Petition for Section 333 Exemption

Leading Edge Aviation Resources, LLC

Page 1 of 21 November 2 5 , 2015

U.S. Department of Transportation

Docket Operations

West Building Ground Floor, Room w12

- 140

1200 New Jersey Ave., SE

Washington, DC 20590

RE: Petition for Section 333 Exemption Under FAA Modernization and Reform Act of 2012

Petitioner : Leading Edge Aviation Resources, LLC

Petitioner’s s UAS(s) Models : DJI Inspire 1 ; DJI Phantom 2 Vision+;

DJI Phantom 3 ; DJI S900;

3D Robotics X8 M

Petitioner’s sUAS(s) Operations : Aerial Imagery; Aerial Photography;

Aerial Videography ; 3D Mapping; Aerial

Agricultural, Environmental, Structural,

and Exploratory Mapping; Agricultural

Spraying ; Aerial Surveying; Education,

Research and Development

Regulations Requiring Exemption : 14 CFR §§ 61.23(a) and (c);

14 C.F.R. §§ 61.101(e)(4) and (5)

14 C.F.R. § 61.113(a);

14 C.F.R. §61.315(a)

14 C.F.R. § 91.7(a);

14 C.F.R. § 91.119(c)

14 C.F.R. §91.121;

14 C.F.R. §91.151(a)(1)

14 C.F.R. §91.405(a);

14 C.F.R. §91.407(a)(1)

14 C.F.R. §§ 91.409(a)(1) and (2); and

14 C.F.R. 91.417(a) and (b)

To whom it may concern,

On behalf of Leading Edge Aviation Resources, LLC (hereinafter “ L.E.A.R. ”) , a Lakeland

, FL

company specializing in aerial imagery, aerial photography, aerial videography, 3D mapping,Petition for Section 333 Exemption

Leading Edge Aviation Resources, LLC

Page 2 of 21 aerial agricultural, environ mental, structural, and exploratory mapping, and agricultural spraying,

aerial surveying, and research and development, the undersigned counsel for L.E.A.R. hereby

applies for Section 333 exemption pursuant to the FAA Modernization and Reform Act of 2012,

Public Law 112

- 95 (P.L. 112

- 95)

, and 14 C.F.R. Part 11.

The owner and operator for Leading Edge Aviation Resources, Mr. Anthony G. Ison, holds a

Private Pilot, Airplane, Single Engine, Land (PVT) certificate. Consequently, Mr. Ison and his

employees unde rstand the importance of safe flight operations and are acutely aware of the

importance of complying with all Federal Aviation Regulations (F.A.R.s). As such, L.E.A.R.,

through the careful oversight and tutelage of Mr. Ison, will ensure that all sUAS fligh t operations

are conducted in the safest possible manner. To that end, L.E.A.R. will comply with any flight or

atmospheric condition limitations imposed upon the commercial operation of all sUAS flight.

This petition will address the following topics, as they relate to L.E.A.R. commercial sUAS flight

operations: the nature of L.E.A.R. commercial d rone operations, as well as the particular sUAS

models for which L.E.A.R. seeks exemption ; L.E.A.R.’s proposed sUAS flight operations and

conditions ; p rivacy concerns; public interest and safety concerns; and, the above specified F.A.R.s

requiring exemption. Under Section 333(b)(1), L.E.A.R.’s petition will give the FAA good cause

to issue a Certificate Of Waiver or Authorization by showing that the size, weight, speed,

operational capacity, proximity to airports and populated areas, and operations within the Visual

Line of Sight of the Pilot in Command and Visual Observer of L.E.A.R.’s sUAS models neither

creates a hazard to users of the Na tional Airspace System or public nor poses a threat to national

security.

Additionally, this petition will prove that L.E.A.R.’s flight operations for the commercial usage of

its sUAS models provides an equivalent level of safety when compared to the F.A .R.s requiring

exemption. To that end, this petition will highlight some of the numerous, granted petitions for

Section 333 exemption for similar commercial operations of L.E.A.R.’s sUAS models.

Please refer to the “Table of Contents” beginning on page th ree (3) to assist your review of

L.E.A.R.’s petition for Section 333 exemption. If we may provide additional insight or information

regarding L.E.A.R.’s petition, please do not hesitate to contact The Ison Law Group at 863

- 712

- 9475 or Christopher@thepilotl awyer.com.

Sincerely,

THE ISON LAW GROUP

Christopher Ison, Esq.

Enclosures

T ABLE OF CONTENTSPetition for Section 333 Exemption

Leading Edge Aviation Resources, LLC

Page 3 of 21 I. Glossary of Terms ................................................................................4

II. Publishable Summary

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

III. Petitioner’s Contact I nformation ..............................................................5

IV. L.E.A.R. Overview

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

V. L.E.A.R. sUAS Models

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

a. DJI Inspire 1 Specifications

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

b. DJI Phantom 2 Vision+ Specifications ..................................

........ ..9

c. DJI Phantom 3 Specifications ...................................................10

d. DJI S900

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

e. 3D Robotics Specifications

......... ...................................................1 3

VI. Flight Conditions and Operating Procedures ...................................................1 4

VII. Privacy .......................................................................................1 7

VIII. Public Interes t and Safety .....................................................................1 7

IX. Regulations from Which Exempti on is Requested ..........................................1 8

a. 14 CFR §§ 61.23(a) and (c): Medical Certificates Requirement and Duration ...............1 8

b. 14 C.F.R. §§ 61.101(e)(4) and (5): Recreational Pilot Privileges and Limitations

............... 1 8

c. 14 C.F.R. § 61.113(a): Private Pilot Privileges and Limitations: Pilot in Command

...... 1 8

d. 14 C.F.R. §61.315(a): What Are The Privileges and

Limits of My Sport Pilot Certificate?

... ............................................. ... 1 8

e. 14 C.F.R. § 91.7(a): Civil Aircraft Airw orthiness ...................................................1 9

f. 14 C.F.R. § 91.119(c): Minimum Safe Altitude: General ..........................................1 9

g. 14 C.F.R. §91.121: Altimeter Settings

............................................................ 20

h. 14 C.F.R. §91.151(a)(1): Fuel Requirements For Flight In VFR Conditions

............... 20

i. 14 C.F.R. §91.405(a): Maintenance Required

................................................... 20

j. 14 C.F.R. §91.407(a)(1): Operation After Maintenance,

Preventative Maintenance, Rebuilding, Or Alteration

.. ................................ 20

k. 14 C.F.R. §§ 91.409(a)(1) and (2): Inspections

................................................... 20

l. 14 C.F.R. 91 .417(a) and (b): Maintenance Records

.......................................... 20

GLOSSARY OF TERMSPetition for Section 333 Exemption

Leading Edge Aviation Resources, LLC

Page 4 of 21 Aircraft : any contrivance invented, used, or designed to navigate, or fly in, the air (Title 49, United

States Code (49 USC) § 40102)

.

