJI Phantom 3 Professional UAS training and currency requirements, that the PIC is

able to safely operate the DJI Phantom 3 Professional UAS in a manner consistent with this

exemption, including evasive and emergency maneuvers and maintaining appropriate

d istances from people, vessels, vehicles and structures.

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

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

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

UAS to be used for operations under the exemption). In addition to the hour requirements,

the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency

purposes).

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight

experience that was obtained in compliance with applicable regulations will ensure an

equivalent level of safety during Raid F. Zeidan’s proposed operations. The Administrator

has held that prior docum ented flight experience that was obtained in compliance with

applicable regulations would ensure safe operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming ( or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi

- rotor UAS. Prior to operations un der 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 the27 exemption. For clarification, the FAA considers these minimum hour requi rements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi

- rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight

- hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary to safe ly conduct the petitioner’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience

- building flights c an also be conducted under the grant of exemption to accomplish the required flight time. During training, proficiency, and experience

- building flights the PIC is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119.

Exemption No. 11138 at page 15.

Accordingly, Raid F. Zeidan will ensure safe operations by not allowing any PIC to

operate the DJI Phantom 3 Professional UAS unless that PIC has demonstrated, by meeting

minimum flight

- hour and currency requirements, tha t the PIC is able to safely operate the

DJI Phantom 3 Professional UAS in a manner consistent with the exemption, including

evasive and emergency maneuvers and maintaining appropriate distances from people,

vessels, vehicles and structures.

3. Reasons Why A n 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, Raid F. Zeidan will ensure that the DJI Phantom 3

Pr ofessional

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.28

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112,

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

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety.

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

because the altitude information of the DJI Phantom 3 Professional UAS will be provided

to the PIC via GPS equipment and a radio communications telemetry data link, which

downlinks from the UA to the GCS for active monitoring of the flight path and altitude.

This altitude information, combined with Raid F. Zeidan’s operation of the DJI Phantom 3

Professional UAS within visual line of sight, at or below 400 feet AGL, will ensure a level

of safety equivalent to Section 91.121. The altitude information will be generated by GPS

equipment installed onboard the aircraft. Prior to e ach 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).

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely Affect Sa fety.

A grant of this exemption would ensure an equivalent level of safety established by

14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJI

Phantom 3 Professional UAS ; (2) the limitations on the proposed flight oper ations; and (3)

the location of the proposed flight operations. Accordingly, Raid F. Zeidan will ensure that

it will safely operate the battery powered DJI Phantom 3 Professional UAS during daylight

hours in VFR conditions, with enough battery power to fly for a total duration of 13.529

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 Phantom 3

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

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

Section 91.151(b). Furthermore, safety will be ensured as the DJI Phantom 3 Professional

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 Phantom 3 Professional UAS will descend and land automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151

establish that safety is not adversely affected when the technical characteristics and

operating limitations of the UAS are considered. Relief has been granted for manned

aircraft to operate at less than the minimums prescribed in Section 91.151, including

Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted re lief

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, 1115 3, 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, Raid F. Zei dan 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 met30

because Raid F. Zeidan will use tr ained technicians to perform maintenance, alterations, or

preventive maintenance on the UAS using the methods, techniques, and practices

prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3

Professional Instruction Manual ). Furthermore, Raid F. Zeidan will document and maintain

all maintenance records for the DJI Phantom 3 Professional UAS

.

Since the DJI Phantom 3 Professional UAS will be inspected as prescribed by the

operating documents, Raid F. Zeidan will maintain th e equivalent level of safety

established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI

Phantom 3 Professional User Manual is attached hereto as Exhibit B; a copy of the DJI

Phantom 3 Professional UAS Maintenance LOG is attached hereto as Exhibit C.

Likewise, the exemption sought will not adversely affect safety because Raid F.

