1 UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON , DC

IN THE MATTER OF THE PETITION FOR EXEM PTION OF:

**SNAPPY DRONE PRODUCTIONS**

**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 A) Yuneec Typhoon Q500 4K, b) DJI PHANTOM 2 VISION+, and c) DJI PHANTOM 3 UNMANNED AIRCRAFT SYSTEM**  **S PURSUANT TO SECTION 333 OF THE FAA**

**MODERNIZATION AND REFORM ACT OF 2012**

Submitted on 1 2

- 14

- 2015

Snappy Drone Production s David J. Martel, Owner Kevin C. Barker, Owner 6417 Emerson Gardens St Las Vegas, NV 89166 (702) 265

- 28432 UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON , DC

**SUMMARY** Snappy Drone Productions seeks exemption form the requirements of 14 C.F.R § 6 1

. 113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) , to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Snappy Drone Productions to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial photography and video for real estate videography and photography, wedding videography, special events, film videography on movie sets and landscaping in and throughout the United States.
**INTRODUCTION OF PETITIONER** Snappy Drone Productions is an experienced company which specializes in aerial videography and photography. It is the mission of Snappy Drone Productions to provide our clients with the expertise and knowledge in all aspects in video, picture, and audio production

. This is provided by the most advanced technologies and solutions available. With the use of advan ced technologies, we are able to provide our clients with the highest quality digital content in use of their multimedia needs. High quality videography and photography from variable low level angles using the UAS’s specified are far more desired and effective than ground

- based imagery. The use of UAS’s is also safer than utilizing manned aircraft of significantly greater proportions, carrying crew and flammable fuel. Snappy Drone Productions has over 5 years of recreational/hobby experience in all aspects of remote control aircraft operation and approximately 1 year recreational/hobby
e xperience in all aspects of aerial videography and photography. Snappy Drone Productions wants to provide the highest quality aerial videography and photography imaging for a variety of public, commercial, and residential uses to include but not limited to:

 Motion Picture Videography

 Real Estate Videography and Photography

 Wedding Videography and Photography

 Search and Rescue

 Equipment Inspections

 Land Survey & Appraisals

 Roof Inspections

 Public Service Announcements (PSA’s)

 Special Events

 Construction Site Inspections3 UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON , DC

**Background** Unmanned Aircraft Systems: Yuneec Typhoon Q500 4K, DJI Phantom 2 Vision +, and DJI Phantom 3 UAS’s Snappy Drone Productions seeks an exemption to operate the Yuneec and DJI systems for compensation or hire within the NAS. The Yuneec Typhoon Q500 4K, DJI Phantom 2 Vision +, and DJI Phantom 3 are vertical takeoff and landing (VTOL) Unmanned Aircraft Syste ms (UAS’s) with a Ground Control Station (GCS) utilizing electronic tablets, smart phone systems or Capacitive Multi

-touch 5.5” LCD Screen on ST10+ remote. The Yuneec Typhoon Q500 4K has a maximum gross weight of approximately (60.0 oz) 3 pounds 75 ounces, while having a length of (420mm) 16.5 inches, width of (525mm) 22.2 inches, height of (210mm) 8.3 inches, and a maximum speed of approximately 1 4 knots/ 19 knots (Angle Mode/Follow Me Mode) . The DJI Phantom 2 Vision + has a maximum gross weight of approximately 2 pounds 11ounces, while having a length of 16 inches, width of 16 inches, height of 8 inches, and a maximum speed of approximately 29 knots. The DJI Phantom 3 has a maximum gross weight of approximately 2 pounds 13 ounces, while having a len gth of 16 inches, width of 16 inches, height of 8 inches, and a maximum speed of approximately 31 knots. The Yuneec Typhoon Q500 4K, DJI Phantom 2 Vision +, and DJI Phantom 3 UAS’s are equipped with four main rotors; driven by Lithium Polymer battery powered electric motors. The Yuneec Typhoon Q500 4K, DJI Phantom 2 Vision +, and DJI Phantom 3 UAS’s that will be operated by Snappy Drone Productions 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

.4 UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON , DC

**BASIS FOR PETITION** Petitioner, Snappy Drone Productions, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R § 11.61 ) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate the Yuneec Typhoon Q500 4K, DJI Phantom 2 Vision +, and DJI Phantom 3 UAS’s in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R § 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b)