National Airspace System (NAS) : the common network of U.S. airspace; air navigation facilities,

equipment and services, airports or landing areas; aeronautical charts, information and services;

rules, regulations and procedures, technical information, and manpower and material

.

Opera tional Control : with respect to a flight, means the exercise of authority over initiating,

conducting or terminating a flight (14 CFR § 1.1)

.

Pilot in Command (PIC) : the person who has final authority and responsibility for the operation

and safety of th e flight; has been designated as PIC before or during the flight; and holds the

appropriate category class and type

- rating, if appropriate, for the conduct of the flight (14 CFR §

1.1)

.

Small Unmanned Aircraft System ( s UAS) : an unmanned aircraft and associated elements,

including communication links and the components that control the unmanned aircraft, that are

required for the pilot in command to operate safely and efficiently in the national airspace system

(P.L. 112

- 95, Section 331) , weighing less than 55 pounds, including payload.

UAS Certificate of Waiver or Authorization (COA) : an authorization issued by the Air Traffic

Organization to an operator for a specific unmanned aircraft activity

.

Visual Line of Sight (VLOS) : unaided (corrective lens es and/or sunglasses excepted) visual

contact between a pilot in command and an unmanned aircraft sufficient to maintain safe

operational control of the aircraft, know its location, and be able to scan the airspace in which it is

operating to see and avoid other air traffic or objects aloft or on the ground.

PUBLISHABLE SUMMARYPetition for Section 333 Exemption

Leading Edge Aviation Resources, LLC

Page 5 of 21 Pursuant to 14 C.F.R §11.81(f), should the FAA require a publishable summary for the Federal

Register

, Leading Edge Aviation Resources, LLC (“ L.E.A.R. ”), submits the following

information:

L.E.A.R. seeks exemption from the following Federal Aviation Regulations (F.A.R.s):

14 CFR §§ 61.23(a) and (c); 14 C.F.R. §§ 61.101(e)(4) and (5) ; 14 C.F.R. §

61.113(a); 14 C.F.R. §61.315(a) ; 14 C.F.R. § 91.7(a); 14 C.F.R. § 9 1.119(c) ; 14

C.F.R. §91.121; 14 C.F.R. §91.151(a)(1) ; 14 C.F.R. §91.405(a); 14 C.F.R.

§91.407(a)(1) ; 14 C.F.R. §§ 91.409(a)(1) and (2); and 14 C.F.R. 91.417(a) and (b)

.

L.E.A.R. seeks exemption from the above listed F.A.R.s for the purpose of commercially operating

Small U nmanned A ircraft S ystems (sUAS), to wit: the DJI Inspire 1

, DJI Phantom 2 Vision+

, DJI

Phantom 3

, DJI S900 and the 3D Robotics X8

- M

. L.E.A.R. int ends to commercially operate the s e

sUAS model s for aerial imag ery, aerial photography, aerial videography, 3D mapping, aerial

agricultural, environmental, structural, and exploratory mapping, agricultural spraying , aerial

surveying, education, and research and development . As such, this petition will prove that

L.E.A .R.’s flight operations for the commercial usage of this sUAS model provides an equivalent

level of s afety when compared to the F.A.R.s requiring exemption.

In support of this petition, L.E.A.R. notes that the FAA has already granted numerous exemptions

for similar commercial operators of the se above mentioned sUAS models

. To that end, L.E.A.R.’s

petition will highlight some of the numerous, granted petitions for Section 333 exemption for

similar commercial operations of the foregoing sUAS mode ls.

Under Section 333(b)(1) of the FAA Modernization and Reform Act of 2012, L.E.A.R.’s petition

will give the FAA good cause to issue a Certificate Of Authorization by showing that the size,

weight, speed, operational capacity, proximity to airports and populated areas, and operations

within the Visual Line of Sight of the Pilot in Command and Visual Observer of L.E.A.R.’s sUAS

mod els neither creates a hazard to users of the National Airspace System or public nor poses a

threat to national security. To that end, L.E.A.R. seeks exemption from the above specified

F.A.R.s as L.E.A.R.’s flight operations provide an equivalent level of safety when compared to

the F.A.R.s to be exempted. L.E.A.R. will adhere to any flight or atmospheric condition limitation

imposed by the FAA

.

PETITIONER’S CONTACT INFORMATION

Petitioner: Counsel for Petitioner:

Anthony G. Ison, Owner The Ison La w Group

Leading Edge Aviation Resources , LLC 2073 US Hwy 92 West, Suite 104

2073 US Hwy 92 West, Suite 104 Winter Haven, FL 33881

Winter Haven , FL, 338 81 Phone: 863

- 712

- 9475

Phone: 863

- 712

- 9472 Email: Christopher@thepilotlawyer.com

LEADING EDGE AVIATION RESOURCES, LLC’s PETITIONPetition for Section 333 Exemption

Leading Edge Aviation Resources, LLC

Page 6 of 21 FOR SECTION 333 EXEMPTION

Leading Edge Aviation Resources

Overview

Leading Edge Aviation Resources (hereinafter “ L.E.A.R. ”) is a Lakeland, Florida , based company

specializing in aerial imagery, aerial photography, aerial videography, 3D mapping, aerial

agricultural, environmental, structural, and exploratory mapping, agricultural spraying , aerial

surveying, education, and research and development . L.E.A.R. provides services to various

companies requirin g aerial real estate, agricultural, environmental, structural, and exploratory

mapping and photography. Furthermore, L.E.A.R. provides services to companies requiring aerial

photography and event photography

.

As detailed below, L.E.A.R. will only allow c ommercial sUAS operations of its sUAS models by

certificated airmen, holding at the bare minimum a sport pilot certificate. Currently, Mr . Anthony

Ison , owner of L.E.A.R., holds his Private Pilot, Single Engine, Land certificate. Mr. Ison has

approximately 100 hours of Pilot

- In

- Command time in fixed

- wing aircraft, as well as roughly 5

hours of Pilot

- In

- Command time in a rotorcraft aircraft. Consequently, Mr. Ison and the employees

of L.E.A.R. understand safe flight operations and will apply that knowledge d uring all commercial

sUAS operations.

