Regulatory Docket No. :



### IN THE MATTER OF THE PETITION FOR EXEMPTION OF: JASON MENDEZ FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF DJI Inspire 1 UNMANNED AIRCRAFT SYSTEMS.

PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112

- 95)

Submitted on October 1 9 , 2015

JASON MENDEZ
6335 E. Heaton Ave Fresno, CA 93727 (559) 824

- 1680 Jason@jason

- mendez.com 

# UNITED STATES OF AMERICA
DEPARTMENT OF
TRANSPORTATION FEDERAL
AVIATION ADMINISTRATION WASHINGTON, DCGLOSSARY 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 Mod and Reform Act of 2012 (FMRA) Section 333

SO Safety Observer

SOP Standard Oper ating Procedures

UAV Unmanned Aircraft Vehicle

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing

SUMMARY

JASON MENDEZ 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 (FM RA). This exemption will permit JASON MENDEZ to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography of construction sites, real estate, and landscape over certain
areas of the United States.INTRODUCTION AND INTERESTS OF THE PETITIONER

JASON MENDEZ provides his clients with expertise and knowledge in advanced aerial technologies. JASON MENDEZ has thousands of hours flying experience ranging from radio control airplanes and helicopters of va rious sizes including UASs and has been a member of the Academy of Model Aeronautics since 1995

. In addition to his experience with radio
control aircraft and UAS s, JASON MENDEZ is also h as over 1 5 years of professional experience and a photographer and vi deographer and is currently a freelance photographer
for several media outlets in the Fresno area

. The objective of JASON MENDEZ and his aerial operations is to provide high quality imaging for a variety of commercial, public, and residential uses, specifi cally targeting:

• Commercial, residential and agricultural r eal

- estate marketing

• Construction sites before and after

• Appraisals of commercial, residential and agricultural properties

• Motion Picture Filming

• Wedding Photography

• Newspaper Pho tography

BACKGROUND Unmanned Aircraft Systems: DJI Inspire 1

JASON MENDEZ seeks an exemption to operate DJI systems for compensation or hire within the NAS. The DJI Inspire 1 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 Inspire 1 has a maximum gross weight of approximately 7 pounds, with a length of 17 inches and a width of 18 inches and a height of 10 inches and a maximum speed of approxim ately 30 knots.

The DJI Inspire 1 is equipped with four main rotors; driven by Lithium Polymer battery powered electric motors.

The DJI Inspire 1 will be operated by JASON MENDEZ and 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, JASON MENDEZ , pursuant to the provisions of the Federal Aviation Regu lations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate the DJI Inspire 1 UAS in the National Airspac e 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 associated with the unmanned aircraft and its operati on, JASON MENDEZ operation DJI Inspire 1 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, Subpart H.

Accordingly, JASON MENDEZ 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.

JASON MEND EZ submits that the requested relief is proper since an equivalent level of safety will be ensured. JASON MENDEZ will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, tec hniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 UAS Instruction Manual). Furthermore, JASON MENDEZ will document and maintain all maintenance records for the DJI Inspire 1 UAS.

Relief from cer tain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested by JASON MENDEZ to the extent necessary to allow a Pilot in Command (PIC) with significant experience in the field of
UAV’s an d who has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI Inspire 1 UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriat e distances from people, vessels, vehicles and structures.

JASON MENDEZ seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the DJI Inspire 1 UAS do not require an airworthiness certificate in accordance with
14 C.F.R. Part 2 1, Subpart H. As such, JASON MENDEZ submits that he wil l ensure the DJI Inspire 1 UAS are in an airworthy condition, prior to every flight, by determining that the UASs are in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 UAS Instruction Manual), and that the aircraft are in a condition for safe flight.

JASON MENDEZ also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings, as the DJI Inspire 1 UAS will not have a typical barom etric altimeter onboard. However, altitude information of the DJI Inspire 1 UAS will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monito ring of the flight path. This altitude information, combined with JASON MENDEZ’s operation of the DJI Inspire 1 UAS within visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to
Section 91.121.Additionally, JASON MEND EZ seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. JASON MENDEZ submits that safety will not be affected by operation of the DJI Inspire 1 UAS during daylight hours in

visual meteorolo gical conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration of approximately 15 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 5 minutes.

