1

January 22 , 2016

Attn: U. S. Department of Transportation Docket Operations West Building Ground Floor, Room w12

- 140 1200 New Jersey Ave, SE Washington, DC 20590

RE: PLATINUM DRONE SERVICES, LLC REQUEST AN EXEMPTION 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 THE DJI PHANTOM 2, DJI PHANTOM 3, 3DR SOLO, YUNEEC Q500+, AND T HE DJI INSPIRE 1 UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)

Tyler Delino
President Platinum Drone Services, LLC 71 Preston Drive, Gillette, NJ 07933
908

- 377

- 2649 Tyler.delin

o @gmail.co m3 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 Modernization and Reform Act of 2012 (FMRA)
SO Safety Observer
SOP Standard Operating Procedures
UA Unmanned Aircraft

UAS Unmanned Aircraft System
VFR Visual Flight Rules
VLOS Visual Line of Site
VMC Visual Meteorological Conditions
VTOL Vertical Takeoff and Landing4 SUMMARY Platinum Drone Services, LLC 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 ( THE DJI PHANTOM 2, DJI PHANTOM 3, 3DR SOLO, YUNEE C Q500+, AND THE DJI INSPIRE 1 ) pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Platinum Drone Services, LLC to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting ae rial video and photography of construction sites, residential and commercial real estate, civil landscapes and events over certain areas of the United States. Because this petition is similar in all material respects to previously

- granted Section 333 petit ions, Platinum Drone Services, LLC requests expedited approval pursuant to the FAA's summary grant process.

I

, Tyler Delino, owner of Platinum Drone Services, LLC have over ten years with expertise and knowledge in video and multimedia marketing, advertising, public relations and training using
advanced videography

. I Tyler Delino am also a USPA member (NO. 244706) and D

- Licensed Sky Diver : D

- 34903 with my Coach Rating. I understand the importance of safety and flight patterns. I understand the importance of cloud regulations, wind strength, area objects that could cause potential harm and how to avoid them. I am familiar with many FAA regul ations relative to this exemption

. The objective of Platinum Drone Services, LLC and our Unmanned Aircraft System ( THE DJI PHANTOM 2, DJI PHANTOM 3, 3DR SOLO, YUNEEC Q500+, AND THE DJI
INSPIRE 1 ) and aerial operations is to provide a more affordable, high

- quality production system for a variety of commercial, public, and residential uses, specifically targeting

 Construction sites

 Real

- estate

 Outdoor activities

 Landscaping

 Special event coverage

 Hotels

 Golf Courses

To start it will solely be I , Tyler De lino operating the UAS which has already been registered
with FAA

. In time I will hire a small staff with highly regulated training and supervising before any flight under Platinum Drone Services, LLC will occur.

BACKGROUND

Unmanned Aircraft Systems: THE DJI PHANTOM 2, DJI PHANTOM 3, 3DR SOLO, YUNEEC Q500+, AND THE DJI INSPIRE 1 UAS Platinum Drone Services, LLC seeks an exemption to operate THE DJI PHANTOM 2, DJI PHANTOM 3, 3DR SOLO, YUNEEC Q500+, AND THE DJI INSPIRE 1 system for compensation or hire within the NAS. THE DJI PHANTOM 2, DJI PHANTOM 3, 3DR SOLO, YUNEEC Q500+, AND
THE DJI INSPIRE 1 are all vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. All of these UAS’s are well below the 55 pound criteria. The UAS is equipped with four main rotors; driven b y Lithium Polymer battery powered electric motors.5

The UAS that will be operated by Platinum Drone Services, LLC will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft , as well as 14 C.F.R Part 47, Aircraft Registratio n , and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking

.

BASIS FOR PETITION Petitioner, Platinum Drone Services, LLC , 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 commercial ly operate the UAS in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

In consideration of the s peed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, Platinum Drone Services, LLC 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, Platinum Drone Services, LLC 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 w ith an airworthiness certificate.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges
and limitations: Pilot in command , is requested by Platinum Drone Services, LLC to the extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an airman medical certificate, and who has demonstrated, by meeting minimum flight

hour and currency requirements, that the PIC is able to safely operate the UAS in a manner

cons istent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

Platinum Drone Services, LLC seeks relief from Section 91.7(a), entitled Civil aircraft
airworthines s , because the UAS do es not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Platinum Drone Services, LLC submits that they will ensure that the UAS is in an airworthy condition, prior to every flight, by deter mining that the UAS are in complia nce with the operating documents

.6

Platinum Drone Services, LLC also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , as the UAS will not have a typical barometric altimeter onboard. However, altitude information of the 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 monitoring of the flight path. This altitude information, combined with Platinum Drone Services, LLC operation of the UAS within visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.12 1.

Additionally, Platinum Drone Services, LLC seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions

. Platinum Drone Services, LLC submits that safety will not be affected by operation of the UAS during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a to tal duration of approximately 20 minutes. Battery po wer indicators are also able to show exactly how much battery power is left, as well as how much time is needed to return safely back to point of take off.

In accordance with 14 C.F.R. § 11.81, Platinum Drone Services, LLC provides the following
informatio n 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:

Tyler Delino
Owner Platinum Drone Services, LLC 71 Preston Drive, Gillette, NJ 07933
908

- 377

- 2649 Tyler. delino@gmail.com7

B. The Specific Sections Of 14 C.F.R. From Which Platinum Drone Services, LLC Seeks Exemption.

1. Platinum Drone Services, LLC Seeks Exemption From The Requirements Of Section 61.113(a) And (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command

, subsections (a) and (b) prescribe the following, in relevant part:

(a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, 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 is only incidental to that business or employment; and

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

2. Platinum Drone Services, LLC 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. Platinum Drone Services, LLC Seeks Exemption From The Requirements Of Section
9 1.121.

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

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

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

--

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

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

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure.8

4. Platinum Drone Services, LLC 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 enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.

5. Platinum Drone Services, LLC 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 pr escribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.]

6. Platinum Drone Services, LLC Seeks Exemption From The Re quirements 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, prev entive 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. Platinum Drone Services, LLC Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.40 9(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 inspect ion 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.9

8. Platinum Drone Services, LLC Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b).

Section 91.417, entitled Maintenance records , subsections (a) and (b), state the following:

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

(1) Records of the maintenance, preventive maintenance, and alteration and
records of the 1 00

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

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

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

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

(2) Records containing the f ollowing information:

(i) The total time in service of the airframe, each engine, each propeller, and
each rotor.

(ii) The current status of life

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

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

(iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft
and its a ppliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive
involves recurr ing action, the time and date when the next action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances.10 (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 records specified in paragraph (a)(2) of this section shall be retained and
transferred with the aircraft at the time the aircraft is sold.

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

C. The Extent Of Relief Platinum Drone Services, LLC Seeks And The Reason Platinum Drone Services, LLC Seeks The Relief.

1. Extent Of Relief Platinum Drone Services, LLC Seek s And The Reason Platinum Drone Services, LLC Seeks Relief From Section 61.113(a) And (b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in
command , is requested to the extent necessary to allow a PIC holdin g a private pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met certain flight

- hour and currency requirements, to conduct the proposed UAS flight operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire.

As set forth more fully below, Platinum Drone Services, LLC submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the UAS unless that PIC has met certain flight

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

Further, Platinum Drone Services, LLC submits that all flights of the UAS, conducted by the PIC pursuant to the grant of this Petiti on: (1) will be incidental to Platinum Drone Services, LLC business; and (2) will not carry passengers or property for compensation or hire.11

2. Extent Of Relief Platinum Drone Services, LLC Seeks And The Reason Platinum Drone Services, LLC Seeks Relief From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to the extent required to allow Platinum Drone Services, LLC to determine that the UAS are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., Platinum Drone Services, LLC Aerial Operations Manual, Monthly Maintenance Log, and Instruction Manual)

. Platinum Drone Services, LLC seeks the requested relief because the UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Platinum Drone Services, LLC will ensure that the UAS are in airworthy conditi on based upon its compliance with the operating documents (i. e., Monthly Maintenance Log ) prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated in the conditions
and limitations below.

3. Extent Of Relief Platinum Drone Services, LLC Seeks And The Reason Platinum Drone Services, LLC Seeks Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the UAS, which utilize a barometric pres sure 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 the FAA requires that any altitude information concerning UAS operations be report ed to air traffic control (ATC) in feet above ground level (AGL), Platinum Drone Services, LLC seeks the requested relief because the UA’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude,
bef ore 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 l evel of safety will be maintained since the UAS are equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the PIC with
altitude information of the UA on the heads

- up display of the GCS.

4. Extent Of Relief Platinum Drone Services, LLC Seeks And The Reason Platinum Drone Services, LLC Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flig ht in VFR conditions, is requested to the extent required to allow flights of the battery powered UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules ( VFR), for a total
duration of 20 minutes. Platinum Drone Servi ces, LLC seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of thebattery powered UAS will severely constrain the practicality of any aerial video or still photo

flight operations that Platin um Drone Services, LLC proposes to conduct pursuant to this
Petition.

Significantly, as set forth below, the technical specifications of the UAS, operating documents,
and Platinum Drone Services, LLC proposed operating limitations, ensure that Platinum Drone Services, LLC will safely operate the battery powered 3 UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power t o fly for a total duration of 20 minutes.

5. Extent Of R elief Platinum Drone Services, LLC Seeks And The Reason Platinum Drone Services, LLC 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) only apply to aircraft with an airworthiness certificate, Platinum Drone Services, LLC requests relief from these Sections because the UAS do not require airworthiness certificates. As set forth more fully below, the UAS meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, Platinum Drone Services, LLC will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices p rescribed in the UAS operating documents (i.e., the Platinum Drone Services, LLC Aerial Operations Manual, Monthly Maintenance Log, and Instruction Manual). Furthermore, Platinum Drone Services, LLC will document and maintain all maintenance records
for th e UAS.

D. The Reasons Why Granting Platinum Drone Services, LLC 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 Platinum Drone Services

, LLC to safely, efficiently, and economically perform aerial video and photography of

construc tion sites, real estate, events, landscape s, golf courses, weddings, outdoor activities and private parties over certain areas of the United States.

Additionally, use of the UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. The Public Will Benefit From Decreased Congestion Of The
NAS. The UAS are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. This will reduce the amount of aircraft traffic, noise and pollution. In addition an airport is n ot required for takeoff and landing
as the UAS does not require a landing strip. This will allow air traffic control to focus on other flight operations not conducting manned aerial imagery. Congestion in the NAS will be reduced.
The Public Will Benefit Fr om The Safety And Efficiency of t he UAS. A typical aircraft used for aerial imagery burns approximately 25 gallons per hour of fuel. The UAS is much more efficient
and will greatly benefit the public because no fuel is required as the UAS is battery powere d with
electric motors. Furthermore the UAS is much quieter eliminating noise pollution and any
disturbance to the public cause by a loud manned aircraft flying low. There is considerable lessrisk to the public utilizing the UAS as it weighs way under 55p ounds , has no fuel for something

to explode, compared to the manned aircraft weighing around 6,500 pounds, 42 feet wide, 35 feet long with typically close 185 gallons of fuel. The potential for danger with the UAS is greatly
reduced. By using the UAS to pe rform aerial imagery, the risk to life and property in the air and on the ground, will be much less or eliminated compared the typical manned aircraft completing the same objective

. Performing Aerial Video and Photography Operations With UAS Will
Benefit The Economy. T he UAS offer an economical alternative to using manned aircraft for aerial imagery

. This exemption allows companies to remain competitive and offer a service for a much cheaper, more efficient and healthier way. It allows aerial drone companies to grow and positively impact our economy.

Privacy will not be of any concern to the public as the UAS will be operated only in compliance with operating documents (i.e., Platinum Drone Services, LLC 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 requirements of 14 C.F.R. § 91.119.

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Lev el Of Safety At Least Equal To That Provided By The Rule From Which Platinum Drone Services, LLC Seeks Exemption.

1. Reasons Why The UAS Meet The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333.

In consideration of the size, w eight, speed, and limited operating area associated with the unmanned aircraft and its operation, Platinum Drone Services, LLC operation of the UAS meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in
accordance wit

h 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 th reat to national security. Specifically, FMRA Section 333 states the following, in part:

(a) In General.

-- Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transpor tation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act.15 (b) Assessment of Unmanned Aircraft Systems.

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

-- (1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security; and

(2) whether a certificate of waiver, certi ficate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1).

(c) Requirements for Safe Operation.

-- If the Secretary d etermines 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 t his exemption, Platinum Drone Services, LLC submits that the UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the UAS; (b) the pilot certification requirement; and (c) the specific operating lim itations.

a. The Specifications of t he UAS Demonstrate Its Safe Characteristics.

The UAS does not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capabi lity.

i. Technical Specifications of t he UAS.

The technical specifications of the UAS are set forth by the User Manual

The UAS Global Positioning Modes Enable The UAS To Remain Within A Defined Operational Area.

The UAS may be operated in both manual and global positioning flight modes.

The UAS 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 UAS will remain station ary, in flight, for 3 seconds or more. If, after 3 seconds, the UAS does not reacquire control link data from the GCS, the UAS will assume that the Control Link is lost and the will return to the home position (i.e., failsafe mode) via GPS,
and will descen

d to the takeoff position and shutdown.Flight Operations of the UAS Is Limited To The Line Of Sight Of A Certificated Pilot in

Command With A Safety Observer.

Platinum Drone Services, LLC video production staff will be the only persons to act as a pilot in command (PIC) of the UAS. Additionally, a safety observer will assist him at all times during flight time.

b. Flights of the UAS Will Be Conducted Pursuant To Specific Operating Limitations.

In seeking this exemption, Platinum Drone Services, LLC pr oposes to commercially operate the 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 b e limited to the following aircraft described in the operating documents, rotorcraft UAS weighing less than 55 pounds maximum gross weight THE DJI PHANTOM 2, DJI PHANTOM 3, 3DR SOLO, YUNEEC Q500+, AND THE DJI INSPIRE 1

.

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

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

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL), as in

dicated 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

.17 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 verbally at all times. Electronic messagi ng 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 ope rating
documents.

8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is not permitted to operate the camera or other instruments.

9. The operating docu ments 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 i n 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 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. The operator must also present updated and revised documents 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. If the inspection reveals a condition tha t 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 Station must be included in the preflight in spection. 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. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraft records.

12. The pre

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

13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements.18 14. The operator must carry ou t 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 records, including total tim e in service, description of work accomplished, and the signature of the authorized person returning the UAS to service.

15. Each UAS 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 t o 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 the exemption, including evasive and emergency maneuvers and maintain ing 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 PICs are permitted under
the terms of the exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

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

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

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

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

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

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

determined location within the planned operating area and land or be recovered in accordance with the operating documents.19 23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents.

24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 25% battery power remaining.

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of

exemp tion. 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. part 47, and have identificat ion (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 UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.

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

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

30. The UAS may not be operated by the PIC from any moving device or vehicle.

31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless:

a. Barriers or s tructures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipatin g persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, and;20 c. Operations nearer to the PIC, SO, operator trainees or essential persons 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/controller o r 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 reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents must be

repor ted to the National Transportation Safety Board (NTSB) per instructions
contained on the NTSB Web site: www.ntsb.gov

.

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

Platinum Drone Services, LLC 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 UAS unless that PIC has demonstrated, by meeting minimum fligh t

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

Consi dering Platinum Drone Services, LLC 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); an d the airmanship skills necessary to safely operate the UAS, Platinum Drone Services, LLC submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for Platinum Dron e Services, LLC ’s 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. 11062, 11063, 11 064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

Platinum Drone Services, LLC will not allow any PIC to operate the UAS unless that PIC has demonstrated, by meeting minimum flight

- hour re quirements or the UAS training and currency requirements, that the PIC is able to safely operate the UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehic les 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 those21

hours 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 Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during Platinum Drone Services, LLC proposed operations. The Administrator has held that prior documented 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 ope rations under 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 requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of
multi

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

- hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessa ry to safely 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 can also be conducted under the grant of exemption to accomplish the required flight time. During training, proficiency, and experience

- building flights the PIC is required to operate the UA with appropriate
distances in accordance with 14 C.F.R 9 1.119.

