1 UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________



### IN THE MATTER OF THE PETITION FOR EXEMPTION OF:



### Aerospace Access Corporation

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMEN TS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTION S 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1) , 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF DJI INSPIRE 1 UNMANNED

AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Aerospace Access Corporation

Marcello Mattos

President

Address: 3387 Merrick Ct., Margate - FL 33063

Phone: 954-889-6355 / Fax: 954-889-3758 Email: UAV@aerospaceaccess.com2 TABLE OF CONTENTS

GLOSSARY OF ABBREVIATIONS

................................................... .......................................... 4

SUMMARY

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

INTRODUCTION AND INTERESTS OF THE PETITIONER ................................................ 5

BACKGROUND

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

BASIS FOR PETITION

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

A. Name and address of the petitioner.

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

B. The specific sections of 14 C.F.R. from which Ae rospace Access seeks exemption. ............. 7

C. The extent of relief Aerospace Access seeks and the reason Aerospace Access seeks the relief.

................................................... ................................................... ................................................... .. 10

D. The reasons why granting Aerospace Access reques t would be in the public interest ....... 12

E. The reasons why granting the exemption would not adversely affect safety ...................... 14

F. The rules from which Aerospace Access seeks exem ption

................................................... . 25

G. Any additional information, views, or arguments available to support request. ............. 25

CONCLUSION

................................................... ................................................... ......................... 26

APPENDICES

................................................... ................................................... .......................... 27

APPENDIX – A: DJI Inspire 1 Technical Specificati ons

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

APPENDIX – B: DJI Inspire 1 Manufacturer’s User M anual ................................................ 29

APPENDIX – C: DJI Inspire 1 Manufacturer’s Mainte nance Manual .................................. 30

APPENDIX – D: DJI Inspire 1 Manufacturer’s Safety Guidelines ......................................... 3134

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area Of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code Of Federal Regulations

COA Certificate Of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss Of Link

NAS National Airspace System

NOTAM Notice To Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2 012 (FMRA) Section 333

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 Landing5 SUMMARY

Aerospace Access Corporation seeks exemption from t he requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407( a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will perm it Aerospace Access to operate an Unmanned Aircraft System (UAS) for the commercial p urpose of conducting aerial surveying, remote sensing, precision agriculture, real estate marketing and inspection, motion picture aerial filmmaking and photography, private event photograp hy, utility system inspections and patrolling, construction site inspection and monitoring, wildli fe and forestry monitoring, educational and research operations, flare stack inspection, pipeli ne inspection and patrolling over certain areas of the

United States and Brazil.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Aerospace Access Corporation, hereto referred in th is document as Aerospace Access is seeking to offer possibly all the UAS services mentioned in th e summary above as part of new business opportunity. Aerospace Access was founded in 2008 i n the state of Florida as a commercial aviation parts supplier, with nearly a decade of experience with FAA and EASA approved parts and standards. Aerospace Access has established good re lationships in the aviation industry and is among the fastest growing companies in South Florida serv ing end-users worldwide. The objective of Aerospace Access UAS operations is to provide high quality imaging for a variety of commercial, public, and residential uses, specifically targetin g:

 Aerial Surveying

 Remote Sensing

 Precision Agriculture

 Real Estate Marketing and Inspection

 Motion Picture Aerial Filmmaking and Photography

 Private Event Photography

 Utility System Inspections and Patrolling

 Construction Site Inspection and Monitoring

 Wildlife and Forestry Monitoring

 Educational and Research Operations

 Flare Stack Inspection

 Pipeline Inspection and Patrolling

BACKGROUND

Unmanned Aircraft Systems: DJI Inspire 1 UAS Aerospace Access seeks an exemption to operate DJI systems for compensation or hire within the NAS and the Brazil if permitted by National Civil A viation Agency of Brazil (ANAC). The DJI Inspire 1 vertical takeoff and landing (VTOL) Unman ned Aircraft (UA) with a Ground Control Station (GCS) utilizes electronic tablet or smart p hone systems. The DJI Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17 .3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of approximately 42 kno ts. The DJI Inspire 1 UA is equipped with four main rotors; driven by Lithium Polymer battery powered electric motors.6

The DJI Inspire 1 UA that will be operated by Aeros pace Access will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft , as well as 14 C.F.R Part 47, Aircraft Registration

, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking

.

BASIS FOR PETITION

Petitioner, Aerospace Access, pursuant to the provi sions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Refor m Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereby petitions the Administrator to commerciall y operate the DJI Inspire 1 UAS in the National Airsp ace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91 .7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

In consideration of the speed, weight, size, and li mited operating area associated with the unmanned aircraft and its operation, Aerospace Access operat ion of DJI Inspire 1 UAS meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, Aerospace Access 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 se t forth requirements for maintenance that only apply to aircraft with an airworthiness certificate

.

Aerospace Access submits that the requested relief is proper since an equivalent level of safety will be ensured. Aerospace Access will use experienced p ersonnel or technicians to perform maintenance, alterations, or preventive maintenance on the UAS u sing the methods, techniques, and practices prescribed in the operating documents (i.e., Monthl y Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, Aerospace Access will documen t and maintain all maintenance records for the DJI Inspire 1 UAS.