In accordance with 14 C.F.R. § 11.81, JASON MENDEZ provides the following information in support of its petition for exemption:



### A. Name and Address of the Petitioner.

The name and address of the Petitioner and point of contact is:
JASON MENDEZ
6335 E. Heaton Ave. Fresno, CA 93727 Jason@jason

- mendez.com (559) 824

- 1680



### B. The Specific Sections of 14 C.F.R . From Which JASON MENDEZ Seeks Exemption.

1. JASON MENDEZ Seeks Exemption from the Requirements of Section 61.113(a) and (b).

Section 61.113, e ntitled 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 pass engers 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 i s only incidental to that business or employment; and

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

2. JASON MENDEZ 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. JASON MENDEZ Seeks Exemption From The Requirements Of Section 91.121.

Section 91.121, entitled Altimeter settings, subse ction (a), states the following, in part:

I. 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

--

Below 18,000 feet MSL, to

--

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

b) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appr opriate available station; or c) 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. JASON MENDEZ 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 en ough 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. JASON MENDEZ 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 discr epancies repaired as prescribed in part 43 of this chapter[.]

6. JASON MENDEZ Seeks Exemption from the Requirements of Section 91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration, subsection ( a)(1), states the following:

a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

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

under § 43.7 of this chapter[.] 7. JA SON MENDEZ Seeks Exemption from the Requirements of Sections 91.409(a)(1) and 91.409(a)(2).

Section 91.409, entitled Inspections, subsection (a), states the following: a) Except as provided in paragraph (c) of this section, no person may operate an
aircraft unless, within the preceding 12 calendar months, it has had

--

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

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.

8. JASON MENDEZ 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
followin g:

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

--

1. A description (or reference to data acceptable to the Administrator) of the work performed; and
2. The date of completion of the work performed; and
3. The signature and certificate number of the person approving
the aircraft for return to service.

(2) Records con taining the following information:

1. The total time in service of the airframe, each engine, each propeller, and each rotor.

2. The current status of life

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

3. The time since last overhaul o f all items installed on the aircraft which are required to be overhauled on a specified time basis.4. 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.

5. 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 invol ves recurring action, the time and date when the next action is required.

6. 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 r ecords specified in paragraph (a)(2) of this section shall be
retained and transferred with the aircraft at the time the aircraft

is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.



### C. The Extent Of Relief JASON MENDEZ Seeks And The Reason JASON MENDEZ Seeks The Relief.

1) Extent Of Relief JASON MENDEZ Seeks And The Reason JASON MENDEZ Seeks Relief From Sectio n 61.113(a) And (b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command, is requested to the extent necessary to allow a PIC holding a private pilot or higher level certificate, as well as a current a nd 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 pr operty for compensation or hire.As set forth more fully below, JASON MENDEZ submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the DJI Inspire 1 UAS unless that PIC has met certain flight

- hour and curr ency requirements, demonstrating that the PIC is able to safely operate either the DJI Inspire 1 UAS in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures.

Further, JASON MENDEZ submits that all flights of DJI Inspire 1 UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to JASON MENDEZ business; and (2 ) will not carry passengers or property for compensation or hire.

2) Extent Of Relief JASON MENDEZ Seeks And The Reason JASON MENDEZ Seeks Relief From Section 91.7(a).

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

ex tent required to allow JASON MENDEZ to determine that the DJI Inspire 1 UAS are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., the JASON MENDEZ Aerial Operations Manual, Monthly Ma intenance Log, and DJI Inspire 1 UAS Instruction Manual).

JASON MENDEZ seeks the requested relief because the DJI Inspire 1 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, JASON MENDEZ will ensur e that the DJI Inspire 1 UAS are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 UAS Instruction Manual) prior to every flight, and further, determine that the aircraft are i n condition for safe flight, as stated in the

conditions and limitations below.

