PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 1

April 26, 2016

Manager, Flight Standards Service Unmanned Aircraft Systems Integration Office Federal Aviation Administration 800 Independence Avenue, SW Washington, DC 20591

U.S. Department of Transportation, Docket Operatio n West Building Ground Floor Room w

- 12

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



## Petition for Exemption

RE: Petition of Dronefly, Inc. for an Exemption under Section 333 of the FAA Modernization
and Reform Act of 20 12 and from certain rules of 14 C.F.R.

Dear Sir or Madam:

The followin g is a Petition for Exemption relating to Section 333 of the FAA Modernization and Reform Act of 2012. Specifically, this Petition for exemption is filed by DMZ Marketing, LLC., on be half of Dronefly, Inc.

, for exemption from certain rules of 14 C.F.R. Dronefly, Inc. requests Exemption in a n effort to be granted permission to operate small Unmanned Aircraft Systems (“sUAS”) commercially in
the United States of America. These operations would be subject to the current rules and regulations

, not stated herein as rules requested for exemption under Section 333, under the jurisdiction of the Department of Transportation and the Federal Aviation Administration

. Additionally, all operations will adhere to str ict safety rules enforced by Dronefly, Inc. within the

company

. These safety rules will be modeled after recommendations made by the FAA and community

based organizations such as the Academy of Model Aeronautics. Specific conditions relating to the safe operations of sUAS by Dronefly, Inc. will be covered in more detail in the documentation to come,
however

, basi c flight safety parameters often cited by organizations such as the Academy of Model Aeronautics will be closely followed, such as operations at low altitudes and adequate distances away from airports, heliports, and approach areas to name a few.

As was e stablished in Huerta v. Pirker

, an aircraft is, “any” “device” that is “used for flight.” 1 Clearly this broad definition encompasses the types of sUAS the petitioner, Dronefly, Inc. , plans on fl ying commercially within the United States of America and as such, are governed by the rules of 14 C.F.R. Petitioner Name: Dronefly, Inc. Petitioner Contact: Taylor Chien Petitioner Phone Number: 805

- 660

- 3030 Petitioner Email Address: taylor @dronefly.com Petitioner Address: 2630 Townsgate Road Suite I Westlake Village, CA 91361

Document Preparer : DMZ Marketing, LLC. Contact Person: Zach Fiene Phone Number: 608

- 370

- 2858 Email Address: dmzaerial@gmail.com Website: www.dmzaerial.com Address : 1501 Parkview Court Prairie du Sac, WI 53578 USAPETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 2

Due to this, in the following Petition for Exemption and associated documentation, Dronefly, Inc. will
establish clear reasoning as to why their particular commercial sUAS flights should be granted exemption and why his business should be exempt from certain parameters of 14 C.F.R.

A s has been established by the FAA ov er the last year, sUAS pilots are allowed to petiti on for exemption from certain aircraft rules that may be inapplicable to sUAS craft or that may place an undue burden on a peti ti oner looking to turn their sUAS hobb y into a commercial business. Dronefly, Inc. would like to request exemption from certain parameters contained in 14 C.F.R. The specific rules for which Dronefly,

Inc. requests exemption will be covered in further detail in the documentation to come, but, in

summary, Dronefly, Inc. looks to be exempt from the types of rules that may limit or otherwise prevent
their intent of operating sUAS commercially within the United States.

Furthermore, t hese commercial operations would only be conducted after a g ranted Section 333 Exemption and within the outlined conditions below or that may be otherwise highlighted by the Federal Aviation Administration in their Exemption Approval Letter

. With the approval of this exe mption, Dronefly, Inc. will be allowe d to commercially operate sUAS within the United States of America. Specifically, Dronefly, Inc. will be allowed to fly commercially with the DJI Phantom

, DJI Phantom 2

, DJI Phantom 2 Vision

, DJI Phantom 2 Vision +

, DJI Phantom 3 Standard, DJI
Phantom 3 Advanced

, DJI Phantom 3 Professional , DJI Phantom 4, DJI Inspire 1 , and DJI Mat rice 100

. Furthermore, Dronefly, Inc. also seeks permission to utilize any previously

- approved or futurely

approved sUAS that has gone through the Section 333 Exemption Process. Justification for this request will be highlighted in the Small Unmanned A ircraft Systems Section below

. Additionally

, Dronefly, Inc. will be opera ting their sUAS in furtherance of various applications within the following industries; Agriculture

, Cinematography

, Closed

- Set Filming, Fire Services, Infrastructure

, Insurance
, Land Inspection

, Law Enforcement, Search and Rescue, and Real Estate

. Details of these flight crafts; their manuals, safety parameters, operational checklists and more, along with these sUAS flight applications, will be expanded upon in more detail below.

In addition to Dronefly, Inc. ’s Petition for Exemption pertaining to the use of the aforementioned
aircraft and use

- cases, the granting of this Petition will also allow for the commercial operation of sUAS
in Clas s G Airspace, below 400 feet Above Ground Level (“AGL”) , nationwide, or as otherw ise granted in a Certificate of Authorization (“COA”). To start, Dronefly, Inc. will adhere to the blanket Certificate of Authorization that is granted to each entity receiving an Exemption N umber. This COA currently allows for flights nationwi de, in Class G Airspace, below 4 00 feet AGL. 2 Update*

- 14 Further flight areas sought by Dronefly, Inc. will be applied for through the FAA ’s COA Portal. Additionally, with the potential hazards
and obstacles associated with low

- altitude flight

, Dronefly, Inc. will adhere to the Visual Flight Rule (“VFR”) minimums which apply to this airspace. Further details on these operational minimums will be
discussed in the documentation to come.

The Petitio n for Exemption below provides details relating to the proposed applications of commercial sUAS use by Dronefly, Inc. Specifically, Dronefly, Inc. seeks exemption in an effort to conduct commercial operations within the following industries; Agriculture

, Cinematography

, Closed

- S et Filming, Fire Services, Infrastructure

, Insurance
, Land Inspection , Law Enforcement, Search and Rescue, and Real

Estate

.PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 3

In addition to the v ariety of Industry applications highlighted above, this Petition for Exemption will also cover details on various methods of operation and sensor/imagery types for the various applications.

Specifically, Dronefly, Inc. will incorporate a variety of sensor payloads on thei r sUAS in an effort to capture necessary imagery or data types for each specific application or use

- case. Examples of the payload technologies used on the sUAS include, but are not limited to; Visible Light Spectrum Imagery, Near Infrared ( “ NIR ” ) Imagery, Thermal Infrared Imagery, LIDAR, Se nsor Technologies , GPS Guidance, Photogrammetry, Semi

- Autonomous and Autonomous Flight Controllers (For safety), Object Avoidance Systems, and more. With the data collected from these various sensor payloads, Dronefly, Inc. will be able to provide high

- quality data for representatives from the below

- highlighted industries.

 Agriculture: High

- quality actionable data can be utilized by farmers and their partner agronomists, crop consultants, field techs, and interns alike, to support their drive for higher yields and more efficient and effective farming practices.

 Cinematography: High

- Resolution aerial video can provide a new visual communication medium. With video content being one of the fastest

- growing communication mediums for marketing, entertainment, data i nterpretation, and the like, aerial cinematography via UAVs provides an innovative and cost

- effective strategy for capturing new content and information.

 Closed

- Set Filming: High

- quality aerial cinematography for the Closed

- Set Filming Industry provides a cost

- efficient method of aerial content collection for use in movies, commercials, productions, entertainment, viral videos, and the like.

 Fire Services: High

- quality aerial imagery can be used by fire departments to assess ongoing fire situations and e valuate conditions in order to help support ground crews fighting fires.

 Infrastructure: High

- quality, high

- resolution imagery, 3D modeling, and the like, provided to the Infrastructure industry can create a better Infras tructure Industry by promoting safe data

- collection methods and accurate data

- sets

.

 Insurance: High

- qualit y, high

- resolution imagery, coupled with advanced identification and measurement software, can help turn aerial data collected by a sUAS into actionable information for Insuran ce Agents and Adjusters alike.

 Land Inspection: High

- quality, high

- resolution imagery and 3D modeling can help land assessors, government agencies, surveyors, insurers, and the like utilize aerial data to ensure confidence in their operations a nd efficiency in their practices.

 Law Enforcement: High

- quality aerial imagery can help police departments gain an aerial vantage point of an ongoing operation or document evidence after an event has occurred.

 Search and Rescue: High

- quality aerial imag ery can help search crews better survey an area and help coordinate ground

- crews to the correct locations.PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 4  Real Estate: High

- quality, high

- resolution imagery and ae rial cinematography can provide a new perspective for an interested property buyer or real estate investor, allowing for an additional sales tool for land developers, real estate agents, and

prope rty owners

.

The applications highlighted in this petition obviously p rovide high

- quality data to a variety of interested parties in vari ous industries. However, sUAS have more to provide than just interesting pictures and efficient operations. There is also the enhanced safety sUAS provide not only for the operators of these systems, but also, the people around them, communities as a whole, and the National Airspace System (“NAS”).

Within this Petition for Ex emption you will find that the applications highlighted above along with the aircraft systems utilized by Dronefly, Inc. , satisfy the conditions highlighted by the Federal Aviation Administration as requirements for a success ful Section 333 Exemption Petition

. 3 Specifically, the sUAS operating in furtherance of the industry applications above should;

1. Provide a benefit to the public as a whole, and;
2. Not adversely affect safety.

To answer thes e requirements this Petition for Exemption will highlight the public benefits provided by the proposed sUAS operations as well as show the positive affect these operations will have on safety. Specifically, it will be shown that the commercial sUAS flight s proposed in this Petition further the public interest by satisfying what is sometimes referred to as the 3D’s or 4D’s of Unmanned Aerial Vehicle (“UAV”) Intervention

. 4 Basically, the “D” list provides a description of si tuations in which an unmanned vehicle should be used in place of a manned aircraft, more clearly, those situations in which an aerial operation is going to be; Dull, Dirty, Dangerous, or Deep

. 5 This list is often associate d with early military applications utilizing UAV’s. The UK Ministry o f Defense for example has used this list in determining the role of Unmanned Aircraft, highlighting the importance of Unmanned Systems in times where the operation is ; 5

 Dull

- flights re quire persistence or repetition,  Dangerous

- flig hts carry a high degree of risk,  Dirty

- flights must be carri ed out in hazardous environments, or;  Deep

- flights are beyond the range of manned platforms.