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

maintenance on the UAS using the metho ds, 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 Phantom 3 Prof

essional 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 Raid F. Zeidan’s proposed operating limitations, the operating

docum ents, and the technical aspects of the DJI Phantom 3 Professional UAS , Raid F.31

Zeidan submits that safety will not be adversely affected by granting exemption from 14

C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b).

The FAA has previously granted relief specific to UAS in circumstances similar, in all

material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064,

11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156

,
11157,

11158, 11159, 11160, 11161).

7. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Raid F. Ze idan requests that

the FAA prescribe special conditions for the intended operation of the DJI Phantom 3

Professional UAS , which contain such safety standards that the Administrator finds

necessary to establish a level of safety equivalent to that establish ed by 14 C.F.R. Part 21,

Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a),

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

permit safe operation of the 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 Adminis trator may prescribe special conditions pursuant to 14 C.F.R.

§ 21.16, for operation of the DJI Phantom 3 Professional UAS , since the airworthiness32

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

due to the novel o r 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, a ircraft 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 o f 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 Leading Edge’s intended operation of the DJI

Phantom 3 Professional UAS , which contain such safety standards that the Administrator

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

Part 21,

Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a),

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

F. A Summary That Can Be Published In The Federal Register, stating: The Rules From Which Raid F. Zeidan Seeks Exemption:

Raid F. Zeidan seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409 (a)(1) & (a)(2), and 91.417(a) & (b).

A Brief Description Of The Nature Of The Exemption Raid F. Zeidan Seeks:

This exemption will permit Raid F. Zeidan to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States.33

G. Any Additional Information, Views, Or Arguments Available To Support Raid F. Zeidan’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 determin e if certain

UAS may operate safely in the NAS. As such, Raid F. Zeidan’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 cons idering 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, Raid F. Zeidan will operate the DJI Phantom 3

Professional 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

As set forth herein, Raid F. Zeidan seeks an exem ption pursuant to 14 C.F.R. §

11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which

will permit safe operation of the DJI Phantom 3 Professional UAS commercially, without

an airworthiness certificate, for the limited purpose o f 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 int erests of the public, by allowing Raid F.

Zeidan to safely, efficiently, and economically operate the DJI Phantom 3 Professional

UAS commercially within the NAS.34 WHEREFORE , in accordance with the Federal Aviation Regulations and the FAA

Modernization and Reform Act of 2012, Section 333, Raid F. Zeidan respectfully requests

that the Administrator grant this Petition for an exemption from the requirements of 14

C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1),

91.409(a)(1 ) & (a)(2), and 91.417(a) & (b), and permit Raid F. Zeidan to operate the DJI

Phantom 3 Professional UAS commercially for the purpose of conducting aerial video and

photography over certain areas of the United States.

Dated: April 16, 2015

Respectfully submitted,

Raid F. Zeidan

_________________________ Raid F. Zeid an 575 Whitefield Lane Bossier City, LA 71112 318

- 469

- 4462

Appendices :

A

– DJI Phantom 3 Professional Specifications Data Sheet B

– DJI Phantom 3 Professional Manufacturer’s User Manual
C

– Monthly Maintenance Log

APPENDIX

– A

DJI PHANTOM 3 PROFESSIONAL TECHNICAL SPECIFICATIONS35

Raid F. Zeidan only utilizes safe and reliable UAS . DJI is an industry leader in small UAS production. DJI UAS are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJI software provides real

- time altitude and location information to the PIC via the linked monitor (s mart phone/tablet devices)

1.1 DJI Phantom 3 Professional36

Aircraft Weight (Including Battery And Propellers)

1280 g Diagonal Size (Including Propellers) 590 mm Max Ascent Speed 5 m/s Max Descent Speed 3 m/s Hover Accuracy

 Vertical: +/

- 10cm

 Horizontal: +/

- 1m Max Speed 16 m/s (ATTI mode, no wind) Max Altitude Above Sea Level 6000 m Operating Temperature 0°C to 40°C GPS Mode GPS/GLONASS37

Camera Sensor

Sony EXMOR 1/2.3” Effective pixels: 12.4 M (total pixels: 12.76 M) Lens FOV 94° 20 mm (35 mm format equivalent) f/2.8, focus at ∞ ISO Range 100