Relief from certain requirements of Section 61.113( a) and (b), entitled Private pilot privileges and

limitations: Pilot in command , is requested by Aerospace Access to the extent ne cessary to allow a Pilot in Command (PIC) holding a private pilot or h igher level certificate, as well as an airman medical certificate, and who has demonstrated, by m eeting minimum flight- hour and currency requirements, that the PIC is able to safely operat e the DJI Inspire 1 UAS in a manner consistent with this exemption, including evasive and emergency man euvers and maintaining appropriate distances from people, vessels, vehicles and structures.

Aerospace Access seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness , because the DJI Inspire 1 UAS do not require an airworthiness c ertificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Aerospace Access submits that i t will ensure that the DJI Inspire 1 UAS are in an airworthy condition, prior to every flight, by d etermining that the UAS are in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual), and that the aircraft are in a condition for safe fligh t.

Aerospace Access also seeks an exemption from the r equirements of Section 91.121, entitled Altimeter Settings , as the DJI Inspire 1 UA will not have a typical b arometric altimeter onboard. However, altitude information of the DJI Inspire 1 UA will be provided to the PIC via Global Positioning System (GPS) equipment and radio commun ications telemetry data link, which

downlinks from the UA to the GCS for active monitor ing of the flight path. This altitude information,7

combined with Aerospace Access’ operation of the DJ I Inspire 1 UAS within visual line of sight, at or below 500 feet AGL, will ensure a level of safet y equivalent to Section 91.121.

Additionally, Aerospace Access seeks an exemption f rom the requirements of Section 91.151(b),

entitled Fuel requirements for flight in VFR conditions . Aerospace Access submits that safety will not be affected by operation of the DJI Inspire 1 U A during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), w ith enough battery power to fly for a total duration of approximately 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

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

A. Name and address of the petitioner.

The name and address of the petitioner and point o f contact is:

Aerospace Access Corporation

Marcello Mattos

3387 Merrick Ct. Margate, FL 33063

Phone: 954-889-6355

Fax: 954-889-3758

Mobile: 954-643-2512 Email: UAV@aerospaceaccess.com

B. The specific sections of 14 C.F.R. from which A erospace Access seeks exemption.

1. Aerospace Access seeks exemption from the requ irements 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 certific ate 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 o r hire, act as PIC of an

aircraft. (b) A private pilot may, for compensation or hir e, act as PIC of an aircraft in connection with any business or employment if— (1) The flight is only incidental to that busin ess or employment; and (2) The aircraft does not carry passengers or p roperty for compensation

or hire.

2. Aerospace Access seeks exemption from the requ irements of Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness , subsection (a), states the following: (a) No person may operate a civil airc raft unless it is in an airworthy

condition.8

3. Aerospace Access seeks exemption from the requ irements of Section 91.121.

Section 91.121, entitled Altimeter settings, subs ection (a), states the following, in

part: (a) Each person operating an aircraft shall main tain the cruising altitude or flight level of that aircraft, as the case may be, by r eference 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 air craft; (ii) If there is no station within the area pr escribed in paragraph (a)(1)(i) of this section, the current reporte d 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 appro priate altimeter setting available before departure.

4. Aerospace Access seeks exemption from the requ irements 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 condition s) there is enough fuel to fly to the first point of intended landing and, assu ming normal cruising speed, to fly after that for at least 20 minutes.

5. Aerospace Access seeks exemption from the requ irement 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 prescr ibed in subpart E of this part and shall between required inspections, except as pr ovided in paragraph (c) of this section, have discrepancies repaired as pre scribed in part 43 of this chapter[.]

6. Aerospace Access seeks exemption from the requ irements of Section 91.407(a)(1).

Section 91.407, entitled Operation after maintenance, preventive maintenance

, rebuilding, or alteration , subsection (a)(1), states the following: (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteratio n unless-- (1) It has been approved for return to service by a person authorized under § 43.7 of this chapter[.]

7. Aerospace Access seeks exemption from the requ irements of Sections 91.409(a)(1) and 91.409(a)(2).9

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 cale ndar months, it has had -- (1) An annual inspection in accordance with par t 43 of this chapter and has been approved for return to service by a pe rson authorized by § 43.7 of this chapter; or (2) An inspection for the issuance of an airwort hiness certificate in accordance with part 21 of this chapter.