In additi on to the justification that will be provided in detail in the pages to come relating to the 4 D’s of UAV Intervention and safety attributes of the sUAS Operations proposed in this Petition for Exemption, it is also important to quickly consider the aircra ft types utilized by Dronefly, Inc.

As mentioned above, Dronefly, Inc. seeks exemption for the utilization of the DJI Phantom

, DJI Phantom
2

, DJI Phantom 2 Vision

, DJI Phantom 2 Vision +

, DJI Phantom 3 Standard, DJI Phantom 3 Advanced

, DJI Phantom 3 Professional , DJI Phantom 4, DJI Inspire 1

, DJI Matrice 100

, and an assortment of other UAVs previously

- approved by t he FAA through the Section 333 Exemption Process (Please see the Small Unmanned Aircraft Systems Title below for further details)

. All of these aircraft ar e small Unmanned Aircraft Systems and are battery

- powere d. Operations conducted by Dronefly, Inc. with these sUAS will adhere to the guidelines set forth by the Federal Aviation Administration and Community

- BasedPETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 5

Organizations such as the Academy of Model Aeronautics (“AMA”). Th rough the adherence of these guidelines Dronefly, Inc. will c ommercially operate their sUAS with an equivalent level of safety, if not superior level of safety, as outlined by the Federal Aviation Administration’s Section 333 Exemption Guidelines.

Furthermore, the commercial sUAS operations being proposed by Dronefly, Inc. in this Petition for Exemption would pr oduce far safer methods of data

- capture than currently

- used collection methods in

w hich manned aircraft are used. Consider that manned aircraft weigh thousands of pounds, are made of metal, are powered by a combus tion engine, carry flammable fuel, and are carrying people. Plus, with the type of data

- capture proposed in this Petition, a manned aircraft would have to operate in high

- risk situations, including, in close proximity to the ground where the risk of an accident is highest and the risk to people and property on the ground is the greatest. Contrasting the two aircraft types, it is clear that a plastic, battery

- powered, unmanned vehicle operating at low altitudes, would be much safer than a multi

- thousand

- pound

, metal aircraft, powered by a combustion engine, and carrying a person at low altitudes.

This fact is furt her bolstere d by the operational and aircraft

- specific parameters giv en by the FAA when deciding whether or not to grant Section 333 Exemptions

. 6 These directives include ;

1. The size of the aircraft
2. The weight of the aircraft
3. The speed of the aircraft
4. The operational capability of the aircraft
5. The aircraft operation’s proximity to airports
6. The aircraft operation’s proximity to populated areas , and;
7. The aircraft operation’s adherence to Visual Line of Sight Rules

As highlighted above, i t is clear that this Petition for Exemption and both the aircraft types and applications state d herein, strictly adhere to the operational and aircraft

- specific parameters highlighted by the FAA for a successful Exemption Petition and thus, support the gra nting of this Exemption. A summary of the reasoning behind this statement can be found below as;

1. All proposed sUAS are s mall

. 2. All proposed sUAS weigh below 55 lbs.
3. All proposed sUAS travel at less than 100 mph (87 Knots)

. 4. All proposed sUAS are capable fl ight systems and have been granted Exemptions previously

. 5. All proposed operations will take place at least 5 miles from an Airport

. 6. All proposed operations will take place in unpopulated area s (U nless prior approval is given {See Condition #34 [“ Proposed Conditions of the Exemption ”] below})

. 7. All proposed operations will adhere to the Visual Line of Sight Rules

.

By adhering to t he parameters published by the FAA and by promoting the public good through the
various Industry applications to be highlighted below, this Pe tition for Exemption on behalf of Dronefly,
Inc. s trongly supports approval.

We kindly ask for your consideration of this Petition for Exemption. Please see the table o f contents below for all our documentation and for assistance in reviewing this Petition. Thank you for your effortsPETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 6

in reviewing this document and we look forward to your response. If you have any questions while reviewing this document, please do not h esitate to ask. You can contact the Preparer of this document for all questions relating to this petition and they can be reached by email at dmzaerial@gmail.com

. Further contact information can be found at th e top of this Petition or on the following website s; www.dronefly.com or www.dmzaerial.com . Once again

, thank you for your efforts in reviewing this Petition for Exemption and we look forward to your reply.

Best Regards,

DMZ Marketing, LLC. (DMZ Aerial)



## Contact Information

Document Preparer:

DMZ Marketing, LLC. 1501 Parkview Court Prairie du Sac, W I 53578 USA
Contact: Zach Fiene Phone: 608

- 370

- 2858 Email: dmzaerial@gmail.com Website: www.dmzaerial.com

Petitioner:

Dronefly, Inc. 2630 Townsgate Road Suite I Westlake Village, CA 91361 Taylor Chien
805

- 660

- 3030 taylor@dronefly.com



## Disclosure

The Petitioner for this exemption is Dronefly, Inc.

, a s mall Unmanned Aircraft Systems (sUAS) distributor, reseller, and consultant

. Dronefly Inc., contracted DMZ Marketing, LLC.

, also known as DMZ

Ae rial, to help formulate exemption docu ments and work with them to help promote safe flying practices and appropriate operations.PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 7



## T able of Contents

Petition for Exemption

................................ ................................ ................................ ................................ .. 1

Contact Information

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

Disclosure

................................ ................................ ................................ ................................ ...................... 6
The Applicant

................................ ................................ ................................ ................................ .............. 12
Commitment to Safety

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

Exper ience and Expertise

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

Privacy

................................ ................................ ................................ ................................ ..................... 13
Publishable Summary

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

Petitioner’s Contact Information

................................ ................................ ................................ ................ 15
Proposed sUAS Operations

................................ ................................ ................................ ......................... 15
Small Unmanned Aircraft Systems

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

DJI Phantom

................................ ................................ ................................ ................................ ........ 16

DJI Phantom 2

................................ ................................ ................................ ................................ ..... 17

DJI Phantom 2 Vision

................................ ................................ ................................ .......................... 17

DJI Phantom 2 Vision +

................................ ................................ ................................ ........................ 18

DJI Phantom 3 Standard

................................ ................................ ................................ ...................... 18

DJI Phantom 3 Advanced

................................ ................................ ................................ .................... 19

DJI Phantom 3 Professional

................................ ................................ ................................ ................ 19

DJI Phantom 4

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

DJI Inspire 1

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

DJI Matrice 100

................................ ................................ ................................ ................................ ... 20
Unmanned Flight Crew

................................ ................................ ................................ ........................... 21
Unmanned Flight Conditions

................................ ................................ ................................ .................. 21
Unmanned Flight Operations

................................ ................................ ................................ .................. 22
Aircraft and Equivalent Level of Safety

................................ ................................ ................................ ....... 23
National Security

................................ ................................ ................................ ................................ ......... 23
Proposed Conditions of the Exemptio n

................................ ................................ ................................ ...... 24
Exemptions Requested & Applicable Conditions/Reasoning

................................ ................................ ..... 30
14 C.F.R 21(h): Airworthiness Certificates

................................ ................................ .............................. 30

14 C.F.R. 27 : Airworthiness Standards

- Normal Category Rotorcraft

................................ .................... 31
14 C.F.R. 43.7: Authorized Maintenance/Repair/Alteration Personnel

................................ ................. 31PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 8

14 C.F.R. 43.11: Dispositions of Records for Inspections

................................ ................................ ........ 31
14 C.F.R. 45.11: Making of Products

................................ ................................ ................................ ....... 32
14 C.F.R. 45.23(b): Display of Mark s; General

................................ ................................ ........................ 32
14 C.F.R. 45.27: Marking of the Aircraft

– Rotorcraft

................................ ................................ ............. 32

14 C.F.R. 45.29: Size of Marks

................................ ................................ ................................ ................. 33

14 C.F.R. 61.3: Require ment for Certificates, Ratings, and Authorizations

................................ ............ 33
14 C.F.R. 61.23(a) and (c): Medical Certificates

– Requirements and Duratio n

................................ ..... 34
14 CFR 61.101(e) (4) and (5): Recreational Pilot Privileges and Limitations

................................ ........... 34
14 CFR 61.113 (a) & (b): Private Pilot Privileges and Limitations

– Pilot In Command

........................... 35
14 C.F.R. 61.315(a)(c): Privileges and Limits of Sport Pilot’s License

................................ ...................... 36
14 C.F.R. 91.7(a): Civil Aircraft Airworthiness

................................ ................................ ......................... 40
14 C.F.R. 91.9(b)(2): Civil Aircraft Flight Manual

................................ ................................ ..................... 40
14 C.F.R. 91.9(c): Civil Aircraft Marking, Placards

................................ ................................ ................... 40
14 C.F.R. 91.103: Preflight Action

................................ ................................ ................................ ........... 41

14 C.F.R. 91.105: F light Crewmembers at Stations

................................ ................................ ................. 41
14 C.F.R. 91.109: Flight Instruction

................................ ................................ ................................ ......... 42
14 C.F.R. 91.113(b): Right

- of

- Way Rules

................................ ................................ ................................ . 43

14 C.F.R. 91.119 : Minimum Safe Altitudes

................................ ................................ ............................. 44
14 C.F.R. 91.121: Altimeter Settings

................................ ................................ ................................ ....... 45
14 C.F.R. 91.151(a): Fuel Requirements for VFR Flight Conditions

................................ ......................... 46
14 C.F.R. 91.203(a) and (b): Civil Aircraft

– Certifications Required

................................ ....................... 47
14 C.F.R. 215: ATC Transponder and Altitude Reporting Equipment and Use

................................ ....... 47

14 C.F.R. 91.403: General

................................ ................................ ................................ ........................ 49
14 C.F.R. 91.405(a): Mainte nance Required

................................ ................................ ........................... 50
14 C.F.R. 91.407(a)(1): Operation after Maintenance or Alteration

................................ ....................... 50
14 C.F.R. 409(a)(1) and (2): Inspections

................................ ................................ ................................ .. 50
14 C.F.R. 91.417(a) and (b): Maintenance Records

................................ ................................ ................ 51

Privacy

................................ ................................ ................................ ................................ ......................... 52
Public Interest and Safety

................................ ................................ ................................ ........................... 52
Agriculture

................................ ................................ ................................ ................................ .......... 53
Cinematography

................................ ................................ ................................ ................................ .. 56

Closed

- Set Filming

................................ ................................ ................................ ............................... 58

Fire Services

................................ ................................ ................................ ................................ ........ 60PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 9

Infrastructure

................................ ................................ ................................ ................................ ...... 62

Insurance

................................ ................................ ................................ ................................ ............. 6 5
Land Inspection

................................ ................................ ................................ ................................ ... 66

Law Enforcement

................................ ................................ ................................ ................................ 68

Real Estate

................................ ................................ ................................ ................................ ........... 70

Search and Rescue

................................ ................................ ................................ .............................. 72

Reg ulations Requested for Exemption

................................ ................................ ................................ ....... 74
Appendix 1: Regulations Requested for Exemption

– List

................................ ................................ ...... 74

Exhibit List

................................ ................................ ................................ ................................ ................... 74

Exhibit 1A: D ronefly, Inc. Operations Manual

................................ ................................ ........................ 74
Exhibit 1B: Dronefly, Inc. Motion Picture and Television Operations Manual (“MPTOM”)

................... 74
Exhibit 2: Dronefly, Inc. Logbook Example

................................ ................................ .............................. 74
Exhibit 3: Dronefly, Inc. Visual Observer Training Procedures & Guide

................................ ................. 75
Visual Observer Training Procedures

................................ ................................ ................................ .. 75

Visual Observer T raining Guide

................................ ................................ ................................ ........... 75
Exhibit 4: Dronefly, Inc. Pilot In Command Training Guide

................................ ................................ ..... 75
Pilot In Command Training Procedures

................................ ................................ .............................. 75
Pilot in Command Training Guide

................................ ................................ ................................ ....... 75

Exhibit 5: DJI Phanto m

................................ ................................ ................................ ............................ 75

Exhibit 6: DJI Phantom User Manual

................................ ................................ ................................ ....... 75

Exhibit 7: DJI Phantom Quick Start Guide

................................ ................................ ............................... 76

Exhibit 8: DJI Phantom Features

................................ ................................ ................................ ............. 76
Exhibit 9: DJI Phantom Specifications

................................ ................................ ................................ ..... 76
Exhibit 10: DJI Phantom Flight Controller User Manual

................................ ................................ ......... 76

Exhibit 11: DJI Phantom Lithium Pol ymer Battery Guide

................................ ................................ ....... 76
Exhibit 12: DJI Phantom Pilot Training Guide

................................ ................................ ......................... 76

Exhibit 13: DJI Phantom 2

................................ ................................ ................................ ....................... 76

Exhibit 14: DJI Phantom 2 User Manual

................................ ................................ ................................ .. 77

Exhibit 15: DJI Phantom 2 Quick Start Guide

................................ ................................ .......................... 77

Exhibit 16: DJI Phantom 2 Features

................................ ................................ ................................ ........ 77
Exhibit 17: DJI Phantom 2 Specifications

................................ ................................ ................................ 77
Exhibit 18: DJI Phantom 2 Flight Controller User Manual

................................ ................................ ...... 77
Exhibit 19: DJI Phantom 2 Smart Battery Safety Manual

................................ ................................ ........ 77PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 10

Exhibit 20: DJI Phantom 2 Pilot Training Guide

................................ ................................ ...................... 77

Exhibit 21: DJI Phantom 2 Vision

................................ ................................ ................................ ............ 78

Exhibit 22: DJI Phantom 2 Vision User Manual

................................ ................................ ....................... 78

Exhibit 23: DJI Phantom 2 Vision Quick Start Guide

................................ ................................ ............... 78

Exh ibit 24: DJI Phantom 2 Vision Features

................................ ................................ ............................. 78
Exhibit 25: DJI Phantom 2 Vision Specifications

................................ ................................ ..................... 78
Exhibit 26: DJI Phantom 2 Vision Flight Controller User Manual

................................ ............................ 78
Exhibit 27: DJI Phantom 2 Vision Smart Battery Manual

................................ ................................ ........ 78
Exhibit 28: DJI Phantom 2 Vision Pilot Training Guide

................................ ................................ ............ 79

Exhibit 29: DJI Phantom 2 Vision +

................................ ................................ ................................ .......... 79

Exhibit 30: DJI Phantom 2 Vision + User Manual

................................ ................................ .................... 79

Exhibit 31: DJI Phantom 2 Vision + Quick Start Guide

................................ ................................ ............ 79

Exhibit 32: DJI Phantom 2 Vision + Features

................................ ................................ ........................... 79

Exhibit 3 3: DJI Phantom 2 Vision + Specifications

................................ ................................ .................. 79
Exhibit 34: DJI Phantom 2 Vision + Flight Controller User Manual

................................ ......................... 79
Exhibit 35: DJI Phantom 2 Vision + Smart Battery Manual

................................ ................................ ..... 80
Exhibit 36: DJI Phantom 2 Vision + Pilot Training Guide

................................ ................................ ......... 80

Exhibit 37: DJI Phantom 3 Standard

................................ ................................ ................................ ........ 80

Exhibit 38: DJI Pha ntom 3 Standard User Manual

................................ ................................ .................. 80

Exhibit 39: DJI Phantom 3 Standard Quick Start Guide

................................ ................................ .......... 80

Exhibit 40: DJI Phantom 3 Standard Features

................................ ................................ ......................... 80
Exhibit 41: DJI Phantom 3 Standard Specifications

................................ ................................ ................ 81
Exhibit 42: DJI Phantom 3 Standard Flight Controller System

................................ ................................ 81
Exhibit 43: DJI Phantom 3 Standard Smart Battery Manual

................................ ................................ ... 81
Exhibit 44: DJI Phantom 3 Standard Safety/Preflight Checklist and Guidelines Training

....................... 81

Exhibit 45: DJI Phantom 3 Advanced

................................ ................................ ................................ ...... 81

Exhibit 46: DJI Phantom 3 Advanced User Manual

................................ ................................ ................. 81

Exhibit 47: DJI Phantom 3 Advanced Quick Start Guide

................................ ................................ ......... 81

Exhibit 48: DJI Phantom 3 Advanced Features

................................ ................................ ....................... 82
Exhibit 49: DJI Phantom 3 Advanced Specifications

................................ ................................ ............... 82
Exhibit 50: DJI Phantom 3 Advanced Flight Controller System

................................ ............................... 82
Exhibit 51: DJI Phantom 3 Advanced Smart Battery Manual

................................ ................................ .. 82
Exhibit 52: DJI Phantom 3 Advanced Safety/Preflight Checklist and Guidelines Training

...................... 82PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 11

Exhibit 53: DJI Phantom 3 Professiona l

................................ ................................ ................................ .. 82

Exhibit 54: DJI Phantom 3 Professional User Manual

................................ ................................ ............. 82

Exhibit 55: DJI Phantom 3 Professional Quick Start Guide

................................ ................................ ..... 83

Exhibit 56: DJI Phantom 3 Professional Features

................................ ................................ ................... 83

Exhib it 57: DJI Phantom 3 Professional Specifications

................................ ................................ ........... 83
Exhibit 58: DJI Phantom 3 Professional Flight Controller System

................................ ........................... 83
Exhibit 59: DJI Phantom 3 Professional Smart Battery Manual

................................ .............................. 83
Exhibit 60: DJI Phantom 3 Professional Safety/Preflight Checklist and Guidelines Training

.................. 83

Exhibit 61: DJI Phantom 4

................................ ................................ ................................ ....................... 83

Exhibit 62: DJI Phantom 4 User Manual

................................ ................................ ................................ .. 84

Exhibit 63: DJI Phantom 4 Quick Start Guide

................................ ................................ .......................... 84

Exhibit 64: DJI Phantom 4 Features

................................ ................................ ................................ ........ 84
Exhibit 65: DJI Phantom 4 Specifications

................................ ................................ ................................ 84

Exhibit 66: D JI Phantom 4 Flight Controller System

................................ ................................ ............... 84
Exhibit 67: DJI Phantom 4 Smart Battery Manual

................................ ................................ ................... 84
Exhibit 68: DJI Phantom 4 Safety/Preflight Checklist and Guidelines Training

................................ ....... 84
Exhibit 69: DJI Inspire 1

................................ ................................ ................................ ........................... 85
Exhibit 70: DJI Inspire 1 User Manual

................................ ................................ ................................ ..... 85

Exhibit 71: DJI Inspire 1 Quick Start Guide

................................ ................................ .............................. 85
Exhibit 72: DJI Inspire 1 Features

................................ ................................ ................................ ............ 85
Exhibit 73: DJI Inspire 1 Specifications

................................ ................................ ................................ .... 85
Exhibit 74: DJI Inspire 1 Flight Controller System

................................ ................................ ................... 85

Exh ibit 75: DJI Inspire 1 Smart Battery Manual

................................ ................................ ...................... 85

Exhibit 76: DJI Matrice 100

................................ ................................ ................................ ..................... 85

Exhibit 77: DJI Matrice 100 User Manual

................................ ................................ ................................ 86

Exhibit 78 : DJI Matrice 100 Features

................................ ................................ ................................ ...... 86
Exhibit 79: DJI Matrice 100 Specifications

................................ ................................ .............................. 86
Exhibit 80: DJI Matrice 100 Smart Battery Manual

................................ ................................ ................. 86

Exhib it 81: Aircraft List (Previously Approved Pursuant to Section 333 Exemption Process)

................ 86

References

................................ ................................ ................................ ................................ .................. 86

MPTOM Reference

................................ ................................ ................................ ................................ ...... 88
Exemption References

................................ ................................ ................................ ................................ 89PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 12



## The Applic ant

The Applicant seeking this Exemption is Dronefly, Inc. , headquartered at;

2630 Townsgate Road Suite i Westlake Village, CA 91361
USA

Dronefly, Inc. is a l eader in the drone aerospace Industry. The company currently focus es on the sale of consumer drones and accessories. Additionally, the business also offer s a full line of service s, including repairs and installs. Dronefly offer s the lowest price and the f astest shipping on all of today’s hottest selling consumer UAV platforms . Dronefly's founders

, Taylor Chien (CEO) and Frank Tesoro (CFO)

, share the same vision of providing high tech aerial vehicles for both profes sional and recreational uses. It is their goal to provide customers with the best equipment possible along with the best shopping experience.

Furthermore, Dronefly has also recently added online training seminars to their website, allowing new users to develop a better grasp on sUAS flying before their new UAV system leaves the box. It is this commitment to customer service and training that sets Dronefly apart from its competitors. Furthermore, with a dedicated operations staff that includes former professional UAV pilots with many years of exp erience with both hobbyist and professional

- grade cinema platforms, Dronefly is unique in its drive to supply the next generation of sUAS pilots.



### Commitment to Safety

Dr onefly, Inc. has always been committed to safety. The founder s of the company previously worked i n the Aerial Cinematography business , performing a wide array of tasks including UAV flights for video productions around the world. Having worked in the pot entially hazardous industry prior to forming the company and seeing how a focus on safety kept former employers’ wor kforces safe, Dronefly continues
to strive to f oster safe working environments and sUAS operations.

Additionally, the company’s focus on pr oviding top

- notch training to customers sets it apart and helps foster a safer UAV community. As one of the largest UAV Sales companies in the world, Dronefly is uniquely positioned to positively impact a large segment of the UAV marketp lace and this focu s on safety will continue to playout on the sales side as well as their new commercial

- services segment.



### Experience and Expertise

Dronefly, Inc., was founded by Taylor Chien and Frank Tesoro and today co nsists of 15 employees and experts in the sUAS space. Many of the company’s employees, including the founders, have been flying small hobbyist model aircraft for many years. Taylor specifically has been flying since he was ten yearsPETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 13

old and eventually wo uld fly UAVs professionally around the world for a couple years. Additionally, his brother Justin, who serves as Dronefly’s Chief Operating Officer, flew professionally for Coptervision, an early aerial cinematography business that did work on such films as Transformers.

Furthermore, Dronefly is also the largest online distributor for DJI, which is the largest consumer UAV company in the world. Dronefly’s extensive work with DJI platforms as well as many other platforms from companies like 3D Robotics, ma ke it a great candidate for commercial sUAS operations. The business is filled with UAV experts who have done everything from train people on UAV systems, to providing customer support and repairing units.



### Privacy

Privacy is important in any business, but especially one in which imagery is captured. For this reason Dronefly, Inc. will use commonly accepted practices in order to secure imagery. A few practices they will put into action include; obtai ning proper permissions and consent, keeping data on a secure computer system, and the like. Additionally, they will also seek what is required by law to remain compliant and secure in terms of data/imagery privacy.



## Publishable Summ ary

DMZ Marketing, LLC. files this petition for exemption on behalf of Dronefly, Inc.

, a s mall Unmanned Aircraft Systems (sUAS) distri butor, rese ller, and consultant. Dronefly, Inc. is seeking exemption from certain parameters of 14 C.F.R. in orde r to commercially operate sUAS within the United States in the following industries; Agriculture

, Cinematography

, Closed

- Set Filming, Fire Services, Infrastructure

, Insurance
, La nd Inspection , Law Enforcement, Search and Resue, and Real Estate

. Specifically, Dronefly, Inc. requests exemption from the following Federal Aviation Administration rules;

1. 14 C.F.R 21(h): Airworthiness Certificates

2. 14 C.F.R. 27: Airworthiness Standards

- Normal Category Rotorcraft
3. 14 C.F.R. 43.7: Authorized Maintenance/Repair/Alteration Personnel

4. 14 C.F.R. 43.11: Dispositions of Records for Inspections

5. 14 C.F.R. 45.11: Making of Products
6. 14 C.F.R. 45.23(b): Display of Marks; General

7. 14 C.F.R. 45.27: Marking of the Aircraft

– Rotorc raft
8. 14 C.F.R. 45.29: Size of Marks
9. 14 CFR 61.3: Requirement for Certificates, Ratings, and Authorizations
10. 14 CFR §§ 61.23(a) and (c): Medical Certificates

– Requirements and Duration

11. 14 CFR 61.101(e) (4) and (5): Recreational Pilot Privileges and Limitati ons 12. 14 CFR 61.113(a) & (b): Private Pilot Privileges and Limitations

– Pilot In Command
13. 14 C.F.R. 61.315(a): Privileges and Limits of Sport Pilot’s LicensePETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 14

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

15. 14 C.F.R. 91.9(b)(2): Civil Aircraft Flight Manual
16. 1 4 C.F.R. 91.9(c): Civil Aircraft Marking, Placards

17. 14 C.F.R. 91.103: Preflight Action
18. 14 C.F.R. 91.105: Flight Crewmembers at Stations
19. 14 C.F.R. 91.109: Flight Instruction
20. 14 C.F.R. 91.113(b): Right

- of

- Way Rules
21. 14 C.F.R. 91.119: Minimum Safe Altitudes
22. 1 4 C.F.R. 91.121: Altimeter Settings
23. 14 C.F.R. 91.151(a): Fuel Requirements for VFR Flight Conditions

24. 14 C.F.R. 91.203(a) and (b): Civil Aircraft

– Certifications Required
25. 14 C.F.R. 215: ATC Transponder and Altitude Reporting Equipment and Use
26. 14 C.F.R. 91 .403: General
27. 14 C.F.R. 91.405(a): Maintenance Required
28. 14 C.F.R. 91.407(a)(1): Operation after Maintenance or Alteration
29. 14 C.F.R. 409(a)(1) and (2): Inspections
30. 14 C.F.R. 91.417(a) and (b): Maintenance Records

The approval of this Petition for Exemption would allow for the commercial operation of small Unmanned Aircraft Systems by Dronefly, Inc. These commercial operations would strictly adhere to all Federal Aviation Administration rules and regulations not stated herein a s rules requested for exemption. The commercial operations flown by Dronefly, Inc. , if this Petition were granted, would be flown utilizing one of the following aircraft platforms; the DJI Phantom

, DJI Phantom 2

, DJI Phantom 2
Vision

, DJI Phantom 2 Vision +

, DJI Phantom 3 Standard, DJI Phantom 3 Advanced

, DJI Phantom 3
Professional , DJI Phantom 4, DJI Inspire 1 , DJI Matrice 100

, or other UAV Syste m s previously

- approved via the Section 333 Exemption Process

. Specifically, the commercial operations utilizing t hese
unmanned aircraft would center around the following industry applications; Agriculture

, Cinematography

, Closed

- Set Filming, Fire Services, Infrastructure

, Insurance
, Land Inspection , Law Enforc ement, Search and Rescue, and Real Estate

. Additionally, a ll the industry applications highlighted above would include one or more of the unmanned
aircraft noted above flying no more than 400 feet Above Ground Level (“AGL”) o r in airspace otherwise

spec ified in a granted Certificate of Authorization (“COA”).

Furthermore, this Petition for Exemption should be granted to Dronefly, Inc. because th e operation of the
listed sUAS above will provide for commercial operations while maintaining an equivalent level of safety as would be p rovided by the above

- listed rules. Additionally, as will be highlighted below, the small Unmanned Aircraft utilized by Dronefly, Inc. will provide methods of aerial data collection far safer than
the alternative of manned ai rcr aft collection of the same data

- sets. Low altitude data

- collection flights, in close proximity to people and property, are far safer when accomplished using a battery

- pow ered sUAS weighing less than 55 lbs., than with a combustion

- engine

- powered, multi

- t housand

- pound, manned aircraft, with flammable fuel onboard.

Considering the seve n factors highlighted by the FAA as parameters for successful Section 333 Exemption Petitions, including; Size, Weight, Speed, Operational Capability, Proximity to Airport s, Proximity to Populated Areas, and Operations within Visual Line of Sight

, 6 this Petition supports the Petitioner’sPETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 15

re quest for exemption relating to each operational and aircraft

- specific parameter . Specifically, the
ai rcraft utilized by Dronefly, Inc. a re in the small

- size category, they ar e below the 55 lbs. weight limit

, they travel at less than 100 mph, they are proven flight platforms based on previously granted petitions, all operatio ns will be conducted at least 5 miles from an airport and over unpopulated areas (unless otherwise granted permis sion by the FAA in a granted Certificate of Authorizatio n), and all flights will be
conducted within Visual Line of Sight.

In addition , the d ata

- collectio n flights provided by the sUAS highlighted in this Petition will promote safer operations for professional service providers in the aforementioned industries.



## Petitioner’s Contact Information

Petitioner:

Drone fly, Inc. 2630 Townsgate Road Suite I Westlake Village, CA 91361
805

- 660

- 3030 taylor@dronefly.com



## Document Preparer:

DMZ Marketing, LLC. 1501 Parkview Court Prairie du Sac, WI 53578 USA
Contact: Zach Fiene Phone: 608

- 370

- 2858
E mail: dmzaerial@gmail.com Website: www.dmzaerial.com



## Proposed sUAS Operations

Small Unmanned Aircraft Systems

This Petition for Exemption under Section 333 will perm it the Petitioner to operate the DJI Phantom

, DJI
DJI Phantom 2

, DJI Phantom 2 Vision

, DJ I Phantom 2 Vision + , DJI Phantom 3 Standard, DJI Phantom 3
Advanced

, DJI Phantom 3 Professional , DJI Phantom 4, DJI Inspire 1

, and DJI Matrice 100 . Additionally, the Petitioner requests permission to utilize any previo usly

- approved, aircraft to be approved in the
future , or substantially

- similar sUAS that have navigated the Section 333 Exe mption Process.

Specif ically, the Petitioner asks to be allowed to operate the following aircraft for commercial use within the United States of America;PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 1 6

1. All UAS previously approved pursuant to the Section 333 Exemption Process,
2. All UAS to be approved in the future pursuant to the Section 333 Exemption Process, and;
3. Any substantially similar multirotor or fixed

- wing aircraft.

On March 7 th , 2016, the FAA granted an amendment to a Petition put forth by Measure, a 32 Advisors Company, LLC, seeking to operate any UAS that have been previously approved by the Secretary of Transportation pursuant to the Section 333 Exemption Process. 13

Dronefly, Inc. would like to be granted this same permission and allowed to operate any previously

approved aircraft listed in Regulatory Docket FAA

- 2007

- 3330 on the Regulations.gov website, which can be found below in the last Exhibit

.

Furtherm ore, Dronefly, Inc. would like to be granted permission to operate any UAS that is approved in
the fut ure, pursuant to the Section 333 Exe mption Process. Although Dronefly will likely not u tilize every current and futurely

- approved aircraft , its business opera tes in a constantly

- changing field in which the adoption and experimentation of new aircraft is r equired.

Fina lly, Dronefly would also like to be granted permission to utilize any substantially similar multirotor or
fixed

- wing aircraft for commercial services within the United States.

As with the specific aircraft cited, all of the aircraft referenc ed relating to previously

- approved, futurely

approved, or substantially similar aircraft, will be utilized with safety in mind and adhere to the same conditions and limitations stated herein or that may be highlighted by the then

- current UAV regulations
fr om the Federal Aviation Administration.

Further operating characteristics, specifications, and other important craft

- specific information on the
DJI Phantom

, DJI Phantom 2

, DJI Phantom 2 Vision

, DJI Phantom 2 Vision + , DJI Phantom 3 Standard, DJI
Phantom 3 Advanced

, DJI Phantom 3 Professional

, DJI Inspire 1

, and DJI Matrice 100 are covered in detail starting with Exhibit 5

. Each of these documents are publically circulated and have been previousl y vetted by the FAA in previously granted Petitions for Exemption under Sect ion 333. In the
aircraft summaries below , please see the references to previously granted petitions for the use of each specific aircraft type in commercial operations within the United States

.



### DJI Phantom

The requested exemption will permit the Petitioner the right to use the DJI Phantom Quadcopter for

commerc ial use within the United States of America and under the strict adherence of FAA Guidelines,
ATO

- Issued COA’s, and the like. The DJI Phantom has a maximum weight of <1200 grams including technical payloads and batteries. Furthermore, this quadcopter is capable of a max flight speed of 10 meters per second and has the following abilities;

 Vertical Take

- Off  Vertical Landing  Hover

- Hold Position  Simultaneous Vertical & Horizontal Movement  Maximum Flight Speed Abilities in every lateral directionPETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 17

For easy re viewing, please see Phantom

- Specific Exhibits below for more information on the DJI Phantom craft, its specifications, abilities, and more. Additionally, please consider the FAA’s previous review of these exhibits and granting of Petitions using these sup porting documents for the commercial use of the DJI Phantom in the following listed Exemptions;

 Douglas Trudeau

– Tierra Antigua Real Estate

– Exemption No. 11138



### DJI Phantom 2

The requested exemption will permit the Petitioner the right to use the DJI Phantom 2 Quadcopter for commercial use within the United States of America and under the strict adherence of FAA Guidelines,
ATO

- Issued COA’s, and the like. The DJI Phantom 2 has a maximum take

- off wei ght of 1300 grams including technical payloads and batteries. Furthermore this quadcopter is capable of a max flight speed of 15 meters per second and has the following abilities;

 Vertical Take

- Off  Vertical Landing  Hover

- Hold Position  Simultaneous Vertic al & Horizontal Movement  Maximum Flight Speed Abilities in every lateral direction

For easy reviewing, please see the Phantom 2

- Specific Exhibits below for more information on the DJI Phantom 2 craft, its specifications, abilities, and more. Additionally, please consider the FAA’s previous review of these exhibits and granting of Petitions using these supporting documents for the commercial use of the DJI Phantom 2 in the following listed Exemptions;

 Marco Zvanik

– Ventus Wind, LLC.

– Exemption No. 11398



### DJI Phantom 2 Vision

The requested exemption will permit the Petitioner the right to use the DJI Phantom 2 Vision Quadcopter for commercial use within the Uni ted States of America and under the strict adherence of FAA Guidelines, ATO

- Issued COA’s, and the like. The DJI Phantom 2 Vision has a weight of 1160 grams including propellers and batteries. Furthermore

, this quadcopter is capable of a max flight speed of 15 meters per second and has the following abilities;

 Vertical Take

- Off  Vertical Landing  Hover

- Hold Position  Simultaneous Vertical & Horizontal Movement  Maximum Flight Speed Abilities in every lateral direction

For easy reviewing, please see the Phanto m 2 Vision

- Specific Exhibits below for more information on the DJI Phantom 2 Vision craft, its specifications, abilities, and more. Additionally, please consider the FAA’sPETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 18

previous review of these exhibits and granting of Petitions using these supporting documents for the commercial use of the DJI Phantom 2 Vision in the following listed Exemptions;

 Douglass Trudeau

– Tierra Antigua Real Estate

– Exemption Number 11138



### DJI Phantom 2 Vision +

The requested exemption will permit the Petitioner the right to use the DJI Phantom 2 Vision + Quadcopter for commercial use within the United States of America and under the strict adherence of FAA Guidelines, ATO

- Issued COA’s, and the like. The DJI Phantom 2 Vision + has a weight of 1242 grams including propellers and batteries. Furthermore this quadcopter is capable of a max flight speed of 15 meters per second and has the following abilities;

 Vertical Take

- Off  Vertic al Landing  Hover

- Hold Position  Simultaneous Vertical & Horizontal Movement  Maximum Flight Speed Abilities in every lateral direction

For easy reviewing, please see Phantom 2 Vision +

- Specific Exhibits below for more information on the
DJI Phantom 2 Vision + craft, its specifications, abilities, and more. Additionally, please consider the FAA’s previous review of these exhibits and granting of Petitions using these supporting documents for the commercial use of the DJI Phantom 2 Vision + in the following li sted Exemptions;

 Douglass Trudeau

– Tierra Antigua Real Estate

– Exemption Number 11138  Anton Ewing

– Video Solutions, LLC.

– Exemption Number 11189  Michael Singer

– Singers Creations

– Exemption Number 11191



### DJI Phantom 3 Standard

The requested exemptio n will permit the Petitioner the right to use the DJI Phantom 3 Standard Quadcopter for commercial use within the United States of America and under the strict adherence of FAA Guidelines, ATO

- Issued COA’s, and the like. The DJI Phantom 3 Standard has a w eight of 1216 grams including propellers and batteries. Furthermore this quadcopter is capable of a max flight speed of 16 meters per second and has the following abilities;

 Vertical Take

- Off  Vertical Landing  Hover

- Hold Position  Simultaneous Vertical & H orizontal Movement  Maximum Flight Speed Abilities in every lateral direction

For easy reviewin g, please see Phantom 3 Standard

- Specific Exhibits below for more informati on on the
DJI Phantom 3 Standard craft, its specif ications, abilities, and more.PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 19



### DJI Phantom 3 Advanced

The requested exemption will permit the Petitioner the right to use the DJI Phantom 3 Advanced Quadcopter for commercial use within the Uni ted States of America and under the strict adherence of FAA Guidelines, ATO

- Issued COA’s, and the like. The DJI Phantom 3 Advanced has a weight of 1280 grams including propellers and batteries. Furthermore, this quadcopter is capable of a max flight spee d of 16 meters per second and has the following abilities;

 Vertical Take

- Off  Vertical Landing  Hover

- Hold Position  Simultaneous Vertical & Horizontal Movement  Maximum Flight Speed Abilities in every lateral direction

For easy reviewing, please see Phantom 3 Advanced

- Specific Exhibits below for more information on the DJI Phantom 3 Advanced craft, its specifications, abilities, and more. Additionally, please consider the FAA’s previous review of these exhibits and granting of Petitions using these supportin g documents for the commercial use of the DJI Phantom 3 Advanced in the following listed Exemption;

 Jeffery Greer

– Berkshire Hathaway Home Services

– Exemption Number 11587/11587A



### DJI Phantom 3 Professional

The requested exemption will permit the Petitioner the right to use the DJI Phantom 3 Professional Quadcopter for commercial use within the United States of America and under the strict adherence of
FAA Gu idelines, ATO

- Issued COA’s, and the like. The DJI Phantom 3 Professional has a weight of 1280 grams including propellers and batteries. Furthermore, this quadcopter is capable of a max flight speed of 16 meters per second and has the following abilities;

 Vertical Take

- Off  Vertical Landing  Hover

- Hold Position  Simultaneous Vertical & Horizontal Movement  Maximum Flight Speed Abilities in every lateral direction

For easy reviewing, please see the Phantom 3 Professional

- Specific Exhibits below for more inform ation on the DJI Phantom 3 Professional craft, its specifications, abilities, and more. Additionally, please consider the FAA’s previous review of these exhibits and granting of Petitions using these supporting
documents for the commercial use of the DJI Phantom 3 Professional in the following listed Exemption;

 Jeffery Greer

– Berkshire Hathaway Home Services

– Exemption Number 11587/11587APETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 20



### DJI Phantom 4

The requested exemption will permit the Petition er the right to use the DJI Phantom 4 Quadcopter for commercial use within the United States of America and under the strict adherence of FAA Guidelines,
ATO

- Issued COA’s, and the like. The DJI Phantom 4 has a weight of 1380 grams including propellers and batteries. Furthermore, this quadcopter is capable of a max flight speed of 20 meters per second and has the following abilities;

 Vertical Take

- Off  Vertical Landing  Hover

- Hold Position  Simultaneous Vertical & Horizontal Movement  Maximum Flight Speed Abi lities in every lateral direction  Object Avoidance Technologies

For easy reviewing, please see the Phantom 4

- Specific Exhibits below for more information on the DJI Phantom 4 craft, its specifications, abilities, and more.



### DJI Inspire 1

The requested exemption will permit the Petitioner the right to use the DJI Inspire 1 Quadcopter for
commercial use within the United States of America and under the strict adherence of FAA Guidelines,
ATO

- Issued COA’s, and the like. The DJI Inspire 1 has a weight of 2935 grams including the battery payload. Furthermore, this quadcopter is capable of a max flight speed of 22 meters per second and has the following abilities ;

 Vertical Take

- Off  Vertical Landing  Hover

- Hold Position  Simultaneous Vertical & Horizontal Movement  Maximum Flight Speed Abilities in every lateral direction

For easy reviewing, please see the Inspire

- Specific Exhibits below for more information on the D JI Inspire 1 craft, its specifications, abilities, and more. Additionally, please consider the FAA’s previous review of these exhibits and granting of Petitions using these supporting documents for the commercial use of the DJI Inspire 1 in the following listed Exemptions;

 Jeffery Greer

– Berkshire Hathaway Home Services

– Exemption Number 11587/11587A  Phillip Stiles

– GPS Development, LLC dba SkyViewHD

– Exemption Number 11399/11399A



### DJI Matrice 100PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 21

The requested exemption will permit the Petitioner the right to use the DJI Matrice 100 Quadcopter for commercial use within the United States of America and under the strict adherence of FAA Guidelines,
ATO

- Issue d COA’s, and the like. The DJI Matrice 100 has a maximum take

- off weight of 3400 grams including technical payloads and batteries. Furthermore, this quadcopter is capable of a max flight speed of 22 meters per second and has the following abilities;

 Ver tical Take

- Off  Vertical Landing  Hover

- Hold Position  Simultaneous Vertical & Horizontal Movement  Maximum Flight Speed Abilities in every lateral direction

For easy reviewing, please see Matrice 100

- Specific Exhibits below for more information on the DJI

Mat rice 100 craft, its specifications, abilities, and more. Additionally, please consider the FAA’s previous review of these exhibits and granting of Petitions using these supporting documents for the commercial use of the DJI Matrice 100 in the following li sted Exemption;

 Dan Pham

– Alert5 International, LLC.

– Exemption Number 11814



### Unmanned Flight Crew

The unmanned flight crew ope rating Dronefly, Inc. flight craft for purposes of commercial operations
within the United Sta tes under this proposed Exe mption will consist of a Pilot I n Command (“PIC”) and a Visual Observer (“VO”).

Adhering to current FAA guidelines and precedent established in previously granted Section 333 Exemptions, the PIC will have, at minimum, a Recreat ional or Sport Pilot’s License and a Third Class
Medical Certificate or a valid U.S. Driver’s License (Unless the then

- current FAA Regulations require otherwise, in which case the Petitioner will follow the then

- current rules)

. 7 Additionally, both the PIC
and VO will be trained in the operation of sUAS prior to commercial operations. Furthermore, any new information surrounding the aircraft’s efficient, effective, or safe operations, will be disseminated by Dronefly, Inc. to both the PIC and VO to ensure continued safe flights.

On top of the general sUAS training, the PIC will also have completed, at a minimum, 25 hours of sUAS flight training with the specific sUAS craft they are using for th eir commercial operation and will be required to receive annual continued educatio n and training moving forward. A specific PIC Training Presentation is contained in the exhibits below and will accompany this Petition for Exemption.

The Visual Observer wi ll also have completed specific trai ning relating to their duties during an unmanned flight. The training procedures that will be used to educate VO’s are contained in Exhibits 1
& 3 below.



### Unmanned Flight ConditionsPETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 22

As has been described above , the s UAS

- use proposed by the Petitioner in this Petition for Exemption
revolves around the following industries; Agriculture

, Cinematography

, Closed

- Set Filming, Fire Services,
Infrastructure

, Insurance
, Land Inspection , Law Enforcement, Search and Rescue, and Real Estate

. Each of these industry applications will be described in further detail below under the “ Unmanned Flight Operations ” Title.

Moving on from the specific use cases, it should also be noted that all commercial sUAS flights proposed in this Petition for Exemption will be conducted below 400 feet AGL or as othe rwise permitted in a granted Certificate of Authorization. Furthermore, all flights will be conducted within Visual Line of Sight, as is currently advised by the Federal Aviation Administration and Academy of Model
Aeronautics

. 6 Additionally, the PIC will only operate the Petitioner’s sUAS if weather conditions permit safe operations. The judgement of “Safe Weather Conditions” will be determined based on several standing classifications developed by the Federal Aviation A dministration. These include operations being conducted under the Visual Meteorological Conditions (“VMC”) rules.

As stated previously in this Petition, Dronefly, Inc. will strictly adhere to the FAA’s V isual F light R ule s,

an d obviously, to be following Vis ual Flight Rules, Dronefly, Inc. will have to first satisfy the Visual Meteorological Conditions associated with VFR flights. In particular, the Petitioner will be cognizant of the boundary between Visual Meteorological Conditions, which allow for Visual Flight Rules, and Instrument Meteorological Conditions, which require Instrument use. Specifically, Dronefly, Inc. will be considering the VMC Minima pertaini ng to Visibility, Cloud Ceilings, and Cloud Clearances associated with airspace below 400 feet AGL, where the Petitioner’s sUAS will be flying. Thus, the Petitioner will only operate when visibility is at least 3 statute miles from the PIC and at a minimu m of 500 feet below and 2,000 feet horizontally from a cloud

. 8

In addition to the particular flight conditions stated above, it should also be noted that the flight crew will always make an assessment of the current situati on for each, specific flight. This assessment will conclude with a determination of the relative safety of the flight and any risks or hazards that may be present. If this assessment finds that the flight will be too dangerous or that there are too many hazards or risks associated with the flight, the flight crew will not take off. Furthermore, in order to maintain the safety of the general public, flight operations utilizing the Petitioner’s sUAS will only take place after permission is granted to the P etitioner by the landowner, property owner, or other controlling representative. All current FAA regulations not covered within this petition will be followed as well as all local and state rules surrounding flights near or around people. Additional info rmation on the parameters dictating flights near people can be found below in the “ Proposed Conditions of the Exemption .”



### Unmanned Flight Operations

When conducting commercial flight operations under the pro pose d applications in this Petition for Exemption , a commitment to safety will always be paramount. Additionally, with the goal of each flight to accurately collect valuable aerial data in an efficient manner, it will be vital for all flights to be safe for

s everal reasons, including;PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 23

 The safety of the Flight Crew will be necessary for continued flights.  The safety of the general public will be necessary for continued operations.  The safety of the aircraft will be necessary for continued commercial endeavors.

Furthermore, in an effort to supply the Agriculture

, Cinematography

, Closed

- Set Filming, Fire Services,
Infrastructure

, Insurance
, Land Inspection , Law Enforcement, Search and Rescue, and Real Estate industries with valuable data, it will be imperative for all Dronefly, Inc. flights to be conducted in a safe and professional manner so as to not risk the safety of the flight crew, general public, or aircraft as well as to avoid damaging people or property operating in the National Airspace System or on the ground
below.

To ensure the safe and professional execution of each sUAS flight, a ll flights will be conducted utilizing at
least a two

- person flight crew. This flight crew will consist of an adequately

- trained (“ Unmanned Flight
Crew ” ) PIC and VO. For specifics pertaining to the standard operat ing procedures utilized by the Petitioner under the proposed Petition for Exemption and for more details on training, please see
Exhibits 1

- 4

. 

## Aircraft and Equivalent Level of Safety

As is stated in the FAA’s Section 33 3 Exemption Guidelines, Petitioners for Exemption must show that their proposed commercial, sUAS operations provide a level of safety at least equal to that provided by the rule from which the Petitioner seeks an exemption

. 6 As will be highlighted below, the request for this Exemption by the Petitioner is fortified by its commitment to safety. Furthermore, the operation of sUAS by the Petitioner, using the previously stated flight craft and operating within the above

- state d

use

- cases under the rules, regulations, and limitations stated herein, should be permitted under the proposed exemption. Reasoning for this can be derived from the strict adherence to existing regulations
from the Federal Aviation Administration as well as the adoption of the following conditions ; each providing at least an equivalent level of safety as is provided by the existing rule s

. 

## National Security

In addition to the arguments supporting the Peti tioner’s exemp tion from certain rules contained in 14
C.F.R. , it is also important to note that the granting of this petition and in turn, permission for the
Petitioner to conduct commercia l sUAS flights, will not present a national security threat. As ha s been stated in this Petition

, and

, as is precedent from the F ederal Aviation Administration , the PIC of a sUAS must hold, at minimum, a Recreational or Sport Pilot’s Certificate, meaning he or she has already been subject to a security screening by the D epartment of Homeland Security. 9

This provision, relating to the acquisition of a Recreational or Sport Pilot Certificate, points to checks already provided by the FAA and Department of Homeland Security in ensuring secu re aircraft operations. As is stated by the Aviation and Transportation Security Act, the Transportation Security Administration (“TSA”) must assess information in order to identify individuals that may pose a threat to transportation security and coordin ate countermeasures with other Federal Agencies such as the FAA. Therefore, due to the fact it is a requirement for all PICs to be at least Recreational or Sport PilotPETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 24

Certified, it can be assumed that adequate security checks by the TSA and FAA have take n place prior to a sUAS Pilot conducting commercial operations.


## Proposed Conditions of the Exemption

As is noted by the Federal Aviation Administration in their, “Section 333 Petition Guidance & Checklist” 3 form, Secti on 333 Exemption Petitioners are strongly advised to, “Carefully review the Conditions and
Limitations Section in the most recently granted exemptions.” 3 Due to this, the following Conditions of the proposed Exemption clos ely follow this guidance and mirror many of the same conditions previously noted by other exemption petitioners. The following list will highlight these conditions and establish a framework from which the petitioner, Dronefly , Inc. , will conduct their commercial sUAS operations under a granted petition for exemption.

1. Proposed operations using s mall Unmanned Aircraft Systems in the United States under the granted form of this Petition for Exemption will be limited to the f ollowing aircraft, which all weigh less than 55 pounds including batteries and operational/technical payloads; DJI Phantom

, DJI Phantom 2

, DJI Phantom 2 Vision

, DJI Phantom 2 Vision + , DJI Phantom 3 Standard, DJI
Phantom 3 Advanced

, DJI Phantom 3 Professional

, DJI Phantom 4, DJI Inspire 1 , DJI Matrice 100

o r any airc raft previously

- approved, to be approved in the future , or substantially similar pursuant to the Section 333 Exemption Process

. Furthermore, any aircraft ou tside of this comprehensive list for this Petition for Exemption will have to be added to an amended version of this petition or a new Petition for Exemption must be filed with the new flight platform (s)

.

2. The proposed use

- cases/applications contained withi n this Petition for Exemption under Section 333 are as follows; Agriculture

, Cinematography

, Closed

- Set Filming, Fire Services,
Infrastru cture
, Insurance
, Land Inspection , Law Enforcement, Search and Rescue, and Real

Estate

. All of these flights will take place below 400 feet AGL nationwide unless otherwise advised in an
ATO

- issued Certificate of Waiver or Authorizati on.

3. All flights conducted by Dronefly, Inc. will be below 400 feet AGL, operated within Visual Line of Sight, and have a live, GPS

- based, read

- out of altitude during the flight. Furthermore, each flight will begin with a “Z ero Altitude” start point, thus creating an accurate AGL calculation.

4. All flights conducted by the Petitioner will be controlled by a trained flight crew consisting of a licensed (at minimum Recreational or Sport Pilot’s Certificate or whatever licens ing requirement
is enforced via the then

- current regulations from the FAA ) PIC with a Medical Certificate or equivalent valid U.S.A. Driver’s license and a trained Visual Observer.

5. All flights conducted by the Petitioner will include aircraft that are fly ing below the 87 knot (100 mph) airspeed maximum, highlighted by the FAA in their guidelines.PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 25

6. All flights conducted by Dronefly, Inc. will be conducted within Visual Line of Sight, during daytime flying hours, and adhere t o Visual Flight Rules under the Visual Meteorological Conditions associated with 400 foot AGL airspace.

7. The Petitioner will not allow any PIC to operate a sUAS unless the PIC meets the qualification standards set by the Fede ral Aviation Administration (e .g. Minimum

- Sport Pilot’s Certificate and Medical or U.S.A. Driver’s License) and by the safety guidelines and operational capabilities relating to safe sUAS operations, such as;

a. Evasive Maneuvers
b. Emergency Actions

c. Fail

- Safe Knowledge
d. Flight Skills
i. Main taining adequate distances from;

1. People
2. Property
3. Structures
4. Etc.

8. PIC qualification flight hours will be logged in a manner consistent with 14 C.F.R. 61.51(b). Additionally, a record of the PIC training will be documented and made available upon request by the Administrator.

9. Training operations will only be conducted during dedicated training sessions. During training, all persons not essential for flight operations will be deemed nonparticipants, and thus, the PIC will operate the aircraft with appropria te distance from nonparticipants in accordance with 14
C.F.R. 91.119.

10. As highlighted by the FAA, the Visual Observer’s duty is to visually observe the relevant airspace for aircraft, hazards, obstacles, structures, or the like. For this reason, the VO w ill not be allowed to operate the camera or other instruments on the sUAS during flight operations. Instead, a third person will have to serve as a camera operator if the flight crew seeks a dedicated pilot and dedicated camera operator.

11. The PIC, for the duration of an unmanned flight, will be named prior to the flight. Due to this, once the PIC is named and a flight is begun, the PIC will not be able to transfer his/her designation as the PIC through the duration of the flight. Furthermore, the PIC is the Captain of the flight crew and will ensure that the Visual Observer is qualified to hold the VO position for the duration of the flight.

12. Each commercial sUAS flight performed by Dronefly, Inc. will be planned for ah ead of the flight date. This will be to ensure adequate time for all participants to prepare and to obtain all the necessary permissions (landowners, homeowners, property owners, etc.) if any are needed. All flights will be preceded by a meeting at least one day before the flight at which all participants of the flight will be present. This is to ensure adequate knowledge and preparedness prior to the sUAS flight.PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 26

13. Aircraft maintenance is obviously vital for any commercial sUAS operation. It ensures s afety and is necessary prior to each flight to maintain safe, efficient, and effective flight operations. Once again, the PIC, as the captain of the flight crew, will take a leading role in inspecting the aircraft prior to flight. The PIC will likely hav e the most experience of anyone on the flight crew and will be in tune with the specific maintenance needs of each specific flight craft. If the PIC were to find an error in the flight craft or any of the associated systems, including the Ground Control
S ystem for example, he/she would ground the flight until adequate maintenance is completed and the aircraft is once again safe to fly. All maintenance on flight crafts utilized by the Petitioner will be noted and logged to ensure the safety of all aircraft and the people operating them.

14. Relating to the above Condition, anytime a flight

- critical component is replaced or anytime there is mission

- critical maintenance on the craft, the PIC will conduct a flight test of the system before completing the intend ed, commercial mission. Once again this flight test will be logged by the PIC.

15. Routine maintena nce and inspections of the sUAS will be logged by the PIC in accordance with the requirements and suggestions laid out by the aircraft manufacturer in terms o f aircraft component maintenance, overhaul, replacement, inspection, and life limits, which are part of the supporting documents for each aircraft below in the aircraft

- specific exhibits . The logging of these maintenance/inspection checks will be included in the aircraft records and include the total time of service and description of work.

16. All sUAS flights will be conducted within Visual Line of Sight (“VLOS”) of both the PIC and VO at all times. Furthermore, VLOS means visual observance unaided by an y device other than corrective lenses such as eye glasses or contacts. The use of telescopes, FPV systems (for purposes of VLOS flights), binoculars, and the like will not be permitted. Also, both the PIC and VO should be in constant, verbal communicatio n range. The use of other devices to communicate out of verbal range are not permitted. These devices would include, cell phones, text messaging, walky

- talkies, and the like.

17. No commercial flight missions will be executed unless it can be determined t hat the flight crew can complete their mission from take

- off through landing, with a reserve of 25% battery life. The Petitioner’s newest flight crafts have adaptive battery monitors and

, for this reason

, this condition will be an automated process as the Petitioner can set the default Advisory and Critical Battery warnings to 35% and 30% respectively, which will warn the PIC of the depleted battery and engage him/her to fly home and land with 25% remaining power. For all Dro nefly,
Inc. systems without this automated feature, a watch will be used to monitor flight times to ensure a safe return home with adequate battery power. However, due to the revolving adoption of the newest flight platforms and the current stock of new generation flight crafts, the overwhelming majority of sUAS flights after the granting of this exemption will utilize a Smart Battery System.

18. In the case of an unexpected obstacle or in

- flight issue, each sUAS the Petitioner operates will have the abilit y to abort a mission and take corrective actions.PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 27

19. The sUAS utilized by Dronefly, Inc. will be programmed so that if the sUAS loses signal with the PIC or Ground Control Station during flight, the system will return to a p reprogrammed GPS location located within the operating area containing the flight crew. Furthermore, this failsafe can also be used in controlled situations, meaning the failsafe will be able to be engaged should something happen on the ground that disall ows the PIC from bringing the sUAS back in a normal fashion. Additionally, in both situations described above, where the failsafe is either a controlled action from the pilot or an uncontrolled situation, like radio

- link signal loss, the unit will not onl y fly back to its preprogrammed home point, it also has the ability to land itself. This allows safe operations of the aircraft even in troublesome situations, such as signal loss, and prevents the unit from flying off uncontrollably or landing in an unkn own location.

20. The operating documents required under 14 C.F.R. 91.9 and 91.203 will be maintained and available to the PIC at the Ground Control Station of the aircraft anytime the sUAS is operating. Furthermore, these documents will be available for re view by the Administrator or other law enforcement officials upon request and are additionally contained in Exhibit 1, with appropriate links to the specific flight manuals of each flight craft requested in this Petition for Exemption.

21. It is always imp ortant to specify precedent when determining operating practices. For this reason, if a discrepancy exists between the conditions laid out in this Petition for Exemption and the actual Granted Exemption, the conditions laid out in the finalized Granted Ex emption will take precedent over the conditions laid out in this Petition. Furthermore, if there are no discrepancies between the Petition and Grant of Exemption, the Petitioner will follow the procedures outlined in the Operating Documentation below. Ad ditionally, if any changes are made to the Operating Procedures and Documentation contained in this Petition for Exemption, the Petitioner will present the updated documents upon request from the Administrator. Also, should the Petitioner determine that a n update or change to the procedures or documentation would affect the basis of the approved version of this Petition for Exemption, the Petitioner will either file for an amendment to the existing Exemption or create a new Petition with the
revisions.

22. As has been noted, the Petitioner will obtain written and/or oral permission from the landowners, farmers, property owners, or otherwise authorized agents for flights above their property.

23. The Petitioner will also obtain all required permissions and per mits from territorial, state, county or city jurisdictions, including;

a. Law Enforcement b. Fire Departments

c. Municipal Agencies, or; d. Other Appropriate Governmental Bodies

24. The Petitioner will not conduct operations at night. Furthermore, all operations will b e conducted under Visual Meteorological Conditions (“VMC”).

25. The Petitioner is aware of the need to obtain an Air Traffic Organization (“ATO”) issued Certificate of Waiver or Authorization (“COA”) prior to conducting operations under the grant ofPETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 28

exemption . The Petitioner intends to fly under the Blanket COA provided by the FAA in M arch of 2016 for flights below 4 00 feet to all Section 333 Exemption holders or under a future ATO

issued COA that will be applied for by the Petitioner after receiving their Se ction 333 Exemption.