. In consideration of the speed, weight, si ze, and limited operating area associated with the unmanned aircraft and its operation, Snappy Drone Productions meets the conditions of FMRA Section 333 and therefore, will not require airworthiness certification in accordance with 14 C.F.R Part 21, Subpa rt H. Accordingly, Snappy Drone Productions, request 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 and airworthiness certi ficate. Snappy Drone Productions however understands the importance with aircraft maintenance and safety. Snappy Drone Productions submits that the requested relief is proper due to an equivalent level of safety will be ensured. Prior to each flight, the Pilot in Command (PIC) will ensure that the UAS is in working order and perform any required maintenance. A log of any maintenance performed will be kept and available for inspection. Snappy Drone Productions will only use experienced personnel or technicians to perform mainten ance, alterations, or preventive maintenance on the UAS’s using the methods, techniques, and practices prescribed in the operating documents (Instruction Manuals, Monthly Maintenance Logs). Relief from certain requirements of Section 61.113(a) & (b), entit led Private Pilot Privileges and Limitation: Pilot in Command , is requested by Snappy Drone Productions to the extent necessary to allow a Pilot in Command (PIC) holding a sport pi l ot, private pilot or high er level certificate, as well as an airman medical certificate, and who has demonstrated by meeting minimum flight hour and currency requirements, that the PIC is able to safely operate the Yuneec Typhoon Q500 4K, DJI Phantom 2 Vision +, DJI Phantom 3 UAS’s in a manner consistent with this exemption, incl uding evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.5 UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON , DC Snappy Drone Productions also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings, as the Yuneec Typhoon Q500 4K, DJI Phantom 2 Vision +, and DJI Phantom 3 UAS’s will not have a typical barometric altimeter onboard. However, altitude information of the UAS’s will be provided to the PIC via Global Positioning System (GPS) equipment and radio communica tion telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with Snappy Drone Productions operation of the UAS’s within Visual Line of Sight (VLS), at or below 2 00’ AGL, wil l ensure a level of safety equivalent to Section 91.121. Snappy Drone Productions seeks an exemption from the requirements of Section 91.151(b), entitled Fuel Requirements for flight in VFR conditions. Snappy Drone Productions submits that safety will not be affected by operation of the UAS’s during daylight hours in Visual Meteorological conditions (VMC) under Visual Flight Rules (VFR), with enough battery power to fly for a total duration of approximately 13 minutes to the first point of intended landing and assuming normal cruising speed. After that will fly for at least 5 minutes.

**Snappy Drone Productions request would be in the public interest; that is, how it would benefit the public as a whole.**  Granting the petitioner will further the public interest by allowing Snappy Drone Productions to safely, efficiently, and economically perform aerial videography and photography of , movie scenes, weddings, real estate, assist in search and rescue, land and building surveying/appraisals, construction sites, roo f ins pections, and landscape over certain areas of the United States. Additionally, the use of the Yuneec Q500 4K, DJI Phantom 2 Vision +, and DJI Phantom 3 UAS’s will decrease congestion of the NAS, reduce pollution, and provide significant benefits to th e economy.6 UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON , DC