3) Extent Of Relief JASON MENDEZ Seeks And The Reason JASON MENDEZ 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 t he FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), JASON MENDEZ seeks the requested relief because the DJI Inspire 1 UAS altimeter may be set on the ground to

z ero 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 UAS are equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a groun dlevel 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 JASON MENDEZ Seeks And The Reason JASON MENDEZ 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 UAS during daylight hours in visual meteorological conditions (VMC), u nder visual flight rules (VFR), for a total duration of 15 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 5 minutes. JASON MENDEZ seeks the requested relief because without an exemption fr om Section 91.151(b), the flight time duration of the battery powered DJI Inspire 1 UAS will severely constrain the practicality of any aerial video or still photo flight operations that JASON MENDEZ proposes to conduct pursuant to this Petition.

Signific antly, as set forth below, the technical specifications of the DJI Inspire 1 UAS operating documents, and JASON MENDEZ proposed operating limitations, ensure that JASON MENDEZ will safely operate the battery powered DJI Inspire 1 UASs during daylight ho urs in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total duration of 15 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that
for at least 5 minutes.

5) Extent Of Relief JASON MENDEZ Seeks And The Reason JASON MENDEZ 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)

o nly apply to aircraft with an airworthiness certificate, JASON MENDEZ requests relief from these Sections because the DJI Inspire 1 UAS do not require airworthiness certificates. As set forth more fully below, DJI Inspire 1 UAS meet the conditions of

FMRA Section 333 for operation without an airworthiness certificate. Accordingly, JASON MENDEZ will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in th e UAS operating documents (i.e., the JASON MENDEZ Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 UAS Instruction Manual). Furthermore, JASON MENDEZ will document and maintain all maintenance records for the DJI Inspire 1 UAS .



### D. Th e Reasons Why Granting JASON MENDEZ 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 JASON MENDEZ to safely, efficiently, and economica lly perform aerial video andphotography of construction sites, real estate, and landscape 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 JASON MENDEZ 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.

DJI Inspire 1 UAS are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the us e 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 opera ting in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The DJI Inspire 1 UAS do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations.

2) The Public Will Benefit From The Safety And Efficiency Of The DJI 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

ope rations. 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 utiliz ed for aerial video and photography, while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The DJI Inspire 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 DJI Inspire 1 UAS (weighing approximately 6 pounds 7.5 ounces at their maximum gross we ights with a length of 17.3 inches , width of 17.7 inches respectively, and with no fuel on board), has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 6,000pounds 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 Econ omy.

In addition to being safe and efficient, the DJI Inspire 1 UAS are 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, li ke JASON MENDEZ, 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

op erated 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, bu t provides such flexibility without the high operational cost of a traditional
manned aircraft.

By operating the DJI Inspire 1 UAS , companies such as JASON MENDEZ can remain competitive and profitable, and therefore, provide greater job stability to empl oyees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through comme rcial use of the DJI Inspire 1 UAS, provides a stable workforce that increases consumer spending; improve s local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the United States
and abroad.

4) There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operati ons that have been conducted for decades, JASON MENDEZ 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 JASON MEND EZ Aerial Operations Manual, Monthly Maintenance Log, and 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 r equirements 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 JASON MENDEZ Seeks Exemption.

1) Reas ons Why The DJI Inspire 1 UAS 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, JASON MENDEZ operation of the DJI Inspire 1 UAS meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part:

a) In General.

-- No twithstanding 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 syst em before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by
section 334 of this Act.

b) Assessment of Unmanned Aircraft Systems.

-- In making the determination under subsection (a), the Secretary shall determ ine, at a minimum

--

i) 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

ii) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required
for the o peration 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, JASON MENDEZ submits that the DJI Inspire 1 UAS can operate safely in the NAS pursuant to FMRA Section 333, as demons trated by: (a) the characteristics of the DJI Phantom 3 UASs; (b) the pilot certification requirement; and (c) the specific operating limitations.

a) The Specifications Of The DJI Inspire 1 UAS Demonstrate Its Safe Characteristics.

The DJI Inspire 1 UAS do not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability.1. Technical Specifications of DJI Inspire 1 UAS.

The technical specifications of the DJI Inspire 1 UAS are set forth by the User Manuals, attached hereto as Appendix A and B.

2. 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 b oth manual and fully autonomous flight modes. A complete description of the flight and navigational modes of the DJI Inspire 1 UAS provided in the User Manual , att ached hereto as Appendix A

.

3. The DJI Inspire 1 UAS is Designed For Automatic Return To Home P oint Or Hover In The Event Of Loss Of The Control Link Or Navigation.

When the Control Link is lost, the DJI Inspire 1 UAS will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Inspire 1 UAS do not reacquire control link d ata from the GCS, the UAs will assume that the Control Link is lost and the UAs will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown.

A complete description of the Failsafe Functions of the UAS are set forth in pages 27 through 29. The DJI Inspire 1 User Manual is a ttached here as Appendix A

.

4. DJI Inspire 1 UAS GCS Operation.

A complete description of the operation and specifications of the DJI Inspire 1 GCS and flight control software is p rovided in the “Flight Test” portion of their respective user manuals.

b) Flight Operations Of DJI Inspire 1 UAS are Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer.

JASON MENDEZ will be the only person to act as a pil ot in command (PIC) of DJI Inspire 1 UAS. Additionally, a safety observer will assist him during flight time.

c) Flights Of DJI Inspire 1 UAS will Be Conducted Pursuant To Specific Operating

Limitations.

In seeking this exemption, JASON MENDEZ 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 UAS. Proposed operations of any other aircraft will require a new petition or a petition to amend t his 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 45 knots.

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

5. The 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 FAA

- issued
airman medical certificate.

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

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be able to communicate verbal ly at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the SO can perform the functions prescribed in the operating documents.

8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is not permitted to operate the camera or o ther
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 docum ents. 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 andrevised doc uments if it petitions for extension or amendment to the grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS

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

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. I f 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 Stat ion 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. repl acement 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. inopera ble 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 r ecords, 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 Safety Bulletins.

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

17. The PIC must possess at least a private pilot certificate and at least a current

third

- class medical certificate.

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under theexemption, 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 P ICs are permitted under the terms of the exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

- building flights, all persons not essential for flight operations are co nsidered 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 conduct ed 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 UAV 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 req uired by the operator’s COA.The letter of agreement with the airport management must be made available to the Administrator upon request.

21. The UAV may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibi lity is less than 3 statute miles
from the PIC.

22. If the UAV loses communications or loses its GPS signal, it must return to a

pre

- determined location within the planned operating area and land or be recovered in accordance with the operating documents.

23. T he 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 UAV 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. par t 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 UAV must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.

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

29. The UAV must remain clear and yield the right of way to all manned aviation operations and activities at all times.

30. The UAV may no t 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:

(1) Barriers or structures are present that sufficiently protect nonparticipating persons from the UAV and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation aris es where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or;

(2) 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;

(3) Operations nearer to the PIC, SO, operator trainees or essential p ersons do not present an undue hazard to those persons per § 91.119(a).

32. All operations shall be conducted over private or controlled

- access property with permission from the land owner/controller or authorized representative. Permission from land owner/co ntroller or authorized representative will be obtained for each flight to be conducted.33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be repor ted 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 O f Section 61.113(a) And (b) Would Not Adversely Affect Safety.

JASON MENDEZ 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 Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI 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 JASON MENDEZ proposed area of operations, and the operating
limitations set forth

- above; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI Inspire 1 UAS, JASON MENDEZ submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary specific proposed flight operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 1106 2, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

JASON MENDEZ will not allow any PIC to operate the DJI Inspire 1 UAS unless the PIC has demonstrated, by meeting minimum flig ht

- hour requirements or the DJI Inspire 1 UAS training and currency requirements, that the PIC is able to safely operate the DJI Inspire 1 UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropri ate distances from people, vessels,

vehicles and structures.

Specifically, the PIC must have accumulated and logged, in a manner consistent with
14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum
of 5 hours of those hou rs as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes).

As in Exempt ion Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalentlevel of safety during JASON MENDEZ proposed operations. The Administrator has held that prior docume nted 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 und er 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 requir ements 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 m ust 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 safel y conduct the petitioner’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience

- building flights ca n 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 UAS with appropriate distances in accordance with 14 C.F.R 91.119.

Ex emption No. 11138 at page 15.

Accordingly, JASON MENDEZ will ensure safe operations by not allowing any PIC to operate DJI Inspir e 1 UAS unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to sa fely operate the DJI 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.

3) Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.7(a) will be maintained because prior to every flight, JASON MENDEZ wil l ensure that 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 p resented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109,11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

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

The equivalent level of safety established by Section 91.121 will be maintained because the altitude information of the DJI Inspire 1 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 JASON MENDEZ operation of the DJI Inspire 1 UAS within visual line of sight, at or below 400 feet AGL, will ensure a leve l 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 UASs at ground level.

The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

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

A grant of this exemption would ensure an equivalent level of safety established by
14 C.F.R. Section 91.15 1(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, JASON MENDEZ will ensure that it will safely operate the battery powered DJI Inspire 1 UAS during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 15 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after
that for at least 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 batter y 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.

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 mannedaircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos . 2689, 5745, and 10650. Moreover, the FAA has previously granted
relief from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

6) Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adve rsely Affect Safety.

In seeking this exemption, JASON MENDEZ 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 91.4 17(a) & (b) will be met because JASON MENDEZ 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
JASON MENDEZ Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, JASON MENDEZ 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, JASON MENDEZ will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI Inspire 1 User Manuals are attached here as Appendix A

.

Likewise, the exemption so ught will not adversely affect safety because JASON MENDEZ 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.

Furthermor e, 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 main tained 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 JASON MENDEZ proposed operating limitations, the operating documents, and the technical a spects of the DJI Inspire 1 UAS , JASON MENDEZ 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 pr esented 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, JASON MENDEZ requests that the FAA prescribe special conditions for the intended operation of the DJI Inspire 1 UAS , which contain s uch safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the 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 accordan ce with any requirements that must be
establ ished 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 ope ration of the DJI Inspire 1 UAS , since the airworthiness reg ulations 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 r egulations 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 condition s 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 safet y 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 Inspire 1 UAS , wh ich 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).• A Summary That Can Be Published In The Federal Register, stating: The Rules From Which JASON MENDEZ Seeks Exemption:

JASON MENDEZ 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 JASON MENDEZ Seeks:

This exemption will permit JASON MENDEZ to commercially operate an Unmanned

Airc raft System (UAS) for the purpose of conducting aerial video and photography
over certain areas of the United States.

• Any Additional Information, Views, Or Arguments Available To Support JASON MENDEZ 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, JASON MENDEZ request for exemption may be granted pursuant to the authority of FMRA S ection 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 poses a threat to national security; and further, provide s the authority for such UAS to operate
without airworthiness certification.

As discussed in detail above, JASON MENDEZ 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

As set forth herein, JASON MENDEZ 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 UA S commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing JASON MENDEZ to safely, efficiently, and economically operate the DJI Inspire 1 UAS commercially within the NAS.WHEREFORE , in accordance with t he Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, JASON MENDEZ 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 Leading Edge 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: October 19, 2015

Attachments to this submission:

1. DJI Inspire 1 Manual
2. UAS Flight/ Maintenance Log

JASON MENDEZ 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 dis tance. In addition, DJI software provides real

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

Very respectfully, JASON MENDEZ 6335 E. Heaton Ave Fresno, CA 93727 (559) 824

- 1680 Jason@jason

- mendez.com

Maximum upload to this site would not support my attachments: I've added the following
links instead:
1. DJI Inspire 1 Manual

http://download.dji

i nnovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.2_en.pdf