Exemption No. 11138 at page 15.

Accordingly, Platinum Drone Services, LLC will ensure safe operations by not allowing any PIC to operate the UAS unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the 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 O f Section 91.7(a) Would Not Adversely Affect Safety.22

The equivalent level of safety established by Section 91.7(a) will be maintained because prior to every flight, Platinum Drone Services, LLC will ensure that the UAS is in an airworthy co ndition based upon the UAS’s compliance with its operating documents and as stated in the conditions
and limitations herein.

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

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

The equivalent level of safety established by Section 91.121 will be maintained because the altitude information of the UAS will be provided to the PIC via GPS equipment and a radio communications telemetry data l ink, which downlinks from the UA to the GCS for active monitoring of the flight path and altitude. This altitude information, combined with Platinum Drone Services, LLC ’s operation of the UAS within visual line of sight, at or below 500 feet AGL, will ensu re a level 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 UAS at ground level.

T he 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 91.151(b) as a result of (1) the technical specifications of the UAS; (2) the limitations on the proposed flight operations; and (3) the location of the p roposed flight operations. Accordingly, Platinum Drone Services, LLC will ensure that it will safely operate the battery powered UAS during daylight hours in VFR conditions, with enough battery power to fly for a
total duration of 23 minutes.

Here, as in E xemption No. 11109, the technical specifications of the 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 UAS provide audible and visual warnings to the PIC at the GCS when the UAS experiences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining bat tery23

power. At the critically low battery level, the UAS will descend and land automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previ ously 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, 11 138, 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 Adversely Affect Safety.

In seeking this exemption, Platinum Drone Services, LLC submits that the equivalent level of safety with regard to the regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met
because P latinum Drone Services, LLC will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., Platinum Drone Services, LLC Aerial Operations Manual, Monthly Maintenance Log, and Instruction Manual). Furthermore, Platinum Drone Services, LLC will document and maintain all maintenance records for the UAS.

Since the UAS will be inspected as prescribed by the operating documents, Platin um Drone Services, LLC will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2).

Likewise, the exemption sought will not adversely affect safety because Platinum Drone Services, LLC will use trained te chnicians to perform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed by the operating documents.

Furthermore, the exemption sought would maintain an equivalent level of safety establishe d by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the UAS will be performed by trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log.

Significantly, previous exemptions granted by t he 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.• A Summary Tha t Can Be Published In The Federal Register, stating: The

Rules From Which Platinum Drone Services, LLC Seeks Exemption:

Platinum Drone Services, LLC 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 Platinum Drone Services,
LLC Seeks:

This exemption will permit Platinum Drone Services, LLC to commercially operate an Unmanned Aircraft 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 Platinum Drone Services, LLC ’s Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. As such, Platinum Drone Services, LLC ’s request for exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set
forth above.

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national secur ity; and further, provides the authority for such UAS to operate without airworthiness certification.

As discussed in detail above, Platinum Drone Services, LLC will operate the UAS safely in the NAS, without creating a hazard to users of the NAS, or the p ublic, or otherwise pose a threat to national security.

CONCLUSION

As set forth herein, Platinum Drone Services, LLC 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 UAS commercially, without an airworthiness certificate, for the limited purpose of conducting a erial 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 pu blic, by allowing Platinum Drone Services, LLC to safely, efficient ly, and economically
operate THE DJI PHANTOM 2, DJI PHANTOM 3, 3DR SOLO, YUNEEC Q500+, AND THE DJI

INSPIRE 1 commercially within the NAS.26

Because this petition is similar in material respects to previous petitions the FAA has granted, Platinum Drone Services, LLC requests that the FAA issue a summary grant of exemption pursuant to the agency's expedited summary grant process.

WHEREFORE , in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, Platinum Drone Services, LLC respectfully requests that the Administrator grant this Petition for an exemption from the requiremen ts 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 UAS commercially for the purpose of conducting aerial video and photography ove r certain areas of the United States.

Dated: 1

- 22

- 16

Respectfully submitted,

Tyler Delino
Owner Platinum Drone Services, LLC
71 Preston Drive Gillette, NJ, 07933 908

- 377

- 2649 tyler.delino@gmail.com27