Based upon L.E.A.R.’s intended use and proposed flight operations and conditions limitations,

L.E.A.R. would like an exemption from the following Federal Aviation Regulations (F.A.R.s) to

commer cially operate the above specified sUAS models : 14 CFR §§ 61.23(a) and (c); 14 C.F.R.

§§ 61.101(e)(4) and (5) ; 14 C.F.R. § 61.113(a); 1 4 C.F.R. §61.315(a) ; 14 C.F.R. § 91.7(a); 14

C.F.R. § 91.119(c) ; 14 C.F.R. §91.121; 14 C.F.R. §91.151(a)(1) ; 14 C.F.R. §91.405(a); 14 C.F.R.

§91.407(a)(1) ; 14 C.F.R. §§ 91.409(a)(1) and (2); and 14 C.F.R. 91.417(a) and (b)

.

L.E.A.R.’s s UAS Model

L.E.A.R.’s requested exemption from the above specified F.A.R.s will allow for L.E.A.R.’s use of

the DJI Inspire 1, DJI Phantom 2 Vision+

, DJI Phant om 3

, DJI S900 and the 3D Robotics X8

- M

which L.E.A.R. intends to use for commercial aerial imagery, aerial photography, aerial

videography, 3D mapping, aerial agricultural, environmental, structural, and exploratory mapping,

agricultural spraying , aerial surveying, education, and research and development within the United

States of America. These sUAS model s are either similar to, or the same as, sUAS model that the

FAA has already granted exemption for similar commercial flight operations in Exemption

Numbers

, 11693 , 11109

, and 11213 , 11824, 11617, 11699

, 11693

, 11062, 11109, 11112, 11213

, 11656 , 11845, and 12042.

DJI Inspire 1 and DJI Phantom 2 Vision+

The DJI Phantom 2 Vision+ and DJI Inspire 1 are quad

- copter sUAS models, capable of providing

hove r flight in both the vertical and horizontal planes. As such, both sUAS models provide

excellent maneuverability and ease of control for the PIC. The ease with which a PIC can control

these sUAS models is evidenced by the fact that both sUAS models are com mercially available

for RC hobbyists, requiring no training or experience prior to flight.Petition for Section 333 Exemption

Leading Edge Aviation Resources, LLC

Page 7 of 21 Both the DJI Phantom 2 Vision+ and DJI Inspire 1 additionally provide excellent situational

awareness for the PIC. Both sUAS models allow the PIC to determine the exact altitude of the

sUAS via GPS technology and monitoring. In addition, both sUAS models provide the PIC with

the ability to monitor the available remaining battery life, allowing the PIC to make informed, safe

decisions regarding the duration and conti nuation of a particular flight.

L.E.A.R.’s primary objective with each commercial flight is the safe return of the sUAS without

injury to property or person. Both the DJI Phantom 2 Vision+ and DJI Inspire 1 incorporate unique

operating modes that provide for the safe return of the sUAS should the PIC experience a loss of

signal connectivity between the sUAS model’s transmitter and receiver. The DJI Inspire 1

incorporates three safe modes in such a situation: Failsafe, Return to Home, and Dynamic Home

Point . Likewise, the DJI Phantom 2 Vision+ incorporates a failsafe function should the sUAS

experience loss of signal connectivity. Both models will guide the sUAS back to a predetermined,

safe landing zone should the model experience issues.

Below are the sp ecifications for these sUAS models:

DJI Inspire 1:

Aircraft

Weight (Battery Included): 2935 grams

Hovering Accuracy (P Mode): Vertical: 0.5m; Horizontal: 2.5m

Max Angular Velocity: Pitch: 300 ֯ /s; Yaw: 150 ֯ /s

Max Tilt Angle: 35 ֯

Max Ascent Speed: 5 m/s

Max Descent Speed: 4 m/s

Max Speed: 22 m/s (ATTI mode, no wind)

Max Flight Altitude: 4500 m

Max Wind Speed Resistance: 10 m/s

Max Flight Time: Approximately 18 minutes

Motor Model: DJI 3510

Propeller Model: DJI 1345

Indoor Hov ering: Enabled by default

Operating Temperature Range:

- 10 ֯ C to 40 ֯ C

Diagonal Distance: 559 to 581 mm

Dimensions: 438x451x301mm

Gimbal

Model: ZENMUSE X3

Output Power (with Camera): Static: 9W; In Motion: 11W

Operating Current: Stati on: 750mA; Motion: 900mA

Angular Vibration Range: ±0.03 ֯

Mounting: Detachable

Controllable Range: Pitch:

- 90 ֯ to +30 ֯ ; Pan: ±320 ֯

Mechanical Range: Pitch:

- 125 ֯ to +45 ֯ ; Pan: ±330 ֯

Max Controllable Speed: Pitch: 120 ֯ /s; Pan: 180 ֯ /sPetition for Section 333 Exemption

Leading Edge Aviation Resources, LLC

Page 8 of 21 Camera

Na me: X3

Model: FC350

Total Pixels: 12.76M

Effective Pixels: 12.4M

Image Max Size: 4000x3000

ISO Range: 100

- 3200 (video) 100

- 1600 (photo)

Remote Controller

Name : C1

Operating Frequency: 5.725~5.825GHz; 2.400~2.483GHZ

Transmitting Distance: 2km (Outdoor and Unobstructed)

EIRP: 10dBM@900, 12dBm@5.8G, 20dBm@2.4G

Video Output Port: USB, Mini

- HDMI

Power Supply: Built

- in battery

Charging: DJI Charger

Dual User Capability: Host

- and Slave connection

Mobile Devise Holder: Tablet or Smart Phone

Output Power: 9W

Operating Temperature Range:

- 10 ֯ C to 45 ֯ C

Charging Temperature Range: 0

- 40 ֯ C

Battery: 6000 mAh LiPo 2S

Charger

Model: A11

- 100P1A

Voltage: 26.3V

Rated Power: 100W

Battery (St andard)

Name: Intelligent Flight Battery

Model: TB47

Capacity: 4500mAh

Voltage: 22.2V

Battery Type: LiPo 6S High voltage battery

Energy: 99.9Wh

Net Weight: 570g

Operating Temperature Range:

- 10 ֯ C to 40 ֯ C

Charging Temperature Range: 0

- 40 ֯ C

Max Charging Power: 180WPetition for Section 333 Exemption

Leading Edge Aviation Resources, LLC

Page 9 of 21 DJI Phantom 2 Vision+:

Aircraft Specifications:

Supported Battery: DJI 5200mAh Li

- Po Battery

Weight (Battery & Propellers included): 1242 grams

Recommended Payload: ≤1300 grams

Maximum Payload: 1 350 grams

Hovering Accuracy (Ready to Fly): Vertical: 0.8m; Horizontal: 2.5m

Max Yaw Angular Velocity: 200 ֯ /second

Max Tiltable Angle: 35 ֯

Max Ascent/Descent Speed: Ascent: 6 m/s; Descent: 2 m/s

Max Flight Speed: 15 m/s

Motor Diagonal Length 350 mm

3

- axial Stabilized Gimbal Specifications:

Working Current: Static: 750mA; Dynamic: 900mA

Control Accuracy: ±0.03 ֯

Controllable Range: Pitch:

- 90 ֯

- 0 ֯

Maximum Angular Speed: Pitch: 90 ֯ /second

Camera

Operating Environment Temperature: 0 ֯ C

- 40 ֯ C

Sensor Size: 1/2.3”

Effective Pixels: 14 Megapixels

Resolution: 4384x3288

HD Recording: 1080p30/1080i60

Recording FOV: 110 ֯ /85 ֯

Remote Controller

Operating Frequency: 5.728 GHz

– 5.85 GHz

Communication Distance (open area): C E Compliance: 400m; FCC Compliance: 800m

Receiver Sensitivity (1%PER):

- 93dBm

Transmitting Power (EIRP): CE Compliance: 25mW; FCC Compliance: 100mW

Working Current/Voltage: 120mA@3.7V

Battery: 2000mAh rechargeable LiPo battery

Range Extender

Oper ating Frequency: 2412MHz

- 2462MHz

Communication Distance (open area): 500m

- 700m

Transmitting Power: 20dBm

Power Consumption: 2W

DJI Phantom 3Petition for Section 333 Exemption

Leading Edge Aviation Resources, LLC

Page 10 of 21 The DJI Phantom 3 is a quad

- boom, four (4) motor sUAS, capable of providing hover flight in

both the vertical and horizontal planes. As such, the DJI Phantom 3 provides excellent

maneuverability and ease of control for the PIC. The ease with which a PIC ca n control this sUAS

model is evidenced by the fact that the DJI Phantom 3 is commercially available for RC hobbyists,

requiring no training or experience prior to recreational usage.

Like previous DJI Phantom predecessors, the DJI Phantom 3 provides inno vative features that

culminate in a safe flying experience. For example, the Phantom 3 now uses DJI’s Intelligent Flight

Battery, featuring upgraded battery cells and an advanced power management system. Likewise,

the flight controller found in the Phantom 3 has been updated to provide a safer, more reliable

experience through a newly implemented flight recorder. Moreover, the flight controller now uses

a Vision Positioning System, which, when combined with the remote controller’s flight recorder,

enhances hovering precision when flying in environments where GPS is unavailable.

In an effort to ensure the safety of each flight, L.E.A.R. chose the DJI Phantom 3 due to the

enhanced safety features found in this sUAS. The DJI Phantom 3 boasts various Return

- to

- Home

(RTH) modes which bring the sUAS back to the last recorded Home point, allowing for the safe

landing and return of the sUAS, should an unforeseen emergency arise. As such, the DJI Phantom

3 allows for Smart RTH, Low Battery RTH, and Failsafe RTH.

I n Smart RTH, the DJI Phantom 3 will automatically return to the last recorded Home Point.

During this operation, the PIC may use the remote controller’s control sticks to control the sUAS

to avoid any collisions. The Low Battery RTH failsafe is triggered w hen the DJI Intelligent Flight

Battery is depleted to a point that may affect the safe return on the sUAS. When the DJI Pilot App

notifies the PIC that the battery is low, the sUAS will begin the RTH procedure, unless otherwise

prompted by the PIC. Lastly, the Failsafe RTH allows the sUAS to return to a pre

- recorded location

if the remote controller signal is lost for more than three (3) seconds. If the PIC regains remote

controller connectivity, the PIC may resume control of the sUAS and continue the fligh t.

In addition to the above safety features, the DJI Phantom 3 also incorporates an anti

- drop kit for

the gimbal. The anti

- drop kit ensures that the gimbal and camera remain connected to the sUAS,

so as to preclude the possibility of the gimbal/camera fr om disconnecting during flight operations.

Moreover, the DJI Pilot App provides an incredible wealth of information that will supplement the

PIC’s situational awareness while operating the DJI Phantom 3 by providing the following

information: current fligh t mode, GPS signal strength, system status, battery level indicator,

remote controller signal strength, flight telemetry (height, distance, and airspeed), and area map.

By enhancing the PIC’s situational awareness, the PIC will be able to focus on safe fli ght

operations, thereby reducing the likelihood of an incident which would lead to property damage

or injury to persons.

Below are the specifications for this sUAS model:

DJI Phantom 3:

Aircraft:Petition for Section 333 Exemption

Leading Edge Aviation Resources, LLC

Page 11 of 21 Weight: 1280 g

Maximum Ascent Speed: 5 m/s

Maximum Descent Speed: 3 m/s

Maximum Speed: 16 m/s

Maximum Flight Altitude: 6000 m

Maximum Flight Time: 23 minutes (Approximately)

Operating Temperature Range: 0 ֯ C to 40 ֯ C

GPS: GPS/GLONASS

Gimbal:

Controllable Range: Pitch:

- 90 ֯ to +30 ֯

Vision Positioning:

Velocity Range: <8 m/s (Altitude 2 m)

Altitude Range: 30 cm

– 300 cm

Operating Range: 30 cm

– 300 cm

Operating Environment: Surface w/Clear Pattern and

Adequate Lighting (Lux > 15)

Camera:

Sensor: Sony Exmor 1/2.3”

Operating Temperature Range: 0 ֯ C to 40 ֯ C

Remote Controller:

Operating Frequency: 2.400 GHz

– 2.483 GHz

Maximum Transmission Distance: 2 km (outdoors and unobstructed)

Operating Temperature Range: 0 ֯ C to 40 ֯ C

Battery: 6000 mAh LiPo 2S

Mobile Device Holder: Tablets and smartphones

Transmitter Power (EIRP): FCC: 20 dbm; CE: 16 dbm

Working Voltage: 1.2 A @ 7.4 V

Charger:

Voltage: 17.4 V

Rated Power: 57 W

Intelligent Flight Battery (PH3

- 4480 mAh 15.2V) :

Capa city: 4480 mAh

Voltage: 15.2 V

Battery Type: LiPo 4S

Energy: 68 Wh

Net Weight: 365 g

Operating Temperature:

- 10 ֯ C to 40 ֯ C

Max Charging Power: 100 W

DJI S900Petition for Section 333 Exemption

Leading Edge Aviation Resources, LLC

Page 12 of 21 The DJI S900 is a six

- boom

, six ( 6 ) motor sUAS, capable of providing hover flight in both the

vertical and horizontal planes. As such, the DJI S900 provides excellent maneuverability and ease

of control for the PIC. The ease with which a PIC can control this sUAS model is evidenced by

the fact that the DJI S900 is commercially available for RC hobbyists, requiring no training or

experience prior to recreational usage.

In an effort to ensure the safety of each flight, L.E.A.R. chose the DJI S900 due to the enhanced

safety features found in this sUAS. The DJI S900 boasts various Return

- to

- Home (RTH) modes

which bring the sUAS back to the last recorded Home point, allowing for the safe landing and

return of the sUAS, should an unforeseen emergency arise. As such, the S900 allows for Ground

St ation Signal RTL, Low Battery RTL, GPS Failsafe RTL, RC Controller Failsafe, and an Altitude

Failsafe.

To that end, the DJI S900’s V

- type mixer design provides large amounts of propulsion while

improving power efficiency. From a safety perspective, the D JI flight controllers, when combined

with the A2, allows the S900 to remain stable even with the loss of a rotor. Additionally, the AS150

spark

- proof plug and an XT150 plug prevents creators from mixing up polarity when plugging in

the battery , thus preven ting short circuits.

The DJI S900 is designed for professional aerial photography and cinematography. It is user

friendly, safe, stabilized and easy to fly while its integrated design makes assembly and

configuration simple and fast. Retractable landing gear, vibration dampers, slightly angled arms

provide for a safe flight environment.

Below are the specifications for this sUAS model:

Frame:

Diagonal Wheelbase 900mm

Frame Arm Length 358mm

Frame Arm Weight 316g

Center Frame Diameter 272mm

Center Frame Weight 1185g

Landing Gear Size 460mm(Length)×450mm(Width)×360mm(Height)

Motor:

Stator Size 41×14mm

kV 400rpm/V

Max Power 500W

Weight (with Cooling Fan) 158g

ESC :

Working Current 40A

Working Voltage 6S LiPo

Signal Frequency 30Hz ~ 450Hz

Drive PWM Frequency 8KHz

Weight (with Radiators) 35gPetition for Section 333 Exemption

Leading Edge Aviation Resources, LLC

Page 13 of 21 Foldable Propeller (1552/1552R):

Material High strength performance engineered plastics

Size 15×5.2 inch

Weight 1 3g

Flight Parameters:

Takeoff Weight 4.7Kg ~ 8.2Kg

Total Weight 3.3Kg

Power Battery LiPo (6S, 10000mAh ~ 15000mAh, 15C(Min))

Max Power Consumption 3000W

Hovering Power Consumption 1000W (@6.8Kg Takeoff Weight)

Hovering Time 18min (@12000mAh & 6.8Kg Takeoff Weight)

Working Environment Temp

. - 10°C ~ 40°C

3D Robotics X8

- M

The 3D Robotics X8

- M is a quad

- boom, four (4) motor sUAS, capable of providing hover flight

in both the vertical and horizontal planes. As such, the 3D Robotics X8

- M provides excellent

maneuverability and ease of control for the PIC. The ease with which a PIC can control this sUAS

model is evidenced by the fact that the 3D Robotics X8

- M is commercially available for RC

hobbyists, requiring no training or experience pr ior to recreational usage.

In an effort to ensure the safety of each flight, L.E.A.R. chose the 3D Robotics X8

- M due to the

enhanced safety features found in this sUAS. The 3D Robotics X8

- M boasts various Return

- to

Home (RTH) modes which bring the sUAS b ack to the last recorded Home point, allowing for the

safe landing and return of the sUAS, should an unforeseen emergency arise. As such, the X8

- M

allows for Ground Station Signal RTL, Low Battery RTL, GPS Failsafe RTL, RC Controller

Failsafe, and an Altit ude Failsafe.

T he 3D Robotics X8

- M provides innovative features that culminate in a safe flying experience.

For example, the X8

- M uses failsafe technology designed to prevent a crash in the event of an

unsafe situation. All X8

- M models equipped with the ArduCopter firmware include a GPS failsafe

activated by default. 3DR RTF copters are also preset with radio control (RC) and low battery

failsafe behaviors. For instance, if the X8

- M loses GPS signal in a flight mode that requires GPS

(loiter, auto, return

- to

- launch, guided), it will land automatically, as indicated by a blinking blue

and yellow status LED and a high

- high

- high

- low tone on the controller. Furthermore, if the drone

loses contact with the RC transmitter, it will land automatically, as indicat ed by a blinking yellow

status LED on the controller. Beyond that, if the drone’s battery reaches 25% charge or less , the

drone will land automatically, indicated by a blinking yellow status LED and a quick repeating

tone. Lastly, if the battery runs low d uring a mission, the drone will return to the launch point

before landing.

Below are the specifications for this sUAS model:

3D Robotics X8

- M:

Aircraft dimensions: 13.7 in x 20.1 in x 11.8 in (35 cm x 51 cm x 30 cm)Petition for Section 333 Exemption

Leading Edge Aviation Resources, LLC

Page 14 of 21 Case dimensions: 60.7 i n x 14.5 in x 15.5 in (154 cm x 37 cm x 39 cm)

Weight: 7.7 lbs (3.5 kg)

Radio range: .6 miles* (1 km)

Flight time: 14 min (with ideal conditions)

Maximum operational wind speed: 25 mph (11 m/s)

Landing accuracy: 8.2 ft (2.5 m )

Recommended flight speed: 11 mph (5 m/s)

Autopilot: 3DR Pixhawk V2.4.5

Firmware: ArduCopter 3.2

GPS: 3DR u

- blox GPS with Compass

Telemetry radio: 3DR Radio v2 (915 mHz or 433 mHz)

Motors: SunnySky V2216

- 12 8 00 kV II

Frame: X

Propellers: APC 11X4.7 SFP (4), APC 11X4.7 SF (4)

Battery: 4S 10000 mAh 10C lithium polymer

Aircraft dimensions: 13.7 in x 20.1 in x 11.8 in (35 cm x 51 cm x 30 cm)

Case dimensions: 60.7 in x 14.5 in x 15.5 in (154 cm x 37 cm x 39 cm)

Proposed Flight Conditions and Operating Procedures

L.E.A.R.’s primary objective with every flight is the safe return of the above specified sUAS model

without injury to property or person. In order to obtain this desired objective, L.E.A.R. will abide

by the following flight and atmospheric conditions limitations wh en performing commercial flight

operations with the above specified sUAS models:

1. L.E.A.R. will not operate the sUAS model when weighing more than 55 pounds,

including payload.

2. L.E.A.R. will not operate the sUAS model at a speed exceeding 87 knots (100 m iles

per hour). L.E.A.R. will use either groundspeed or calibrated airspeed to determine

compliance with the 87 knot speed restriction.

3. L.E.A.R. will not operate the sUAS model at an altitude of more than 400 feet above

ground level (AGL). L.E.A.R. will monitor altitude in feet AGL via GPS

technology and monitoring

.

4. L.E.A.R. will only operate the sUAS modes within VLOS of the PIC at all times.

L.E.A.R. will require 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 or U.S. driver’s license.

5. L.E.A.R. requires the utilization of a visual observer (VO) on all commercial sUAS

flights. The sUAS model will be operated within VLOS of the PIC and VO at all

t imes. The VO may be used to satisfy the VLOS requirement as long as the PIC

always maintains VLOS capability. L.E.A.R. requires that the VO and PIC be able

to communicate verbally at all times. L.E.A.R. does not permit electronic

messaging or texting during flight operations. L.E.A.R. requires the sUAS PIC toPetition for Section 333 Exemption

Leading Edge Aviation Resources, LLC

Page 15 of 21 be designated before the flight and does not allow transfer of his or her designation

during the flight. The PIC must ensure that the VO can perform the duties required

of the VO.

6. L.E.A.R. requires that all operating documents (defined as the granted exemption

and all documents needed to operate the UAS model and conduct its operations in

accordance with all grants conditions and limitations) must b e accessible during

sUAS operations and made available to the Administrator upon reasonable request.

7. L.E.A.R. will require a functional test should any sUAS model undergo

maintenance or alterations that affect the sUAS model’s operation or flight

characteristics, e.g., replacement of a flight critical component, must undergo a

functional test flight prior to conducting further operations under this exemption.

L.E.A.R. requires that all function flights be conducted by a PIC wit h a VO and

remain at least 5 00 feet from other people. L.E.A.R. further requires that the

functional test flight be conducted in such a manner so as to not pose an undue

hazard to persons and property.

8. L.E.A.R. will be responsible for maintaining and ins pecting the sUAS model to

ensure that the sUAS model is in a condition for safe operation.

9. L.E.A.R. requires that, prior to each flight, the PIC conduct a pre

- flight inspection

and determine whether the sUAS model is in a condition for safe flight. L.E.A .R.

requires that the pre

- flight inspection must account for all potential discrepancies,

e.g., inoperable components, items, or equipment. Should the inspection reveal a

condition that affects the safe operation of the sUAS model

, L.E.A.R. prohibits the

a ircraft from operating until the necessary maintenance has been performed and the

sUAS is found to be in a condition for safe flight.

10. L.E.A.R. requires compliance with the component manufacturer’s maintenance,

overhaul, replacement, inspection, and life l imit requirements for the components

that combine to assemble the sUAS model.

11. L.E.A.R. requires compliance with all sUAS model manufacture’s safety bulletins

for the sUAS model

.

12. L.E.A.R. requires all sUAS PICs to hold either an airline transport, commercial,

private, recreational, or sport pilot certificate. Further, L.E.A.R. requires the PIC to

also hold a current FAA airman medical certificate or a valid U.S. driver’s license

issued by a state, the Distri ct of Columbia, Puerto Rico, a territory, a possession, or

the Federal Government. The PIC must also meet the flight review requirements

specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her

pilot certificate.

13. L.E.A.R. prohib its any PIC to operate the sUAS model unless the PIC demonstrates

the ability to safely operate the sUAS model in a manner consistent with how the

sUAS will be operated under this petition for exemption, including evasive andPetition for Section 333 Exemption

Leading Edge Aviation Resources, LLC

Page 16 of 21 emergency maneuvers and mainta ining appropriate distances from persons, vessels,

vehicles and structures. To that end, L.E.A.R. requires the PIC ’s qualification flight

hours and currency to be logged in a manner consistent with 14 CFR § 61.51(b).

14. L.E.A.R. prohibits flight operations of the sUAS model during night , as defined in

14 CFR § 1.1. All flight operations will be conducted under visual meteorological

conditions (VMC). L.E.A.R. will not allow the sUAS model to be flown during

special visual flight rules (SVFR).

15. L.E.A.R. will n ot operate the sUAS model within 5 nautical miles of an airport

reference point (ARP) as denoted in the current FAA Airport/Facility Directory

(AFD) or for airports not denoted with an ARP, the center of the airport symbol as

denoted on the current FAA

- pub lished aeronautical chart, unless a letter of

agreement with that airport’s management is obtained or otherwise permitted by a

COA issued to the exemption holder. L.E.A.R. will make the letter of agreement

with the airport management available to the Admin istrator or any law enforcement

official upon request.

16. L.E.A.R. will operate the sUAS model at least 500 feet below and/ or no more than

2,000 feet horizontally from a cloud. L.E.A.R. will not operate the sUAS model

when visibility is less than 3 statute miles.

17. L.E.A.R. requires the sUAS model to return to a pre

- determined location within the

private or controlled

- access property s hould the sUAS model lose communications

or lose its GPS signal.

18. L.E.A.R. requires the PIC of any sUAS model to abort the flight in the event of

unpredicted obstacles or emergencies.

19. L.E.A.R. prohibits the PIC of any sUAS model from beginning a flight unless

(considering wind and forecast weather conditions) there is enough available power

for the sUAS model to conduct the intended operation and to operate after that for

at least 5 minutes or with the reserve power recommended by the manufacturer if

greater.

20. L.E.A.R. requires that all documents used to ensure safe operation and flight of the

sUAS model and any documents required under 14 CFR §§ 91.9 and 91.203 to be

available to the PIC at the Ground Control Station of the sUAS model any time the

aircraft are operating. L.E.A.R. will make these documents available to the

Administrator or any law enforce ment official upon reasonable request.

21. L.E.A.R. requires that during all flights, the sUAS model PIC remain clear and give

way to all manned aviation operations and activities at all times.

22. L.E.A.R. prohibits the PIC of any sUAS model from operating th e sUAS model

from any moving device or vehicle.Petition for Section 333 Exemption

Leading Edge Aviation Resources, LLC

Page 17 of 21 23. L.E.A.R. requires all flight operations of all sUAS models to be conducted at least

500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating

persons from the sUAS and/or debris in the event of an accident. L.E.A.R.

will ensure that nonparticipating persons remain under such protection. If a

situation arises where nonparticipating persons leave such pr otection and

are within 500 feet of the sUAS, L.E.A.R. requires flight operations to cease

immediately in a manner ensuring the safety of nonparticipating persons;

and

b. The owner/controller of any vessels, vehicles or structures has granted

permission for operating closer to those objects 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 un due hazard.

24. L.E.A.R. will operate all sUAS flights over private or controlled

- access property

with permission from the property owner/controller or authorized representative.

L.E.A.R. will obtain permission from the property owner/controller or authorize d

representative prior to each flight to be conducted.

PRIVACY

L.E.A.R. use of the aforementioned sUAS models will not implicate any privacy concerns. Since

L.E.A.R. will only commercially operate the sUAS model at the request of the property and/or

business owner(s), L.E.A.R. will have the express consent and permission of the property and/or

business owner(s) prior to flying over private property. L.E.A.R.’s use of the aforementioned

sUAS models poses no greater privacy concerns than the use of trad itional fixed wing or rotorcraft

aircraft for similar commercial operations. Should L.E.A.R.’s commercial sUAS activity require

aerial based photographic and video imagery , i mages taken will be of individuals who have

consented to being photographed/ filmed or otherwise have agreed to be in the area where aerial

photographic or video imagery will take place

.

PUBLIC INTEREST AND SAFETY

Unlike traditional fixed wing or rotorcraft aircraft, the use of the above specified sUAS models for

the aforemention ed reasons promotes public interest and safety. Whereas traditional fixed wing or

rotorcraft aircraft are large, heavy, noisy, require flammable fuels and manned operators (placing

the pilot’s life in jeopardy should there be an emergency), th ese sUAS mode l s are small, light,

quite, and do not require flammable fuels or a manned operator (i.e. not risking human life for the

purpose of operation).

The use of L.E.A.R.’s sUAS models also benefits the public from a safety perspective since th ese

sUAS model s do not run on fossil fuels. Since th ese sUAS model s are battery powered, its use

over the traditional fixed wing or rotorcraft aircraft will be more environmentally and ecologicallyPetition for Section 333 Exemption

Leading Edge Aviation Resources, LLC

Page 18 of 21 friendly. In addition to the non

- use of flammable fuels, given the extrem e lightness of th ese sUAS

model s , should an emergency result in a forced landing, injury to property or persons would be

negligible compared to the catastrophic injury to property or persons that would result in an

emergency landing of a traditional fixed wing or rotorcraft aircraft.

Apart from the added safety benefits of sUAS flight operations, the use of the aforementioned

sUAS models for the above noted aerial based applications creates new economic opportunities

that could fuel the continued growth o f aviation and aviation related interests. Consequently, the

public will benefit from the use of th ese sUAS model s for commercial purposes as companies like

L.E.A.R. will provide new jobs and economic opportunities, fueling innovation and creativity.

REG ULATIONS FROM WHICH EXEMPTION IS REQUESTED

14 CFR §§ 61.23(a) and (c): Medical Certificates Requirement and Duration

L.E.A.R. requests exemption from 14 CFR §§ 61.23(a) and (c) which provides for certain flight

operations requiring medical certificates. L.E.A.R.’s petition for exemption provides an equivalent

level of safety in that L.E.A.R. would require a sUAS PIC to hold either a current medical

certificate, of any class, or a valid U.S. Driver’s License. L.E.A.R.’s petition for exemption

provides an e quivalent level of safety as provided in 14 C.F.R. §§61.23(a) and (c).

14 C.F.R. §§ 61.101(e)(4) and (5): Recreational Pilot Privileges and Limitations ; 14 C.F.R. §

61.113(a): Private Pilot Privileges and Limitations: Pilot in Command ; and 14 C.F.R.

§61. 315(a): What Are The Privileges and Limits of My Sport Pilot Certificate?

L.E.A.R. requests exemption from 14 C.F.R. §§ 61.101(e)(4) and (5) which prohibits recreational

pilots from receiving compensation for hire or providing flight services in furtherance of a

business, respectively. In addition, L.E.A.R. requests exemption from 14 C.F .R. §61.113(a), which

prohibits a certificated private pilot from receiving compensation or flying for hire when acting as

PIC; and from 14 C.F.R. §61.315(a), which provides the holder of a sport pilot certificate may

only act as pilot in command of a ligh t

- sport aircraft.

L.E.A.R.’s petition for exemption provides an equivalent level of safety in that L.E.A.R. requires

the sUAS PIC, at the bare minimum, to hold the privileges of a sport pilot certificate under 14

C.F.R. §61 Subpart J, hold either a medica l certificate or valid U.S. Driver’s License, and to

demonstrate proficiency in the PIC’s ability to safely operate the sUAS model in a manner

consistent with how the sUAS will be operated under this petition for exemption.

Distinct comparisons between the commercial activities of L.E.A.R. and other businesses

operating traditional fixed wing or rotorcraft aircraft expose the unnecessary limitations placed

upon sport, recreational and private certificated pilots when consider ing PIC privileges of

commercial sUAS flight operations. Whereas requiring pilots of traditional fixed wing and

rotorcraft aircraft to hold commercial and Airline Transport Pilot (ATP) ratings ensures that the

pilots possess the necessary skills, training and experience to safely transport persons and/or cargo

from the point of departure to the intended point of destination, the same correlation for sUAS

pilots and should not apply to the sUAS flight operations of L.E.A.R

.Petition for Section 333 Exemption

Leading Edge Aviation Resources, LLC

Page 19 of 21 In the case of L.E.A.R.’s sUAS f light operations, no persons or third

- party cargo will be carried

by the sUAS model during L.E.A.R.’s aerial based commercial operations. Unlike traditional fixed

wing or rotorcraft aircraft, which must traverse over a greater distance, greater amount of p roperty,

and a greater amount of people in order to get from the point of departure to the intended point of

destination, L.E.A.R.’s sUAS will only fly over property authorized by L.E.A.R.’s clients. In other

words, the sUAS model will not have to originat e flight from a different location and traverse over

the properties of disinterested parties in order to fulfill the purpose of L.E.A.R.’s commercial flight

operations. As such, the risk of injury to disinterested parties is substantially decreased by the use

of a sUAS for aerial based commercial applications described within this petition.

Consequently, L.E.A.R.’s requirement that the sUAS PIC hold, at least, a sport pilot certificate

provides an equivalent level of safety to the requirement that a comme rcial or ATP rated pilot

transport persons and/or cargo for hire in manned aircraft.

14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

L.E.A.R. requests an exemption from 14 C.F.R. §91.7(a) which prohibits the operation of civil

aircraft unless it is i n airworthy condition. As there will be no airworthiness certificate issued for

L.E.A.R.’s sUAS model s

, no standard will exist for determining airworthiness. In any event,

L.E.A.R.’s proposed Flight Conditions and Operating Procedure will ensure an equival ent level of

safety with 14 C.F.R. §91.7(a).

14 C.F.R. § 91.119(c): Minimum Safe Altitude: General

L.E.A.R. requests an exemption from 14 C.F.R §91.119(c) which provides that except when

necessary for takeoff or landing, no person may operate an aircraft below an altitude of 500 feet

above the surface. Furthermore, this section provides that an aircraft may not be operated closer

than 500 feet to any person, vessel, vehicle, or structure. L.E.A.R.’s petition requests that the DJI

Inspire 1 be flown at an altitude no higher than 400 feet AGL and, when complying with the

conditions set forth in §23(b) of L.E.A.R.’s Flight Conditions and Operating Procedures, at

distances closer than 500 feet from any person, vessel, vehicle, or structure.

The requirement that the sUAS models maintain 400 feet or less AGL helps ensure that signal

connectivity between the transmitte r and receiver will not be lost. In addition, this height restriction

ensures that the PIC will be able to maintain VLOS while simultaneously limiting the possibility

of the sUAS model’s interference with other NAS traffic. Moreover, this requirement ensur es at

least 100 feet of vertical separation between sUAS commercial operators and manned aircraft

operating within the NAS.

Traditional principles requiring a 500 foot AGL minimum for fixed

- wing or rotorcraft aircraft

stemmed from a desire to protect the public should the need for a forced landing arise due to an

unforeseen emergency situation or loss of power. These same concerns are not present with

L.E.A.R.’s sUAS model as they are extremely lightweight and small. Any injury to property or

person would be negligible when compared to the catastrophic damage that a fixed wing or

rotorcraft aircraft would inflict due to a forced landing. Consequently, L.E.A.R.’s Flight

Conditions and Operating Procedures provide for an equivalent level of safety when compar ed to

14 C.F.R §91.119(c).Petition for Section 333 Exemption

Leading Edge Aviation Resources, LLC

Page 20 of 21 14 C.F.R. §91.121: Altimeter Settings

L.E.A.R. requests exemption from 14 C.F.R. §91.121 which provides guidelines for the use of

altimeter settings while operating an aircraft. L.E.A.R.’s petition for exemption provides an

equ ivalent level of safety such that the sUAS models PIC will be able to determine the AGL height

of the sUAS model due to GPS technology. The AGL height of the sUAS will be displayed for the

PIC during all flight operations. As such, the PIC will be able to maintain the requirement that the

sUAS models fly no higher than 400 feet AGL during all flight operations.

14 C.F.R. §91.151(a)(1): Fuel Requirements For Flight In VFR Conditions

L.E.A.R. requests exemption from 14 C.F.R. §91.151(a)( 1) which provides that no person may

begin a flight in an airplane under VFR conditions with less than 30 minutes of reserve fuel.

L.E.A.R.’s petition for exemption provides an equivalent level of safety due to L.E.A.R.’s

prohibition against the PIC from b eginning a flight unless (considering wind and forecast weather

conditions) there is enough available power for the sUAS model to conduct the intended operation

and to operate after that for at least 5 minutes or with the reserve power recommended by the

m anufacturer if greater.

Given the design and technology of aforementioned sUAS models, L.E.A.R.’s PIC will have

access to all relevant information concerning the sUAS model’s battery life. The PIC will be able

to make an accurate determination as to whet her the PIC can comply with L.E.A.R. ‘s “fuel”

requirements for each flight. Consequently, L.E.A.R.’s Flight Conditions and Operating

Procedures provide for an equivalent level of safety when compared to 14 C.F.R §91.151(a)(1).

14 C.F.R. §91.405(a): Maintenance Required ; 14 C.F.R. §91.407(a)(1): Operation After

Maintenance, Preventative Maintenance, Rebuilding, Or Alteration ; 14 C.F.R. §§

91.409(a)(1) and (2): Inspections ; 14 C.F.R. 91.417(a) and (b): Maintenance Records

L.E.A.R. requests exemption f rom the following F.A.Rs: 14 C.F.R. §91.405(a), which provides

the owner or operator of aircraft shall have the aircraft inspected pursuant to Subpart E of 14 C.F.R;

14 C.F.R. §91.407(a)(1), which provides that no person may operate any aircraft having und ergone

preventive maintenance unless approved for return to service by a person authorized under §43.7;

14 C.F.R. §§91.409(a)(1) and (2), which provides that no person may operate an aircraft within

the preceding 12 calendar months unless an annual inspec tion has been performed; and 14 C.F.R.

§§91.417(a) and (b), which provides for the recording of an aircraft’s maintenance if the aircraft

holds an airworthiness certificate.

L.E.A.R.’s petition for exemption provides an equivalent level of safety since L. E.A.R. require s

compliance with the sUAS manufacturer’s maintenance, overhaul, replacement, inspection, and

life limit requirements for the aforementioned sUAS models . Due to the nature of a sUAS,

compliance with certain maintenance requirements under Subp art E of 14 C.F.R. are either

impossible or cost prohibitive to implement when applied to a sUAS. As such, L.E.A.R. should be

exempt from these regulations as L.E.A.R.’s Flight Conditions and Operating Procedures provide

for an equivalent level of safety when compared to these F.A.R.s.