**Benefits from decreased congestion of the NAS** 

**.** The UAS’s are all battery powered and serve as a safe, economical, and efficient alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of the UAS’s would reduce the amount of manned aircraft in the NAS, reduce noise, along with air pollution, as well as increase the safety of life and property in the air and ground. By reducing the number of manned aircraft operating in the NAS, congestion in and around area airports would be significantly reduced and providing for a safer NAS. The UAS’s to be utilized do not require an airport to take off and land for aer ial videography or photography. **Benefits to the public from the safety and efficiency of the Yuneec Typhoon Q500 4K, DJI Phantom 2 Vision +, and DJI Phantom 3.**  Conducting aerial acquisitions with the UAS’s instead of manned aircraft, will greatly benefit the public drastically reducing the levels of air and noise pollution generated from manned aircraft. Allowing commercial operations of UAS’s in the real estate and film industry will enhance the safety by reducing the risk. The use of conventional film op erations, using turbine aircraft, operate at low altitudes and present the risks associated with aircraft that weigh around 4,000 pounds and carry large amounts of Jet A fuel. These Aircraft must fly to and from each film location, but a UAS weighing fewer than 55 pounds and powered by batteries eliminates virtually all of that risk given the small size and lack of combustible fuel. The UAS is carried and not flown to the film location. The UAS carries no passengers or crew and will not expose them or the p ublic to the risks associated with manned aircraft. **No Privacy issues** All flights will occur over private or controlled accessed areas with the property owner’s prior consent and knowledge. Filming will be only of people who have given their consent or oth erwise have agreed to be in the area where filming will be taking place. **Technical Specifications of the Yuneec Typhoon Q500 4K, DJI Phantom 2 Vision +, and DJI Phantom 3 UAS’s**  The technical specifications of the Yuneec Typhoon Q500 4K, DJI Phantom 2 Visio n +, and DJI Phantom 3 UAS’s are set forth by Yuneec Typhoon Q500 4K, DJI Phantom 2 Vision +, and DJI Phantom 3 Specifications and Data Sheet, which can be provided by Snappy Drone Productions upon request.7 UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON , DC
**The Yuneec Typhoon Q500 4K, DJI Phantom 2 Vision**  **+, and DJI Phantom 3 UAS’s are**  **designed for automatic return to home point or hover in the event of loss of the control link or navigation.**  When the Control Link is lost, the Yuneec Typhoon Q500 4K, DJI Phantom 2 Vision +, and DJI Phantom 3 UAS’s will rema in stationary, in flight, for 3 seconds or more. If after that time the Yuneec Typhoon Q500 4K, DJI Phantom 2 Vision +, and DJI Phantom 3 do not reacquire control link data from the GCS, the UAS’s will assume that the control link is lost and the UAS’s will return to the home position (i.e. Failsafe mode) via GPS and will descend to the takeoff position and shutdown. **Flights of the Yuneec T** **yphoon Q500 4K, DJI Phantom 2 Vision +, and DJI Phantom 3 UAS’s will be conducted pursuant to specific operating limitations.**  Snappy Drone Productions proposes to commercially operate the Yuneec Typhoon Q500 4K, DJI Phantom 2 Vision +, and DJI Phantom 3 UAS’s for the special purpose of conducting and obtaining video and photography over certain areas of the United States, pursuant to the following specifications and operating limitations:
1. Operations granted by these exemptions will be limited to the followi ng aircraft described in the operating documents, rotorcraft (Multicopter) UAS’s weighing less than 55 pounds maximum gross weight: Yuneec Typhoon Q500 4K, DJI Phantom 2 Vision +, and DJI Phantom 3 Unmanned Aircraft Systems. Operations of any other aircra ft will require a petition to amend this grant or a new petition

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

3. The UAS’s must be operated at an altitude of no more than 200 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved by the ATC. All altitudes reported to ATC must be in feet AGL.

4. UAS’s will not be flown at an indicated airspeed exceeding 20 knots.

5. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted.8 UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON , DC

6. The UAS’s must be operated within visual line of sight of the PIC at all times. This requires the PIC to be able to use human vision unaided by a ny device other than corrective lenses, as specified on the PIC’s FAA issued airman medical certificate.

7. The SO or PIC must not perform any other duties while operating any of the UAS’ s. The SO’s duties are but not limited to , assisting the PIC with seei ng and avoiding other air traffic and other ground based obstacles/obstructions and is not permitted to operate the camera or other instruments.

8. All operations will utilize a SO. The SO may be used to satisfy the VLOS requirements as long as the PIC alwa ys maintains VLOS capability. The PIC must be able to communicate with the SO at all times verbally. This will not be done by electronic messaging or texting during flight operations. The PIC must be designated prior to flight and cannot be switched during the duration of operations. The PIC must insure the SO can and is capable of performing the functions prescribed in the operating document prior to operations.

9. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of flight critical components, must undergo a functional test flight. The PIC who conducts that functional test flight must document in the aircraft maintenance log.

10. Prior to flight, the PIC will inspect the UAS to ensure that it is in a condition for safe flight. The PIC will review all maintenance logs and flight logs prior to flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating and required maintenance must be performed. Not until the aircraft is found to be in a condition for safe flight will the aircraft be flown. The ground control station must be included in preflight inspections and found in flight condition. All maintenance logs will be updated with maintenance conducted.9 UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON , DC

11. The documents and the grant of exemption must be accessible during the UAS operation and made available to the Administrator up 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 limitation contained in the grant of exemption take precedence and mu st be followed. The operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator upon request. If t he operator determines that any update or revisions 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.

12. The operator must follow the UAS’s manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements.

13. Each UAS that operates under this exemption must comply with all manufacturer safety bulletins.

14. Pre

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

15. All corrective actions taken against any discrepancies discovered between or during inspections must be documented on the aircrafts records.