- 3200 (video) 100

- 1600 (photo) Shutter Speed 8s

- 1/8000s Image Max Size 4000 x 3000 Still Photography Modes

 Single Shot

 Burst Shooting: 3/5/7 shots

 Auto Exposure Bracketing (AEB): 3/5

 Bracketed Frames at 0.7EV Bias

 Time

- lapse Video Recording Modes

Phantom 3 Professional

 UHD: 4096x2160p 24/25, 3840x2160p 24/25/30

 FHD: 1920x1080p 24/25/30/48/50/60

 HD: 1280x720p 24/25/30/48/50/60

Phantom 3 Advanced

 FHD: 1920x1080p 24/25/30/48/50/60

 HD: 1280x720p 24/25/30/48/5 0/60 Supported SD Card Types Micro SD Max capacity: 64 GB. Class 10 or UHS

- 1 rating required Max Bitrate Of Video Storage 60 Mbps Supported File Formats

 FAT32/exFAT

 Photo: JPEG, DNG

 Video: MP4, MOV (MPEG

- 4 AVC/H.264) Operating Temperature 0°C to 40°C

Gimbal Controllable Range

Pitch

- 90° to +30° Stabilization 3

- axis (pitch, roll, yaw)38

Vision

Positioning Max Velocity

Less than 8 m/s (when 2 m above ground) Altitude Range 30 cm

- 300 cm Operating Range 30 cm

- 300 cm Operating Environment Surface with clear pattern and adequate lighting (Lux > 15)

Remote

Controller Operating Frequency

2.400 GHz

- 2.483 GHz Max Distance 2000m (outdoors and unobstructed) Video Output Port USB Operating Temperature 0°C

- 40°C Battery 6000 mAh LiPo 2S Mobile Device Holder For tablet or phone Receiver Sensitivity (1%PER)

- 101 dBm ±2 dBm Transmitter Power (EIRP)

 FCC: 20 dBm

 CE: 16 dBm Working Voltage 1.2 A @7.4 V

Battery
Charger Voltage

17.4 V Rated Power

Phantom 3 Professional

 100 W

Phantom 3 Advanced

 57 W39

Intelligent

Flight Battery Capacity

4480 mAh Voltage 15.2 V Battery Type LiPo 4S Energy 68 Wh Net Weight 365 g Max Flight Time Approximately 23 minutes Operating Temperature

- 10°C to 40°C Max Charging Power 100 W

App / Live

View Mobile App

DJI Pilot EIRP 100mW Live View Working Frequency 2.4GHz ISM Live View Quality 720P @ 30fps (depending on conditions and mobile device) Latency 220ms (depending on conditions and mobile device) Required Operating Systems

 iOS 8.0 or later

 Android 4.1.2 or later Recommended Devices

 iOS: iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air Wi

- Fi + Cellular,
iPad mini 2, iPad mini 2 Wi

- Fi + Cellular, iPad Air 2, iPad Air 2 Wi

- Fi +
Cellular, iPad mini 3, and iPad mini 3 Wi

- Fi + Cellular. This app is optimized
for iPhone 5s, iPhone 6, and iPhone 6 Plus

 Android: Samsung S5, Note 3, Sony Xperia Z3, Google Nexus 7 II, Google
Nexus 9, Mi 3, Nubia Z7 mini

 *Support for additional Android devices available as testing and development

continues

APPENDIX

– B40

DJI Phantom 3 Professional Manufacturer’s User Manual

APPENDIX

– E

MONTHLY$MAINTENANCE$LOG
month:_________(year:________ UAS$#:$___________ Date(Issue( Discovered Date(Issue( Addressed Issue(Description(&(Maintenance(Conducted Maintenance(Performed(By:((( Print( &(Sign

Software(Updates

Airframe(

Engines

Propellers

Camera(Gimbal

Landing(Gear

Vibration(Dampening

Other: