1

Drone/UAS Practice Group 35 E Wacker Drive

Suite 1875 Chicago, IL 60601

Tel. 312.201.8310 Jeffrey@Antonelli

- Law.com

U.S. Department of Transportation January 29, 2016 Docket Management System 1200 New Jersey Ave S.E. Washington, D.C. 20590

Re: Request for Exemption under Section 333 of the FAA Modernization and Reform Act of 2012 and Part 11 of the Federal Aviation Regulations from Certain Provisions of 14 C.F.R.

JandDImages LLC

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 20 12 (the Reform Act) and 14 C.F.R. Part 11, Antonelli Law files this petition for exemption on behalf of JandDImages LLC ( “ JandDImages ” )

, an operator of Small Unmanned Aircraft Systems (“UAs”) for the commercial purposes of aerial photography and videography for the construction and real

estate industries . Specifically, petitioner seeks an exemption from the Federal Aviation Regulations (“FARs”) listed in Appendix A to allow commercial operation of its UA , so long as such operations are conducted w ithin and under the conditions outlined herein or as may be established by the FAA in a grant of this petition. This request is substantially similar to dozens of other aerial photography and videography petitions previously approved, and should be conside red under the expedited summary grant procedure.

Approval of the exemption for petitioner will allow operation of the DJI Inspire 1 P ro for the proposed uses in Class G airspace nationwide, or as otherwise prescribed by an Air Traffic Organization (ATO) i ssued COA. The UA covered by this petition has been previously approved for the proposed uses in the exemption grants identified in Section VII of the petition. The UA covered by this petition is small battery

- powered craft, weighing no more than 7.7 lbs. (3.5 kg)

, inclusive of battery and payload. Operation of the UA under the strict conditions proposed below will provide an equivalent level of safety, as Congress intended, while still allowing commercial

op erations. Operations using this UA is far safer t han conventional operations conducted with helicopters and fixed

- wing aircraft that weigh thousands of pounds, carry large amounts of highly flammable fuel, and operate in close proximity to the ground, trees, infrastructure, and people.

Congress directe d the FAA to consider seven factors in deciding whether to approve Section 333 exemption petitions

- size, weight, speed, operational capability, proximity to airports, proximity to populated areas, and operation within visual line of sight. In this case, each factor2

supports the exemption re quest. In particular, the UA is small, and will operate at slow speeds and close to the ground. It will be able to more safely and efficiently conduct operations that would otherwise involve risk of injury or death. The substantial increase of safety and decrease of risk to human life and to property weighs heavily in favor of granting the exemption.

For your ease in reviewing this petition, please refer to the table of contents which begins on page 3. If we can provide any additional information to assist your understanding or review of

these document s , please do not hesitate to contact us at 312

- 201

- 8310 or via email at jeffrey@antonelli

- law.com

. Thank you,

Jeffrey J. Antonelli

Amelia R. Niemi Benjamin C. Fink Attorneys for JandDImages LLC3 Table of Contents

I. Publishable Summary

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

II. Petitioner’s Contact Information

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

III. Proposed Operations

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

A. The UA

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

B. The Crew

................................ ................................ ................................ ........................ 7

C. Flight Conditions

................................ ................................ ................................ ............ 7

D. Flight Operations

................................ ................................ ................................ ............ 7

IV. Aircraft and Equivalent Level of Safety

................................ ................................ ................ 8

VI. Proposed Conditions of the Exemption

................................ ................................ ................. 8

VI. Privacy

................................ ................................ ................................ ................................ . 11

VII. Public Interest and Safety

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

VIII. Regulations from Which Exemption is Requested

................................ .............................. 13

Appendix A: FARs as to which JandDImages wishes the same determination to be made as has been made previously.

................................ ................................ ................................ ..... 134 Exhibit List

Exhibit 1 : DJI Inspire 1 Pro User Manual

.............. Submitted separately due to upload constraints

Exhibit 2 : DJI Inspire 1 Pro Quick Start Guide

...... Submitted separately due to upload constraints

Exhibit 3: DJI Inspire 1 Pro Safety Guidelines and Disclaimer

................................ .......................

................................ ................................ ................. Submitted separately due to upload constraints

Exhibit 4 : DJI Inspire 1 Series Intelligent Flight Battery Safety Guidelines

................................ ....

................................ ................................ ................. Submitted separately due to upload constraints

Exhibit 5: DJI Phantom Pilot Training Guide

......... Submitted separately due to upload constraints

Exhibit 6 : DJI Inspire 1 Pro Overview

................................ ................................ ......................... 15

Exhibit 7 : DJI Inspire 1 Pro Features

................................ ................................ ............................ 23

Exhibit 8 : DJI Inspire 1 Pro Specifications

................................ ................................ ................... 28

Exhibits 1 through 5 have been uploaded to Regulations.gov separately due to size

constraints.5

I. Publishable Summary

Pursuant to 14 C.F.R. §11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed:

Petitioner seeks an exemption from the following rules:

14 C.F.R 21(h); 14 C.F.R. 43.7; 14 C.F.R. 43.11; 14 C.F.R. 45.11; 14 C.F.R. 45.27; 14 C.F.R. 45.29; 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2); 14 C.F.R. 91.9(c); 14 C.F.R. 91.103(b)(2); 14 C.F.R. 91.105; 14 C.F.R. 91.109; 14 C.F.R. 91.113(b); 14 C.F.R. 91.11 9 (c); 14 C.F.R. 91.121; 14 C.F.R. 91.151(a); 14 C.F.R. 91.203(a) and (b); 14 C.F.R. 215; 14 C.F.R. 91.403; 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 409(a)(1) and (2); and 14 C.F.R. 91.417(a) and (b) to operate commercially small unmanned ai rcraft systems (UAs) ( 7.7 lbs. or less ).

Approval of the exemption requested by petitioner will allow commercial operation of the DJI Inspire 1 Pro for the purposes of aerial photography and videography for the construction and

real estate industries in Class G airspace nationwide, unless otherwise prescribed by an ATO

issued COA. The requested exemption should be granted because operation of a small UA weighing no more than 7.7 lbs. (3.5 kg)

, inclusive of battery and payload , conducted in the strict

c onditions outlined below, will provide an equivalent level of safety, while still allowing commercial operations. The lightweight aircraft covered by the exemption are far safer than conventional operations conducted with helicopters and fixed

- wing aircraf t weighing thousands of pounds and carrying large amounts of highly flammable fuel, and operating in close proximity to the ground and people. The seven factors Congress directed the FAA to consider when approving Section 333 exemption petitions

- size, we ight, speed, operational capability, proximity to airports, proximity to populated areas, and operation within visual line of sight

– each support the request. In particular, the aircraft are small, and will operate at slow speeds, and close to the ground. The substantial increase of safety and decrease of risk to human life, coupled with the low risk use of UAs to conduct these operations, weigh heavily in favor of granting the exemption.

II. Petitioner’s Contact Information

David Fisher Manager JandDImaging LLC

4734 Terrace Greene Trace Stone Mountain, GA 30088 Tel: (678) 283

- 2876 Email: janddimages@aol.com

Counsel for Petitioner: Jeffrey J. Antonelli

Antonelli Law 35 E Wacker Drive, Suite 1875 Chicago, IL 60601

Tel: 312

- 201

- 8310

Email: jeffrey@antonelli

- law.com6

III. Proposed Operations

A. The UA

The requested exemption will permit petitioner to operate the DJI Inspire 1 Pro . This UA

has been previously approved for commercial operation in, among others, the exemption grants

identified in Section VII below.

The specific conditions of the proposed exemption that relate t o the characteristics of the

UA are numbers 1, 5, and 16

- 20 in Sectio n V below. Each has been adopted or imposed by the FAA in numerous previous grants of Section 333 exemption petitions.

The DJI Inspire 1 Pro have the ability to hover and move in the vertical and horizontal planes simultaneously. The UA will have the foll owing specifications or equivalent:

Airframe DJI Inspire 1 Pro

Control System Internal to the Inspire 1. This includes the main controller (MC), which receives battery voltage, capacity, and current, the internal measurement unit (IMU), which

receives telemetry data, compass, and GPS.