8. Aerospace Access seeks exemption from the requ irements 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 foll owing records for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preventive main tenance, and alteration and records of the 100-hour, annual, progressiv e, and other required or approved inspections, as appropriate, for ea ch 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 accept able to the Administrator) of the work performed; and (ii) The date of completion of the work perfor med; and (iii) The signature and certificate number of the person approving

the aircraft for return to service. (2) Records containing the following informatio n: (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 item s installed on the aircraft which are required to be overhauled o n a specified

time basis. (iv) The current inspection status of the airc raft, including the time since the last inspection required by the insp ection program under which the aircraft and its appliances ar e maintained. (v) The current status of applicable airworthi ness 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 r ecurring action the time and date when the next action is requ ired. (vi) Copies of the forms prescribed by § 43.9( d) of this chapter for each major alteration to the airframe and curr ently installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the follo wing records for the periods prescribed:10

(1) The records specified in paragraph (a)(1) o f this section shall be retained until the work is repeated or supersed ed by other work or for 1 year after the work is performed. (2) The records specified in paragraph (a)(2) o f this section shall be

retained and transferred with the aircraft at t he time the aircraft is

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

C. The extent of relief Aerospace Access seeks and the reason Aerospace Access

seeks the relief.

1. Extent of relief Aerospace Access seeks and th e reason Aerospace Access 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 P IC holding a private pilot or higher level certifica te, as well as a current and valid airman medical certificate, and who has met certain flig ht-hour and currency requirements, to conduct the proposed UAS flight operations for co mpensation or hire.

This relief is requested since the limitations se t 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, Aerospace Access s ubmits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the DJI Inspire 1 UAS unless that PIC has met certain flight-hour a nd currency requirements, demonstrating that the PIC is able to safely oper ate either the DJI Inspire 1 UAS in a manner consistent with the operations specificati ons as described in this exemption, including evasive and emergency maneuvers, as wel l as maintaining appropriate distances from people, vessels, vehicles and stru ctures.

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

2. Extent of relief Aerospace Access seeks and th e reason Aerospace Access 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 Aerospace Access to dete rmine that the DJI Inspire 1 UAS is in airworthy condition prior to every flight by e nsuring that the UAS is in compliance11

with the operating documents (i.e., the Aerospace Access Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 Instru ction Manual).

Aerospace Access seeks the requested relief becau se the DJI Inspire 1 UAS does not require an airworthiness certificate in accordanc e with 14 C.F.R. Part 21, Subpart H.

Therefore, Aerospace Access will ensure that the DJI Inspire 1 UAS is in airworthy condition based upon its compliance with the oper ating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 Instruction Ma nual) prior to every flight, and further, determine that the aircraft are in condi tion for safe flight, as stated in the

conditions and limitations below.

3. Extent of relief Aerospace Access seeks and th e reason Aerospace Access

seeks relief from Section 91.121.

Relief from Section 91.121, entitled Altimeter se ttings, may be required to allow flight operations of the DJI Inspire 1 UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink

altitude information from the UA to the PIC at th e ground control station (GCS). Since the FAA requires that any altitude informat ion concerning UAS operations be reported to air traffic control (ATC) in feet abo ve ground level (AGL), Aerospace Access seeks the requested relief because the DJI Inspire 1 UA’s altimeter may be set on the ground to zero feet AGL, rather than the l ocal barometric pressure or field altitude, before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to compl y with the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level of safety will be maintained since the DJI Inspire 1 UA are equipped with a barometric pressure sensor and GPS equipment, which automati cally ensures that a ground level pressure setting will be established prior to eac h flight, and provides the PIC with altitude information of the UA on the heads-up di splay of the GCS.

4. Extent of relief Aerospace Access seeks and th e reason Aerospace Access seeks relief from Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requi rements for flight in VFR conditions, is requested to the extent required t o allow flights of the battery powered DJI Inspire 1 UA during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total dura tion of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. Aerospace Access seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered DJI Inspire 1 UA will severely constrain the prac ticality of any aerial video or still photo flight operations that Aerospace Access pro poses to conduct pursuant to this

Petition.

Significantly, as set forth below, the technical specifications of the DJI Inspire 1 UAS, the DJI Inspire 1 operating documents, and A erospace Access proposed12

operating limitations, ensure that Aerospace Acce ss will safely operate the battery powered DJI Inspire 1 UA during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enou gh battery power to fly for a total duration of 13.5 minutes to the first point of in tended landing and, assuming normal cruising speed, to fly after that for at least 4. 5 minutes.

5. Extent of relief Aerospace Access seeks and th e reason Aerospace Access 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 cert ificate, Aerospace Access requests relief from these Sections because the DJI Inspir e 1 UAS does not require

airworthiness certificates. As set forth more ful ly below, the DJI Inspire 1 UAS meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, Aerospace Access will u se trained technicians to perform maintenance, alterations, or preventive maintenan ce on the UAS using the methods, techniques, and practices prescribed in the UAS o perating documents (i.e., the Aerospace Access Aerial Operations Manual, Monthl y Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, Aeros pace Access will document and maintain all maintenance records for the DJI Insp ire 1 UAS.

D. The reasons why granting Aerospace Access reque st would be in the public interest; that is, how it would benefit the public as a whol e.

Granting the present Petition will further the pub lic interest by allowing Aerospace Access to safely, efficiently, and economically perform aeri al surveying, remote sensing, precision agriculture, real estate marketing and inspection, motion picture aerial filmmaking and photography, private event photography, utility sy stem inspections and patrolling, construction site inspection and monitoring, wildl ife and forestry monitoring, educational and research operations, flare stack inspection, pipel ine inspection and patrolling over certain

areas of the United States and Brazil.

Additionally, use of the DJI Inspire 1 UAS will de crease congestion of the NAS, increase public safety by performing inspections transporta tion infrastructures, monitor forests and wildlife, reduce pollution and provide signifi cant benefits to the economy. Notably, the benefits of Aerospace Access’ proposed operat ion of the DJI Inspire 1 UAS will be realized without implicating any privacy issues.

1. The public will benefit from decreased congest ion of the NAS.

The DJI Inspire 1 UA are battery powered and serv e as a safe, efficient, and

economical alternative to the manned aircraft tra ditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraf t needed to perform aerial acquisitions, an exemption allowing the use of a DJI Inspire 1 UAS would reduce the amount of manned aircraft in the NAS, reduce nois e and air pollution, as well as increase the safety of life and property in the a ir and on the ground.13

Furthermore, by reducing the number of manned air craft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The DJI Inspire 1 UA does not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial vi deo and photography missions

would result in fewer aircraft that must be handl ed by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. The public will benefit from the safety and ef ficiency of the DJI Inspire 1

UAS.

Conducting aerial acquisitions with the DJI Inspi re 1 UAS, instead of manned aircraft, will greatly benefit the public by dras tically reducing the levels of air and noise pollution generated during traditional aeri al video and still photography flight operations. By using battery power and electric m otors, the DJI Inspire 1 UAS produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combust ion engine aircraft that are typically utilized for aerial video and photography, while burning approximately 20-30 gallons per hour of leaded aviation fuel. The DJI Inspire 1 UA, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UA are propelled by battery powered electric motors, rat her than an internal combustion engine.

By using the DJI Inspire 1 UAS to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, w hich is usually associated with traditional manned aircraft flight operations, wi ll be substantially reduced or completely eliminated. Aside from the lack of fli ght crew members located onboard the aircraft, the DJI Inspire 1 UA (weighing appr oximately 6 pounds 7.5 ounces, at maximum gross weights with length of 17.3 inches, width of 17.7 inches, and with no fuel on board), has less physical potential for c ollateral damage to life and property on the ground, and in the air, compared to the ma nned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

3. Increased safety in highways and protection of forests and wildlife.

The use of the DJI Inspire 1 UAS is more affordab le than the use of traditional manned aircraft during inspections of bridges, hi ghways and other infrastructure, a

reduced cost would be an incentive to increased f requency of inspections and less rush while performing the task. The silent nature of the DJI Inspire 1 UAS also helps monitor wildlife without any disturbance and in c ountries like Brazil that suffers with extraction of wood, it would help monitor any cha nges in the landscape and even catch illegal activities or fire started by farme rs illegally to increase pasture and agricultural land.

4. Performing aerial video and photography operat ions with the DJI Inspire 1 UAS will benefit the economy.

In addition to being safe and efficient, the DJI Inspire 1 UAS are also an economical alternative to using manned aircraft to conduct s imilar aerial operations. As such,14

operation of the DJI Inspire 1 UAS will allow Uni ted States based companies, like Aerospace Access, to remain competitive and contr ibute to growth of the U.S. economy. Specifically, with the rising cost of av iation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phas ing out leaded aviation fuels, U.S. owned and operated companies must adopt new and a lternative technology in order to remain competitive. Operating the battery powered DJI Inspire 1 UAS is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility wi thout the high operational cost of a

traditional manned aircraft.

By operating the DJI Inspire 1 UAS, companies suc h as Aerospace Access, can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. c ompanies, through commercial use of the DJI Inspire 1 UAS, provides a stable w orkforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to re main competitive both in the United

States and abroad.

5. There are no privacy issues.

Similar to the manned aerial acquisition flight o perations that have been conducted for decades, Aerospace Access’s proposed operatio n of the DJI Inspire 1 UAS will not implicate any privacy issues. Specifically, t he DJI Inspire 1 UAS will be operated only in compliance with operating documents (i.e. , the Aerospace Access Aerial Operations Manual, Monthly Maintenance Log, and D JI Inspire 1 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 no t adversely affect safety, or how the exemption would provide a level of safety at least equal to that provided by the rule from which Aerospace Access seeks exemption.

1. Reasons why the DJI Inspire 1 UA meet the cond itions of the FAA Modernization and Reform Act of 2012 (FMRA) Secti on 333.

In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, Aerospac e Access operation of the DJI Inspire 1 UAS meet the conditions of FMRA Section 333, and will not require an

airworthiness certificate in accordance with 14 C .F.R. Part 21, Subpart H.

Section 333 provides authority for a UAS to opera te without airworthiness certification and sets forth requirements for con sidering whether a UAS will create a hazard to users of the NAS or the public, or othe rwise pose a threat to national security. Specifically, FMRA Section 333 states t he following, in part:

(a) In General.--Notwithstanding any other requi rement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of15

Transportation shall determine if certain unmann ed aircraft systems may operate safely in the national airspace system b efore completion of the plan and rulemaking required by section 332 of this A ct or the guidance required by section 334 of this Act.

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under subsection (a), the Secretary shall determ ine, at a minimum-- (1) which types of unmanned aircraft systems, i f any, as a result of their size, weight, speed, operational capability, pr oximity to airports and populated areas, and operation within visual li ne of sight do not create a hazard to users of the national airspa ce system or the public or pose a threat to national security; and (2) whether a certificate of waiver, certificat e of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of u nmanned aircraft systems identified under paragraph (1). (c) Requirements for Safe Operation.--If the Sec retary determines under this section that certain unmanned aircraft systems m ay operate safely in the national airspace system, the Secretary shall es tablish requirements for the safe operation of such aircraft systems in the n ational airspace system.

In seeking this exemption, Aerospace Access submits that the DJI Inspire 1 UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonst rated by: (a) the characteristics of the DJI Inspire 1 UAS; (b) the pilot certification requirem ent; and (c) the specific operating limitations.

a. The specifications of the DJI Inspire 1 UAS d emonstrate its safe

characteristics.

The DJI Inspire 1 UAS does not create a hazard t o users of the NAS or the public, or otherwise pose a threat to national s ecurity considering its size, weight, speed, and operational capability.

i. Technical specifications of the DJI Inspire 1 UAS.

The technical specifications of the DJI Inspire 1 UAS are set forth by the DJI Inspire 1 Technical Specifications, att ached hereto as Appendix A.

ii. The DJI Inspire 1 UAS autonomous flight and navigation

modes enable the UAS to remain within a defined operational

area.

The DJI Inspire 1 UAS may be operated in both m anual and fully autonomous flight modes. A complete description of the flight and navigational modes of the DJI Inspire 1 UAS is provided at pages 45- 50 of the DJI Inspire 1 User Manuals, attached hereto as Appendix B.16

iii. The DJI Inspire 1 UAS are designed for aut omatic return to home point or hover in the event of loss of the control link or navigation.

When the Control Link is lost, the DJI Inspire 1 UA will remain stationary, in flight, for 3 seconds or more. I f, after 3 seconds, the DJI Inspire 1 UA does not reacquire control link da ta from the GCS, the

UAs will assume that the Control

Link is lost and the UA will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and

shutdown. A complete description of the Failsafe Function s of the DJI Inspire 1 are set forth at pages 13 through 15 in the DJI Inspire 1 User Manual, attached hereto as Appendix B.

iv. The DJI Inspire 1 GCS and its operation.

A complete description of the operation and spe cifications of the DJI Inspire 1 GCS and flight control software is pr ovided at pages 40 through 47 of the DJI Inspire 1 User Manual. DJ I Inspire 1 User Manuals are attached hereto as Appendix B.

b. Flight operations of the DJI Inspire 1 UAS is limited to the line of sight of a certificated pilot in com mand with a safety observer.

Aerospace Access will only utilize certificated operators to act as a pilot in command (PIC) of the DJI Inspire 1 UAS. Addition ally, a safety observer will assist all pilots during flight time.

c. Flights of DJI Inspire 1 UAS will be conducte d pursuant to specific operating limitations.

In seeking this exemption, Aerospace Access prop oses to commercially operate the DJI Inspire 1 UAS for the special pu rpose of conducting aerial video and photography over certain areas of Unit ed States, pursuant to the following specific operating limitations:

1. Operations authorized by this grant of exemp tion will be limited to the following aircraft described in the operati ng documents, rotorcraft UAS weighing less than 55 pounds maximum gross weight: DJI Inspire 1 Unmanned Aircraft Systems. Proposed o perations of any other aircraft will require a new petition or a petition to amend this

grant.

2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photography.17

3. The UA may not be flown at an indicated airs peed exceeding 20

knots.

4. The UA must be operated at an altitude of no more than 500 feet above ground level (AGL), as indicated by the p rocedures specified in the operating documents unless a special reques t 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 a ble to use human vision unaided by any device other than corrective len ses, as specified on the

PIC’s FAA-issued airman medical certificate.

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

7. All operations must utilize a safety observe r (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 m essaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or he r designation for the duration of the flight. The PIC must ensure tha t the SO can perform the functions prescribed in the operating docum ents.

8. The SO must not perform any other duties bey ond 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 documents and the grant of exe mption must be accessible during UAS operations and made avail able to the Administrator upon request. If a discrepancy ex ists between the conditions and limitations contained in the gra nt of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The ope rator may update or revise its operating documents. It is the opera tor’s responsibility to track such revisions and present updated and re vised documents to the Administrator upon request. The operator must a lso present updated and revised documents if it petitions for exten sion or amendment to the grant of exemption. If the operator determi nes 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.18

10. Prior to each flight the PIC must inspect t he UAS to ensure that it is in a condition for safe flight. If the inspecti on reveals a condition that affects the safe operation of the UAS, the airc raft is prohibited from operating until the necessary maintenance has b een performed and the UAS is found to be in a condition for safe flig ht. The Ground Control Station must be included in the preflight inspe ction. All maintenance and alterations must be properly documented in the aircraft records.

11. Any UAS that has undergone maintenance or a lterations that affect the UAS operation or flight characteristics, e. g. replacement of a flight critical component, must undergo a funct ional test flight. The PIC who conducts the functional test flight mus t 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 docum ents.

13. The operator must follow the UAS manufactur er’s aircraft/component, maintenance, overhaul, repl acement, inspection, and life limit requirements.

14. The operator must carry out its maintenance , inspections, and record keeping requirements, in accordance with the op erating documents. Maintenance, inspection, alterations, and statu s of replacement/overhaul component parts must be no ted in the aircraft records, including total time in service, descr iption of work accomplished, and the signature of the authoriz ed 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 d iscovered between inspections.

17. The PIC must possess at least a private pil ot certificate and at least a

current third- class medical certificate.

18. The operator may not permit any PIC to oper ate unless the PIC meets the operator’s qualification criteria and demon strates the ability to safely operate the UAS in a manner consistent w ith how the UAS will be operated under the exemption, including evas ive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualifica tion 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 ar e permitted under the terms of the exemption. However, training opera tions may only be19

conducted during dedicated training sessions. D uring training, proficiency, and experience-building flights, a ll persons not essential for flight operations are considered nonpartici pants, and the PIC must operate the UA with appropriate distance from n onparticipants 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 conditions (VMC). If flight at n ight is required, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visua l flight rules (SVFR) are

not authorized.

20. The UA may not operate within 5 nautical mi les of an airport reference point as denoted on a current FAA-pub lished aeronautical chart unless a letter of agreement with that ai rport’s management is obtained, and the operation is conducted in acc ordance with a NOTAM as required by the operator’s COA. The le tter of agreement with the airport management must be made availa ble to the Administrator upon request.

21. The UA may not be operated less than 500 fe et below or less than 2,000 feet horizontally from a cloud or when vi sibility 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 planne d operating area and land or be recovered in accordance with the ope rating documents.

23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating do cuments.

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

25. The operator must obtain an Air Traffic Org anization (ATO) issued Certificate of Waiver or Authorization (COA) pr ior to conducting any operations under the grant of exemption. This C OA will also require the operator to request a Notice to Airman (NOT AM) 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 cl ass of airspace, altitude level and potential transponder requir ements.

26. All aircraft operated in accordance with th e exemption must be identified by serial number, registered in acco rdance with 14 C.F.R. part 47, and have identification (N- Number) ma rkings in accordance20

with 14 C.F.R. part 45, Subpart C. Markings mus t be as large as practicable.

27. Before conducting operations, the radio fre quency spectrum used for operation and control of the UA must comply wit h the Federal Communications Commission (FCC) or other approp riate 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 S tation of the UAS any time the UAS is operating. These documents must be made available to the Administrator or any law enforcement off icial upon request.

29. The UA must remain clear and yield the righ t 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 leas t 500 feet from all nonparticipating persons (persons other than th e PIC, SO, operator trainees or essential persons), vessels, vehicl es, and structures unless:

a. Barriers or structures are present that sufficientl y protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonpa rticipating persons remain under such protection. If a situatio n arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immedi ately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or s tructures has granted permission and the PIC has made a safety as sessment of the risk of operating closer to those objects and d etermined that it does not present an undue hazard, and;

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

32. All operations shall be conducted over priva te or controlled-access property with permission from the land owner/co ntroller or authorized representative. Permission from land owner/cont roller or authorized representative will be obtained for each flight to be conducted.

33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UA S Integration Office (AFS-80) within 24 hours. Accidents must be reported to the21

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.

Aerospace Access submits that the equivalent leve l of safety established by Section 61.113(a) and (b) will be maintained because no P IC will be allowed to operate the DJI Inspire 1 UAS unless that PIC has demonstrate d, by meeting minimum flight- hour and currency requirements, that the PIC is a ble to safely operate the DJI Inspire 1 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances f rom people, vessels, vehicles and

structures.

Considering Aerospace Access’ proposed area of op erations, and the operating limitations set forth-above; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot require ments (See Exemption No. 11062); and the airmanship skills necessary to safely ope rate the DJI Inspire 1 UAS, Aerospace Access submits that the additional mann ed airmanship experience of a commercially certificated pilot would not correla te to the airmanship skills necessary for Aerospace Access’ specific proposed flight op erations.

The FAA has previously granted relief from Sectio n 61.113(a) and (b) specific to UAS, in circumstances similar, in all material re spects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

Aerospace Access will not allow any PIC to operat e the DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum fli ght-hour requirements or the DJI Inspire 1 UAS training and currency requirements, that the PIC is able to safely operate the DJI Inspire 1 UAS in a manner consist ent with this exemption, including evasive and emergency maneuvers and maintaining a ppropriate distances from people, vessels, vehicles and structures.

Specifically, the PIC must have accumulated and l ogged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those 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, pri or documented flight experience that was obtained in compliance with applicable r egulations will ensure an equivalent level of safety during Aerospace Access’s propose d operations. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe ope rations, stating as follows:

In Exemption No. 11062, the FAA required that pr ior to conducting operations for the purpose of motion picture fil ming (or similar operations),22

the PIC must have accumulated and logged, in a m anner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS ro torcraft pilot including at least 10 hours logged as a UAS pilot with a mult i-rotor UAS. Prior to operations under Exemption No. 11062, the PIC mu st also have accumulated and logged a minimum of 5 hours as a UAS pilot o perating the same make and model of UAS to be used for operations under the exemption. For clarification, the FAA considers these minimum h our requirements to be inclusive rather than additive; i.e. 5 hours mak e 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 F AA finds that at a minimum, the flight-hour requirements in Exemption No. 11 062 are appropriate to practice and build proficiency in the skills nec essary to safely conduct the petitioner’s proposed operations. The FAA also f inds that prior documented flight experience that was obtained in complianc e with applicable regulations would satisfy this requirement. Training, profic iency, and experience- building flights can also be conducted under the grant of exemption to accomplish the required flight time. During trai ning, proficiency, and experience-building flights the PIC is required to operate the UA with appropriate distances in accordance with 14 C.F. R 91.119. Exemption No. 11138 at page 15.

Accordingly, Aerospace Access will ensure safe op erations by not allowing any PIC to operate the DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, th at the PIC is able to safely operate the DJI Inspire 1 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropria te distances from people, vessels, vehicles and structures.

3. Reasons why an exemption from the requirements of Section 91.7(a) would not adversely affect safety.

The equivalent level of safety established by Sec tion 91.7(a) will be maintained because prior to every flight, Aerospace Access w ill ensure that the DJI Inspire 1 UAS is in an airworthy condition based upon the U AS’s compliance with its operating documents and as stated in the conditio ns and limitations herein.

Additionally, the FAA has previously granted reli ef from Section 91.7(a) specific to UAS, in circumstances similar, in all material re spects, 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 Sec tion 91.121 will be maintained because the altitude information of the DJI Inspi re 1 UA will be provided to the PIC via GPS equipment and a radio communications tele metry data link, which23

downlinks from the UA to the GCS for active monit oring of the flight path and altitude. This altitude information, combined wit h Aerospace Access’s operation of the DJI Inspire 1 UA within visual line of sight, at or below 500 feet AGL, will ensure 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 establ ished by the UAS at ground level.

The FAA has previously granted relief from Sectio n 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. 22

A grant of this exemption would ensure an equival ent level of safety established by 14 C.F.R. Section 91.151(b) as a result of (1) th e technical specifications of the DJI Inspire 1 UAS; (2) the limitations on the propose d flight operations; and (3) the location of the proposed flight operations. Accor dingly, Aerospace Access will ensure that it will safely operate the battery po wered DJI Inspire 1 UA during daylight hours in VFR conditions, with enough bat tery power to fly for a total duration of 13.5 minutes to the first point of in tended landing and, assuming normal cruising speed, to fly after that for at least 4. 5 minutes.

Here, as in Exemption No. 11109, the technical sp ecifications of the DJI Inspire 1 UAS; the limitations on the proposed flight opera tions; and the location of the proposed operations, will ensure an equivalent le vel of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety wil l be ensured as the DJI Inspire 1 UAS provide audible and visual warnings to the PI C at the GCS when the UA experiences low battery voltage, the first warnin g occurring at approximately 33% remaining battery power, and again at approximate ly 10% remaining battery power. At the critically low battery level, the DJI Insp ire 1 UAS will descend and land automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected w hen 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 pre scribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, t he FAA has previously granted relief from Section 91.151 specific to UAS, in ci rcumstances similar, in all material respects, to those presented herein (e.g. Exempti on Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

6. Reasons why an exemption from the requirements of Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a ) & (b) would not adversely affect safety.24

In seeking this exemption, Aerospace Access submi ts 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 Aerospace Access will u se trained technicians to perform maintenance, alterations, or preventive maintenan ce on the UAS using the methods, techniques, and practices prescribed in the opera ting documents (i.e., the Aerospace Access Operations Manual, Monthly Maintenance Log , and the DJI Inspire 1 Instruction Manual). Furthermore, Aerospace Acces s will document and maintain all maintenance records for the DJI Inspire 1 UAS.

Since the DJI Inspire 1 UAS will be inspected as prescribed by the operating documents, Aerospace Access will maintain the equ ivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a )(2). A copy of the DJI Inspire 1 User Manuals is attached hereto as Appendix B; a copy of the DJI Inspire 1 UAS Maintenance Manual and Maintenance Log is attache d hereto as Appendix C and E, respectively.

Likewise, the exemption sought will not adversely affect safety because Aerospace Access will use trained technicians to perform ma intenance, alterations or preventive maintenance on the UAS using the methods, techniq ues, and practices prescribed by the operating documents.

Furthermore, the exemption sought would maintain an equivalent level of safety established by Sections 91.407, 91.417(a) and 91. 417(b), because all maintenance of the DJI Inspire 1 UAS will be performed by traine d technicians. Maintenance will be documented and maintained utilizing the monthly m aintenance log.

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), a nd 91.417(a) & (b) establish that safety is not adversely affected when the technic al characteristics and operating

limitations of the UAS are considered.

In consideration of Aerospace Access’s proposed o perating limitations, the operating documents, and the technical aspects of the DJI I nspire 1 UAS, Aerospace Access submits that safety will not be adversely affecte d by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2 ), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted relief specif ic to UAS in circumstances similar, in all material respects, to those presented here in (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

7. The FAA may prescribe any other conditions for safe operation.

In accordance with Section 333 of the FAA Moderni zation and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Con ditions, Aerospace Access requests that the FAA prescribe special condition s for the intended operation of the DJI Inspire 1 UAS, which contain such safety stan dards that the Administrator finds necessary to establish a level of safety equivale nt to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 9 1.7 (a), 91.121, 91.151(b),25

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), a nd 91.417(a) & (b). Such special conditions will permit safe operation of the UAs for the limited purpose of conducting aerial video and photography over cert ain areas of the United States for compensation or hire. FMRA Section 333 sets forth the requirements for considering

whether a UAS will create a hazard to users of th e NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification in ac cordance with any requirements that must be established for the safe operation of the UAS in the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of the DJI Inspire 1 UAS, si nce the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appr opriate safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special Conditions, states the following:

If the FAA finds that the airworthiness regulati ons of this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or unusu al design feature of the aircraft, aircraft engine or propeller, he presc ribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and cont ain such safety standards for the aircraft, aircraft engine or propeller as th e FAA finds necessary to establish a level of safety equivalent to that e stablished in the regulations.

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 an d 14 C.F.R. § 21.16, the FAA may prescribe special conditions for Aerospace Ac cess intended operation of the DJI Inspire 1 UAS, which contain such safety standard s that the Administrator finds necessary to establish a level of safety equivale nt to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), a nd 91.417(a) & (b).

F. A summary that can be published in the federal register, stating: The rules from which Aerospace Access seeks exemption:

Aerospace Access seeks exemption from the require ments 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 exemptio n Aerospace Access seeks:

This exemption will permit Aerospace Access to co mmercially operate an Unmanned Aircraft System (UAS) for the purpose of conducti ng aerial video and photography over certain areas of the United States and Brazi l.

G. Any additional information, views, or argument s available to support Aerospace Access’ request.26

This Petition is made pursuant to the FAA Moderni zation and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary o f Transportation to determine if certain UAS may operate safely in the NAS. As suc h, Aerospace Access’s request for exemption may be granted pursuant to the authorit y 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 auth ority for such UAS to operate without

airworthiness certification.

As discussed in detail above, Aerospace Access wi ll operate the DJI Inspire 1 UAS safely in the NAS, without creating a hazard to u sers of the NAS, or the public, or otherwise pose a threat to national security.

If approved we would like to request the right to exercise the privileges of operating our UAS outside the United States under § 11.83; specifically in Brazil, if permitted by National Civil Aviation Agency of Brazil (ANAC ). They are currently defining

rules and restrictions and Brazil is a vast count ry that will have a high demand in agriculture and the public will benefit from infr a-structure inspections for safety and all the above mentioned benefits applied here in the United States. We understand that we must be compliant with the Standards of t he International Civil Aviation Organization (ICAO) and ANAC.

CONCLUSION

As set forth herein, Aerospace Access seeks an exe mption pursuant to 14 C.F.R. § 11.61 and

Section 333 of the FAA Modernization and Reform Ac t of 2012 (FMRA), which will permit safe operation of the DJI Inspire 1 UAS commercial ly, 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 Aerospace Access to safely, efficiently, and economically operate the DJI Inspire 1 UAS commerc ially within the NAS.

WHEREFORE , in accordance with the Federal Aviation Regulatio ns and the FAA Modernization and Reform Act of 2012, Section 333, Aerospace Access respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151( b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Aerospace Access to operate the DJI Inspire 1 UAS commercially for the purpose of conducting aerial video and photography over certain areas

of the United States and Brazil.

_________________________ Marcello Mattos - President Aerospace Access Corporation27 APPENDICES

APPENDIX – A: DJI Inspire 1 Technical Specification s

APPENDIX – B: DJI Inspire 1 Manufacturer’s User Man ual

APPENDIX – C: DJI Inspire 1 Manufacturer’s Maintena nce Manual

APPENDIX – D: DJI Inspire 1 Manufacturer’s Safety G uidelines28 APPENDIX – A: DJI Inspire 1 Technical Specification s29 APPENDIX – B: DJI Inspire 1 Manufacturer’s User Man ual30 APPENDIX – C: DJI Inspire 1 Manufacturer’s Maintena nce Manual31 APPENDIX – D: DJI Inspire 1 Manufacturer’s Safety G uidelines