November, 20, 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 4 5.23(b); 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203 (a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR 91.417(a) and (b) Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act") and 14 CFR Part 11, Nicholas Martino , DBA "4 Rotors Technologies ," operator of the DJI Phantom model 3 Small Unmanned Aircraft System (UAS), hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of designated UAS, provided such operations are conducted within and under the conditions outlined herein or as may be establis hed by the FAA as required by Section 333. Commercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors, would provide professional services in the following areas: 1. Aerial photography and/or video for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities. 2. Aerial video and/or photography for public and/or private use including television , public events, cinematography and newsgathering. 3. Aerial inspection/photography of residential/commercial structures under contract with the owners or local government authority. 4. Aerial inspection/photography of residential/commercial utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers.5. Aerial video/photography or providing live video feed to assist with search and

rescue operations in cases of an emergency or natural disaster only when the local authorities or government has reque sted it by contract or donation. Nicholas A Martino , DBA " 4 Rotors Technologies ", will operate one or more of the following mod el UAS: 1. DJI Phantom 3 Professional + with the following specifications:

 Phantom Aircraft o Flight time 24 minutes o Height 1 90 mm o Diagonal Length Without Rotors Installed 5 90 mm o Propellers 9.5 x 5 ” self-tightening propellers o Weight Without Battery and Payload 1.8 lbs. o We ight With Battery and Payload 2.8 pounds o Battery 3S 11.1 volt 5100mAh 8C Lithium Polymer pack o Charger Lithium Polymer AC/DC Intelligent Balancing charger o Transmitter 9 channel 915MHz Given the small size of the UAS in scope and the controlled environment provided, the proposed operations will adhere to the Reform Act's safety requirements. The approval of this application presents no national security issues. Regarding the level of safety surrounding the proposed operations and the public benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise, the grant of the requested exemption is in the public interest. Accordingly, the applicant graciously requests that the FAA grant the requested exemption.AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The operation limitations proposed for an equivalent or higher level of safety because operations will further enhance the safety of the persons and/or property using conventional aircraft. These limitations and conditions to which the applicant agrees to adhere to when conducting commercial operations under the FAA issued exemption as set forth in the Flight Operations Manual (FOM) include: 1. The UAS will weigh significantly less than 55 lbs. It weighs less than 4 pounds with battery and camera. 2. The UAS, depending on the model in operation, will have a maximum operat ing speed of no more than 70 MPH. 3. Flights will be operated within line of sight of the Pilot in Command (PIC) and/or Visual Observer (VO). 5. Maximum flight time for each operational flight will be depending on the UAS model in operation, but will not exceed 24 minutes. Flights will be terminated at 25% battery power reserve or 24 minutes of flight time whichever occurs first. Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and not more than 200 feet above an e levated platform from which filming is planned. 6. Minimum crew for each operation will consist of the UAS Pilot and at least one Visual Observer (VO), and may include a third, but separate, Camera Operator (CO). 7. The UAS pilot will be a designated Pilot in Command (PIC ). The PIC will have logged a minimum of 20 hours on the designated UAS. 8. A safety briefing will be performed prior to each day's flights consisting of all the days' production activities. 9. All flight activities will be logged. 10. All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only. 11. The flights will occur in Class G airspace no closer than a 5mile radius of the geographic center/Airport Reference Point (AR P) of a tower controlled or uncontrolled airport.12. Flights will not be closer than a 5 mile radius of the geographic center/Airport.

13. The operator will file FAA Form 77111, or its equivalent, as modified in light of the requested exemption, with the appropriate local Flight Standards District Office (FSDO) no more than 72 hours but no less than 48 hours from planned operation. 14. The o perator will obtain verbal/written consent of all persons involved with the planned operation and ensure that only consenting persons will be allowed within 100 feet of the flight operation, and the radius may be reduced to 30 feet based upon an equivalent level of safety determination, as U.S. Department of Transportation required under the FOM. W ith the advanced permission of the FSDO, operations at closer range may be approved. 15. The PIC and VO will have been trained in operation of UAS and receive up to date information for the particular UAS to be operated. 16. The PIC and VO will be able to communicate by voice and/or radio at all times. 17. Written and/or verbal permission and permits will be obtained from territorial, state, county or city jurisdictions, including law enforcement, fire or other appropriate governmental agencies as appropriate to flight operations. 18. if the UAS loses communications with the remote controller or loses GPS signal, the UAS will have the capability to return to a p redetermined location within a designated location and land autonomously. Grant of the exemption to Nicholas Martino, DBA “4 Rotors Technologies” will be subject to the following mandatory conditions, which are based upon operating conditions set forth fo r operation of UAS by public entities pursuant to Certificates of Authorization, with additional restrictions:

 All operations to occur in Class G airspace  Operations to avoid congested or populated areas, which are depicted in yellow on VFR charts  Operations to be conducted over private or controlled -access property  Permission from land owner/controller required before commencing any flight  Operations to occur during Visual Flight Rules Meteorological Conditions (VMC)  Aircraft to remain wi thin Visual Line of Sight (VLOS) o VLOS guaranteed with a cylinder of operation around operator of 1/2 nautical miles (NM) o Cylinder walls may be expanded by additional observer's  Operations to occur during daylight hours Above Ground Level (AGL) altitude to be restricted to 400 feet

 All operations conducted in vicinity of airport to remain more than 2.5 NM from centerline azimuth of runway centerline measured from runway thresholds  All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies Operator Requirements Nicholas Martino, DBA “4 Rotors Technologies” respectfully proposes that operator requirements should take into account the characteristics of the particular UAS. Certain UASs, such as the DJI Phantom 3 , are characterized by a high degree of preprogrammed control and various built- in technical capabilities that limit the potential for operation outside of the operating conditions set forth above. The DJI Phantom 3 has a semi -autonomous navigation and control system comprised of a Ground Control Station (GCS), GPS stabilization and auto - pilot system. In the case of unplanned events, the operator can allow the aircraft to follow the pre programmed evasive maneuvers from the control unit or enable assisted steering for direct control. Pre - programmed maneuvers include initiation of holding at present position; suspension of mission; fly back to launch point; fly to point and hold; abort mission and land; and emergency power cut off and land (Flight Termination System). Additional automated safety functions and safety enhancing features of the DJI Phantom 3 include the following:

 Detection of lost GPS signal will initiate a return to launch program, allowing the operator time to take control if necessary. The GCS produces an audible message of the battery level every 15 -60 seconds (this can be adjusted). At 10.2V (this can be adjusted) overall pack voltage the aircraft will automatically land.  On - board failsafe limits aircraft descent speed to a maximum of approximately 5 m/s  The aircraft, weighing less than 4 Ib. , fully loaded, is constructed of high impact plastic or similar material which is intended to absorb impact energy.  The motor is driven by a pulse width modulated signal, not an analog signal. In summary, applicant seeks an exemption from the FARs set forth above and in Appendix A to allow commercial operations of a small unmanned vehicle conducting aerial imaging, photography, videography, inspection and surveying. Approval of the exemption allowing commercial operations of the DJI Phantom 3 foraerial imaging, photography, videography, inspection and surveying work will

enhance safety by reducing risk. Conventional aerial operations, using jet or piston powered aircraft present risks associated with vehicles that weigh in th e neighborhood of 5,000 to 7,000Ibs, carry large quantities of fuel, passengers, and, in some cases, cargo. Such aircraft must fly to and from the survey location. In contrast, a DJI Phantom 3 weighing less than 4 Ibs and powered by batteries eliminates a portion of that risk given the reduced mass and lack of combustible fuel carried on board. The DJI Phantom 3 is carried to the survey location, not flown there. The DJI Phantom 3 will carry no passengers or crew and, therefore, will not expose any individuals to the risks associated with manned aircraft flights. The operation of the DJI Phantom 3 , weighing less than 4 Ibs, for aerial imaging, photography, videography, inspection and surveying in accordance with the strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including exempting Nicholas Martino DBA “4 Rotors Technologies” from the requirements of Part 21.

The DJI Phantoms 3’s satisfaction of the criteria set forth in Section 333 of the Reform Act

—size, weight, speed, operating capabilities, lack of proximity to airports and populated areas, operation within visual line of sight, and national security

—and its showing of an equivalent level of safety as it may relate to the requirement for a pilot' s license, provide more than adequate justification for the grant of the requested exemptions allowing commercial operation of the DJI Phantom 3 in the commercial precision video and imaging business.
Sincerely, Nicholas A. Martino 4 Rotors Technologies Po Box 2708 Camarillo, CA, 93011