Maximum Operating Speed 35 knots

Maximum Flight Time 1 5 minutes

Maximum Weight 7.7 lbs. (3.5 kg)

Transmitter Inspire 1 Pro Remote Control ler

Receiver 5.728~5.850 GHz receiver

Motor DJI 3510H

Propellers Four DJI 1345T propellers

Data Link HD Lightbridge Video Downlink

Video Link HD Lightbridge Video Downlink

Batteries LiPo 6S High Voltage battery with 4500

- 5700 mAh capacity

Telemetric Display DJI Pilot App

Automatic Return to Home If Tx signal is lost for more than three seconds and the UA is under 65 ft. (20 m.) AGL, the UA will rise to 65 ft. AGL, travel horizontally to the predesignated home spot, then land. If the UA is above 65 ft. AGL, travel horizontally to the predesignated home spot, hover for 15 seconds, then land.7

B. The Crew

The crew will consist of a pilot in command (PIC) and a visual observer (VO). The PIC and VO will have been trained in operation of UAs generally and received u p

- to

- date information

on the UA to be operated pursuant to this grant. The PIC will have, at a minimum, a sport pilot

license and either a third class medical certificate or a U.S. driver’s license.

The specific conditions of the proposed exemption that relate to the training and

char acteristics of the crew are numbers 3 and 6

- 9 in Section V below. Each has been adopted or imposed by the FAA in numerous previous grants of Section 333 exemption petitions.

For more information regarding the flight crew and training , please refer to Exhi bit 5 : DJI Phantom Pilot Training Guide.

C. Flight Conditions

The UA will be used for aerial photography and videography for the construction and real

estate industries in Class G airspace (unless otherwise prescribed by an ATO

- issued COA) under

400 fee t above ground level (“AGL”) and under controlled conditions over restricted property. Petitioner will work with the local FSDO when planning operations. Petitioner will only operate

the UA in visual meteorol ogical conditions (VMC). The UA will at all time s be no less than 500 feet below and no less than 2,000 feet horizontally from a cloud, and petitioner will not conduct operations unless visibility is at least 3 statute miles from the PIC. The flight crew will always make a safety assessment of the risk of every operation, and will only operate when it is determined that no hazards are present.

The specific conditions of the proposed exemption that relate to the fl ight conditions in

which the UA will be operated are numbers 2, 4, 16, and 28

- 29 in Section V below. Each has been adopted or imposed by the FAA in numerous previous grants of Section 333 exemption petitions.

D. Flight Operations

The purpose of the UA flights for which exemption is requ ested will be for aerial photography and videography for the construction and real estate industries . Every UA flight will use at minimum a two person flight crew: a PIC and a VO.

The specific conditions of the proposed exemption that relate to flight o perations are

numbers 11

- 12, 17

- 25, and 32

- 34 in Section V below. Each has been accepted or imposed by the FAA in numerous previous grants of Section 333 exemption petitions.

For more information regarding fli ght operations, please refer to the following subsections of the Inspire 1 Pro User Manual: Exhibit 1: DJI Inspire 1 Pro User Manual: Aircraft Exhibit 1: DJI Inspire 1 Pro User Manual: Flight8

IV. Aircraft and Equivalent Level of Safety

Petitioner proposes that the exemption apply to UAs that have th e characteristics and that operate with the limitations proposed herein. These limitations provide for a level of safety at least equivalent to or higher than manned aircraft operations under the current regulatory structure.

Section V below identifies th e limitations and conditions to which petitioner agrees to be bound when conducting commercial operations under a grant of this petition. Appendix A contains a matrix connecting (i) the specific proposed condition with (ii) the FAR provision for which it

p rovides an equivalent level of safety and (iii) one or more recent Section 333 exemption grants in which the FAA recognized this equivalent level of safety.

Approval of the commercial operations outlined in this petition presents no national security

issu e. The PIC will possess, at minimum, a sport pilot’s certificate, and therefore he or she will have been subject to security screening by the Department of Homeland Security.

V. Proposed Conditions of the Exemption

1. The UA, including battery and technical payload, will weigh no more than approximately 7.7 lbs (3.5 kg)

.

2. UA operations under this exemption will be limited to conducting operations for the purposes

of aerial photography and videography for the constructi on and real estate industries in Class G airspace nationwide, unless otherwise prescribed by an ATO

- issued COA.

3. Flights will be operated within line of sight of a PIC and VO.

4. Flights will be operated at an altitude of no more than 400 feet AGL, as indi cated by the procedures specified in the operating documents. All altitudes reported to ATC must be in feet

AGL.

5. The UA will not be flown at an indicated airspeed exceeding 35 knots

.

6. Minimum flight crew for each operation will consist of the UA PIC and a VO.

7. The PIC will possess at a minimum sport pilot license and either a third class medical certificate

or a U.S. driver’s license.

8. The petitioner will not permit any PIC to operate the UA unless the PIC meets its qualification

criteria and demonstrates the ability to safely operate the UA in a manner consistent with how the UA will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualific ation flight hours and currency will be logged in a manner consistent with 14 CFR §61.51(b). A record of the PIC training will be documented and made available upon request by the Administrator. Training operations will only be conducted during dedicated t raining sessions. During training, proficiency, and experience

- building flights, all persons not essential for flight operations will be considered nonparticipants, and the PIC will operate the UA with appropriate distance from nonparticipants in accordanc e with 14 CFR § 91.119.9

9. The VO will not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions, and will not be permitted to operate the camera or other instruments.

10. The PIC will be designated before the flight and will not be allowed to transfer his or her designation for the duration of the flight. The PIC will ensure that the VO can perform the functions prescribed in these conditions and the operating documents.

11. A br iefing will be conducted in regard to the planned UA operations prior to each day’s activities. It will be mandatory that all personnel who will be performing duties in connection with the operations be present for this briefing.

12. Prior to each flig ht, th e PIC will inspect the UA , including the Ground Control Station, to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UA, the PIC will not operate the UA until the necessary maintenance has been performed and the UA is found to be in a condition for safe flight. All maintenance and alterations will be properly documented in the aircraft records.

13. Petitioner will conduct a functional flight test on any UA that has undergone maintenance or alterations that affect the UA operation or flight characteristics, e.g. replacement of a flight critical component. The PIC who conducts the functional test fligh t will make an entry in the

aircraft records.

14. The petitioner will carry out its maintenance, inspections, and record keeping requirements, in accordance with the UA manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and l ife limit requirements set forth in the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts will be noted in the aircraft records, including total time in service, description of work accomplished, and the signature of the authorized person returning the UA to service. The authorized person will make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections.

15. The UA will be operated within vis ual line of sight (VLOS) of the PIC and VO at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses. PIC and VO will at all times be able to communicate verbally. They will not be permitted to us e electronic messaging or texting to communicate during flight operations.

16. The PIC will not begin 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 p repare to land with at least 25% battery power remaining.

17. Actual total flight time for each operational flight will result in no less than a 25% battery

reserve.

18. The UA will have the capability to abort a flight in case of unexpected obstacles or

emergen cies.10

19. The UA will be programmed so that if it loses communications or loses its GPS signal, it will

return to a pre

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

20. If the UA and i ts radio control link disconnect during flight, the system’s failsafe protection will be triggered and the multirotor will return to home and land automatically, rather than flying off uncontrollably or landing at an unknown location.

21. The operating docum ents required under 14 CFR §§ 91.9 and 91.203 will be maintained and available to the PIC at the Ground Control Station of the UA any time the UA is operating. These documents will be made available to the Administrator or any law enforcement official

upon request. If a discrepancy exists between the conditions and limitations in the exemption grant and the procedures outlined in the operating documents, the grant conditions and limitations will take precedence and will be followed. Otherwise, the petitione r will follow the procedures outlined in its operating documents. If it updates or revises its operating documents, it will present updated and revised documents to the Administrator upon request. If the petitioner determines that any update or revision wo uld affect the basis upon which the FAA granted the exemption, then the Petitioner will petition for an amendment to the grant of exemption.

22. Petitioner will obtain written and/or oral permission from the landowners/authorized agents of

the landowners ove r which flights will be conducted.

23. Petitioner will obtain all required permissions and permits from territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies.

24. UA operations will n ot be conducted during night, as defined in 14 CFR § 1.1. All operations will be conducted under visual meteorological conditions (VMC). Flights will not be conducted under special visual flight rules (SVFR).

25. The petitioner will obtain an Air Traffic Or ganization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption. Petitioner will request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 24 hours prior to the operation. All operations will be conducted in accordance with airspace requirements in the ATO issued COA, including class of airspace, altitude level and potential transponder requirements.

26. The UA will not be operated within 5 nautical miles of an airport reference point as denoted

on a current FAA

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

27. The UA 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 statute miles from the PIC.11

28. All operations shall be conducted in Class G airspace or as otherwise prescribed in an ATO

issued COA.

29. All aircraft operated in accordance with this exemption will be identified b y serial number, registered in accordance with 14 CFR part 47, and have identification (N

- Number) markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as practicable.

30. Before conducting operations, petitioner will ensure that t he radio frequency spectrum used for operation and control of the UA complies with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.

31. The UA will remain clear and yield the right of way to all mann ed aviation operations and

activities at all times.

32. The UA will not be operated by the PIC from any moving device or vehicle.

33. Petitioner will conduct all flight operations at least 500 feet from all nonparticipating persons, vessels, vehicles, and st ructures unless one of the following three conditions is met:

a. Barriers or structures are present that sufficiently protect nonpa rticipating persons from the

UA and/or debris in the event of an accident. The petitioner will ensure that nonparticipating pers ons remain under such protection. If a situation arises where nonparticipating persons leave such protection an d are within 500 feet of the UA , the PIC will ensure that flight operations cease immediately.

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.

c. Operati ons nearer to the PIC, VO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a).

34. Petitioner will report any incident, accident, or flight operation that transgresses the lateral or

vertical boundaries of t he operational area as defined by the applicable COA to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Petitioner will report accidents to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

.

VI. Privacy

There is little concern that the proposed flights will cause invasions of privacy. All flights will occur over either (a) public rights of way where there is no expectation of privacy; or (b) over private property with permission of the landowner/authorized agent and consent of participating

individuals.

If data collected is made available for public view, all images containing uninvolved persons will be blurred or blacked

- out. No attempt will be m ade to identify any individuals filmed during the flights except in cases where they are trespassing upon or damaging customer property, or interfering with the petitioner’s or its customers’ operations.12

VII. Public Interest and Safety

The planned UA use wil l increase ground safety for aerial photography and videography

for the construction and real estate industries . This type of data collection has previously been performed by manned aircraft or by individuals on the ground. Both are more time consuming and are more expensive than using UAs. Use of manned aircraft also poses enhanced risk to the pilot and onboard crew, who would be several hundred feet in the air.

The enhanced safety and reduced environmental impact achieved using UAs and carrying

no passe ngers or crew, rather than a manned aircraft of significantly greater mass, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UA operation enabled by this exemption is in the public interest.

Satisfaction of the criter ia provided in Section 333 of the Reform Act of 2012

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

– provide more than adequate justification for the grant of the requested exemption allowing commerci al operation of petitioner’s UA for aerial photography and videography for the construction and real estate industries pursuant to JandDImages rules of operation.

The FAA has previously determined that us ing the DJI Inspire 1 family for aerial photography and videography for the construction and real estate industries y is in the public interest in the following Exemption Nos.: Exemption No. 11204 (aerial photography of... construction industry sites); Exemption No. 11288 (construction... monitoring); Exemption No. 11384 (construction applications such as... construction); Exemption No. 11535 (aerial acquisitions of imagery in support of construction progress); Exemption No. 11620 (aerial photography and videography for... construction industries); Exemption No. 11644 (aerial video and photography of construction sites); Exemption No. 11647 (aerial video and photography of construction sites); Exemption No. 11702 (aerial videography and photography of construction sites); Exemption No. 11712 (aerial video and photography of construction sites); and Exemption No. 11714 (survey

- grade construction mapping and monitoring).

The FAA has previously determined that using the DJI Inspire 1 family for aerial photography and videography for the construction and real estate industries y is in the public interest in the following Exemption Nos.: Exemption No. 11714 (real estate); Exemption No. 11716 (aerial photography and vide ography of real property); Exemption No. 11728 (aerial video and photography of... real estate); Exemption No. 11750 (aerial video and photography of... real estate); Exemption No. 11784 (aerial photography for... real estate); Exemption No. 11790 (aerial photography and videography services for real estate); Exemption No. 11792 (aerial videography and or photography for real estate); Exemption No. 11821 (aerial real estate video and photography); Exemption No. 11836 (aerial videography and photogr aphy of construction sites); and Exemption No. 11843 (aerial photography and videography for real estate).13

VIII. Regulations from Which Exemption is Requested

Appendix A: FARs as to which JandDImages wishes the same determination to be made as has been made pr eviously.

FAR

Provision Applicable condition(s) in

Section 5 of petition FAA Exemption Decision

21(h) 1, 2, 3, 4, 5, 16, 25, 28, 29 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 11945, 12040, 12068, 12080, 12107, 12422, 12474

, 13365, 13366, 13933, 14026, 14194, 14195, 14196

43.7 13, 14 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 11945, 12040, 12068, 12080, 12107, 12422, 12474

, 13365, 13366, 13933, 14026, 14194, 14195, 14196

43.11 12 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 11945, 12040, 12068, 12080, 12107, 12422, 12474

, 13365, 13366, 13933, 14026, 14194, 14195, 14196

45.11 29 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 11945, 12040, 12068, 12080, 12107, 12422, 12474

, 13365, 13366, 13933, 14026, 14194, 14195, 14196

45.27 29 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 11945, 12040, 12068, 12080, 12107, 12422, 12474

, 13365, 13366, 13933, 14026, 14194, 14195, 14196

45.29 29 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 11945, 12040, 12068, 12080, 12107, 12422, 12474

, 13365, 1336 6, 13933, 14026, 14194, 14195, 14196 91.7(a) 12 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 11945, 12040, 12068, 12080, 12107, 12422, 12474

, 13365, 13366, 13933, 14026, 14194, 14195, 14196 91.9(b)(2) 22 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 11945, 12040, 12068, 12080, 12107, 12422, 12474

, 13365, 13366, 13933, 14026, 14194, 14195, 14196 91.9(c) 30 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 11945, 12040, 12068, 12080, 12107, 12422, 12474

, 13365, 13366, 13933, 14026, 14194, 14195, 14196 91.103(b)(2) 3, 9, 15, 16, 17, 18, 19, 20 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 11945, 12040, 12068, 12080, 12107, 12422, 12474

, 13365, 13366, 13933, 14026, 14194, 14195, 14196

91.105 6 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 11945, 12040, 12068, 12080, 12107, 12422, 12474

, 13365, 13366, 13933, 14026, 14194, 14195, 14196

91.109 7, 8 Nos. 11252, 11467, 11745, 11797, 11905, 11945, 12040, 12068, 12422, 12474, 13365, 13366, 13933, 14026, 14194, 14195, 14196 91.113(b) 3, 31 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 11945, 12040, 12068, 12080, 12107, 12422, 12474

, 13365, 13366, 13933, 14026, 14194, 14195, 1419614

FAR

Provision Applicable condition(s) in

Section 5 of petition FAA Exemption Decision

91.119(c ) 4, 33 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 11945, 12040, 12068, 12080, 12107, 12422, 12474

, 13365, 13366, 13 933, 14026, 14194, 14195, 14196

91.121 4 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 11945, 12040, 12068, 12080, 12107, 12422, 12474

, 13365, 13366, 13933, 14026, 14194, 14195, 14196 91.151(a) 16, 17 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 11945, 12040, 12068, 12080, 12107, 12422, 12474

, 13365, 13366, 13933, 14026, 14194, 14195, 14196 91.203 (a) and (b) 22 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 11945, 12040, 12068, 12080, 12107, 12422, 12474

, 13365, 13366, 13933, 14026, 14194, 14195 , 14196

91.215 25, 26 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 11945, 12040, 12068, 12080, 12107, 12422, 12474

, 13365, 13366, 13933, 14026, 14194, 14195, 14196

91.403 12, 13, 14 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 11945, 12040, 12068, 12080, 12107, 12422, 12474

, 13365, 13366, 13933, 14026, 14194, 14195, 14196 91.405(a) 12, 13, 14 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 11945, 12040, 12068, 12080, 12107, 12422, 12474

, 13365, 13366, 13933, 14026, 14194, 14195, 14196 91.407(a)(1) 14 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 11945, 12040, 12068, 12080, 12107, 12422, 12474

, 13365, 13366, 13933, 14026, 14194, 14195, 14196 91.409(a)(1) 12, 13, 14 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 11945, 12040, 12068, 12080, 12107, 12 422, 12474

, 13365, 13366, 13933, 14026, 14194, 14195, 14196 91.409(a)(2) 12, 13, 14 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 11945, 12040, 12068, 12080, 12107, 12422, 12474

, 13365, 13366, 13933, 14026, 14194, 14195, 14196 91.417(a) 12, 13, 14 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 11945, 12040, 12068, 12080, 12107, 12422, 12474

, 13365, 13366, 13933, 14026, 14194, 14195, 14196 91.417(b) 12, 13, 14 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 11945, 12040, 12068, 12080, 12107, 12422, 12474

, 13365, 13366, 13933, 14026, 14194, 14195, 14196