16. The PIC must possess at least a sports pilot’s certificate and at least a current third class medical certificate.10 UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON , DC

17. 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 aircrafts records, including total time in service, description of work accomplished, and the signature of the authorized person returning the UAS to service.

18. The UAS will not be operated within 5 nautical mil es of an airport reference point as denoted on a current FAA published aeronautical chart unless a letter of agreement with that airports’ management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request.

19. The UAS will not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statut e miles from the PIC.

20. No UAS operation will be conducted during night, as defined in 14 C.F.R. § 1.1. All operations will be conducted under visual meteorological conditions.

21. No PIC will be permitted to operate unless the PIC meets the operator’s qualification criteria and demonstrated the ability to safely operate the UAS in a manner consistent with hoe the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, veh icles, and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator’s PICs are permitted under the terms of the exemption. During training, proficiency, an d experience

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

22. PIC is prohibited from beginning a flight unless there is enough power to fly normal cruising speed to the intended landing point and land the UAS with 25% battery power remaining

.11 UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON , DC

23. PIC must consider wind and forecast weather conditions prior to flight.

24. If communication is lost or GPS signal is lost, it must return to a predetermined location within the planned operating area and land or be recovered in accordance with the operating documents.

25. Flight must be aborted in the event of unpredicted obstacl e or emergency in accordance with the operating documents.

26. All UAS’s operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (N

Number) markings in accordance with 14 C.F.R. part 45, Subpart C,. Markings must be as large as practicable.

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

28. The PIC must ensure the UAS remains clear and yield the right of way to all manned aircraft and activities at all times.

29. The UAS may not be operate from any moving vehicle or device.

30. Documents required few er 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 in operation. These documents must be made available to the Administrator or any Law Enforcement official upon request.

31. Operations will be conducted over private or controlled access property with the permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducte d.12 UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON , DC

32. Any and all incidents, accidents, or if flight operation transgress the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA’s UAS Integration Office (AFS

- 80) within 24hrs. Accidents will b e reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB website: www.NTSB.com

33. All flight operations must be conducted with an established safety zone prior to flight. This safety zone will be established by the PIC and maintained by the PIC and SO for the duration of flight operations. I f for any reason a situation arises where a nonparticipant leaves protection and enters the safety zone, the PIC is to immediately cease fli ght operations.

**Any additional information, views, or arguments available to support Snappy Drone Productions request.**  This petition is made pursuant to the FAA Modernization and Reform Act 2012 (FMRA) Section 333, which directs the Secretary of Transport ation to determine if certain UAS may operate safely in the NAS. As such, Snappy Drone Productions request for exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification. As discuss ed in detail above, Snappy Drone Productions will operate the Yuneec Typhoon Q500 4K, DJI Phantom 2 Vision +, and DJI Phantom 3 UAS’s safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national se curity. **A brief description of the nature of the exemption Snappy Drone Productions seeks:** This exemption will permit Snappy Drone Productions to commercially operate an Unmanned Aircraft System (UAS) in the NAS for the purpose of conducting aerial video a nd photography over certain areas of the United States.13 UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON , DC
**Conclusion** Snappy Drone Productions seeks an exemption pursuant to 14 C.F.R. § 11.61 and section 333 of the FAA Modernization and Reform Act of 2012, which will permit safe operation of the Yunee c Typhoon Q500 4K, DJI Phantom 2 Vision +, and DJI Phantom 3 UAS’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 Snappy drone Productions to safely, efficiently, and economically operate the Yune ec Typhoon Q500 4K, DJI Phantom 2 Vision +, and DJI Phantom 3 UAS’s commercially within the NAS. In accordance with the Federal Aviation Regulations and the FAA Modernization Reform Act of 2012, Section 333, Snappy Drone Productions respectfully requests t hat the Administrator grant this petition for an exemption form 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 Snappy Drone Productions to operate the Yuneec Typhoon Q500 4K, DJI Phantom 2 Vision +, and DJI Phantom 3 UAS’s commercially for the purposes of conducting aerial video and photography over certain areas of the United States.

December 14, 2015 Respectfully Submitted Snappy Drone Productions

David J. Martel, Owner

Kevin C. Barker, Owner 6417 Emerson Gardens St Las Vegas, NV 89166 (702) 265

- 2843