26. All sUAS flights conducted by the Petitioner will be done so in accordance with airspace requirements established by the FAA and/or an ATO

- issued COA, including;

a. Class of Airspace b. Altitude Level, and potential;

c. Transponder Requirem ents

27. As has been stated, the sUAS will not be operated within 5 nautical miles of an airport reference point as noted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport’s Air Traffic Control is obtained, and the o peration is conducted in accordance with a NOTAM as required by the Operator’s COA.

28. As stated previously, the Petitioner will follow VMC guidelines for VFR flights and as such, will fly only when there is visibility equal to, or in excess of, 3 statute miles from the PIC, while maintaining an adequate distance of no less than 500 feet below, or less than 2,000 feet horizontally from a cloud.

29. All operations by the Petitioner will be conducted below 400 feet AGL, nationwide or as otherwise advised in an A TO

- issued COA.

30. All sUAS craft flown by the Petitioner will be marked and identifiable by a serial number which will be as large as practicable given the relatively small size of the aircraft. The FAA has previously stated that so long as the markings a re as large as practicable given the size of a sUAS, an equivalent level of safety can be achieved.

31. All aircraft utilized by the Petitioner operate via radio frequency, which is governed by the Federal Communications Commission (“FCC”). For this reas on, prior to commercial operations under a granted Section 333 Exemption, the Petitioner will ensure the radio frequency spectrum used to operate and control its sUAS complies with FCC or other appropriate government oversight agency rules and regulations.

32. As is stated in the FAA guidelines, a sUAS is required to yield the right of way to all manned aircraft and aviation operations at all times. This rule will be strictly followed by the Petitioner.

33. The concentration of a PIC is necessary for safe ope rations. It is for this reason that the Petitioner will not allow any sUAS operations while a PIC is in a moving device or vehicle. These vehicles would include things like;

a. Cars/Trucks/SUVs b. Boats

c. Tractors d. ATVsPETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 29

34. All sUAS operations by the Petitioner wil l be conducted at least 500 feet from all nonparticipating people, vessels, vehicles, and structures, unless the following conditions apply;

a. Protective barriers are present that adequately protect nonparticipants from flying shrapnel or debris should ther e be an accident. Furthermore, should a nonparticipant leave this safe

- zone, the PIC will end the flight.

b. The Petitioner has been granted permission to operate near a vessel, vehicle, or structure by the owner/controller of these properties. In additi on to permission, the PIC will also have to perform a risk assessment of the situation and potential obstacles/flight hazards and determine the safety of the flight. If it is determined that the hazards present no risk, the PIC can start the mission.

c. N on

- participants become official participants by consenting to be involved in the film or television production and they adhere to all the guidelines stated within the Petitioner’s Motion Picture and Television Operating Manual (“MPTOM”).

35. The Petitioner w ill log and report to the UAS Integration Office within 24 hours of any incident, accident, or flight operation that occurred outside the horizontal and vertical boundaries of the operational area as defined by the COA under which the flight was operating. Furthermore, the Petitioner will report accidents to the National Transportation Safety Board (NTSB).

36. The Petitioner will provide additional flight training to PICs that may be towing objects in the event of an exemption from 14 C.F.R. 61.315 (c) (18). In the event that the Petitioner is exempt, each PIC that is designated as being a potential candidate for flying a sUAS while towing an object will be required to undergo additional training, on top of their required training and certifications, that wil l consist of 10 hours of training flights while towing objects. These objects will be dummy banners that weigh no more than the max weight allowable to satisfy the max takeoff weight specifications as highlighted by the manufacturer for each flight craft. Furthermore, the 10 hours of training will be required for each aircraft type, thus giving the PIC adequate training time and experience while towing objects with specific flight crafts. This will be necessary to familiarize each PIC with each specific f light craft in order to learn how specific flight craft respond to towing objects, particularly with regard to downwash and wind. Additionally, of the 10 total flight hours required for training on towing objects, 5 of these hours must be in the max wind tolerances as specified by the manufacturer for each flight craft. Training in these conditions will hone the skills of each PIC and allow them to operate in the worst case scenario for towing objects, which is high wind. When conducting actual commercia l flights while towing objects, the Petitioner will not conduct flights in conditions where sustained winds are more than 75% of the maximum wind tolerance of the aircraft or when there are wind gusts in excess of 75% of the maximum wind tolerance as speci fied by the manufacturer for each aircraft.
37. The Petitioner for this Exemption is requesting permission to operate sUAS for the purposes of commercial, closed

- set filming. Due to this, the Petitioner will submit a Motion Picture and Television Operatio ns Manual (“MPTOM”) along with this Petition.

38. Relating to the MPTOM, the Petitioner will submit a written Plan of Activities to the local Flight Standards District Office (“FSDO”) with jurisdiction over the area of proposed filming, at leastPETITIONER

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three days prior to conducting commercial flights for the purposes of closed

- set filming. As referenced in previous grants for exemptions of Closed

- Set Filming, the three

- day notification period may be waived with concurrence of the FSDO. Furthermore, the Plan of A ctivities paperwork submitted to the FSDO will include at least the following;

a. Date and Times for all flights, b. Name and Phone Number of the Operator of the sUAS Aerial Filming,

c. Name and Phone Number of the person responsible for the on

- scene operation of the sUAS, d. Make, Model, and Serial or N

- Number of the sUAS to be used,

e. Name and Certificate Number of sUAS PICs involved in the aerial filming, f. A statement that the operator has obtained permission from the property owners and/or local officials to conduct the aerial filming with the list of those who gave the permission available upon request to the inspector,

g. Signature of the Exemption Holder or Representative, and; h. A description of the flight activity, including maps and diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes necessary to accomplish the operation.

39. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming p roduction, as specified in the Exemption Holder’s
MPTOM.



## Exemptions Requested & Applicable Conditions/Reasoning

14 C.F.R 21(h) : Airworthiness Certificates

Subpart (h) of Part 21 from the Code of Federal Regulations Title 14, Chapter 1, pres cribes procedural requirements for the issuance of Airworthiness Certificates. Proposed Conditions 1, 2, 3, 4, 5, 15, 24, 27, 28, and 33 are all applicable to this particular Regulation and the FAA has found in favor of exempting previous Petitions #11062 , 11063, 11064, 11065, 11066, and 11067 for this portion of 14 C.F.R. Furthermore, it is the belief of the Petitioner that a sUAS operating without an Airworthiness Certificate but within the conditions stated above would provide an equivalent level of sa fety to an aircraft operating with an airworthiness certificate not subject to the above conditions or limitations.

Additionally, all the sUAS proposed within this Petition for Exemptio n are small, weigh less than 55 lbs, have a flight speed of less than 1 00 mph, carry no pilots or passengers, carry no flammable fuel, are
electric

- powered, are operated below 400 feet, are operated at least 5 miles from an airport, and are flown within unaided, visual line of sight of a trained and licensed Pilot In Command. Plus, with built

- in
fail

- safes that include GPS Guidance technologies, Return to Home Features for lost signal and low battery emergencies, and for the ability to regain radio connection with the craft after a fail

- safe is engaged, it is clear the propos ed aircraft have safety features equivalent to and superior to conventional aircraft that hold airworthiness certificates. For these reasons it is the belief of the Petitioner that they be exempt from 14 C.F.R. 21(h).PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 31



### 14 C.F.R. 27 : Airworthiness Standar ds

- Normal Category Rotorcraft

Title 14, Part 27 of the Code of Federal Regulations creates the procedural requirements for airworthiness certification of Normal Category Rotorcraft. Due to the fact that the proposed aircraft
contained within this Petit ion for Exemption are multi

- rotor aircraft, the Petitioner seeks exemption from 14 C.F.R 27 for the same reasons stated in the request for exemption from 14 C.F.R. 21(h).



### 14 C.F.R. 43.7 : Authorized Maintenance/Repair/Alteration Personnel

Title 14, Part 4 3, Section 43.7 of the Code of Federal Regulations regulates personnel authorized to approve aircraft, airframes, aircraft engines, propellers, appliances, or component parts for return to service after maintenance, preventive maintenance, rebuilding, or a lteration. Proposed conditions 13 and 14 are applicable to this particular regulation and the FAA has found in favor of previous Exemption #11208 pertaining to this rule. Furthermore, it is the opinion of the Petitioner that the stated rule would

create a burden as the Petitioner would have to find a regularly authorized conventional mechanic or otherwise licensed personnel to sign off on an unconventional flight craft’s maintenance. More clearly, it would be difficult to find a mechanic that specializes in Cessna Repair that is also an expert in small
radio

- controlled multi

- rotors.

Additionally, it is likely that the operator of the sUAS (the PIC) would be more knowledgeable on the interworking’s of their sUAS than a regular mechanic as they likely hav e past RC flying experience. Particularly, the PICs working for the Petitioner will always have at least 25 hours of RC craft experience, in which time they will likely have to repair a prop for example. Due to the relative ease of replacing

props on a m ultirotor (screw the broken one off and replace with a new one) it is not necessary for a certified or authorized individual to sign off on the repair. Instead, the repair can easily be done by authorized personnel working for the Petitioner so long as th e conditions and procedures stated above, are followed. For these reasons it is the belief of the Petitioner that they be exempt from 14 C.F.R. 43.7.



### 14 C.F.R. 43.11 : Dispositions of Records for Inspections

Title 14, Part 43, Section 43.11 of the Co de of Federal Regulations pertains to the disposition of Records for Inspections. Proposed condition number 13 pertains to this particular regulation and the FAA has found in favor of previous Exemption #11208 which contained this rule. For the reasons s tated in Condition 13 (“Proposed Conditions of the Exemption”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 43.11.PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 32



### 14 C.F.R. 45.11 : Making of Products

Title 14, Part 45, Section 45.11 of the Code of Federal Regulations per tains to the manufacturing of aircraft and major aircraft components, including, but not limited, aircraft bodies, aircraft engines, and aircraft propellers. This particular rule requires various procedures for marking each component with fireproof markin gs and, in a manner acceptable to the Federal Aviation Administration, for purposes of
identification. Proposed Condition for Exemption #30 above, pertains to this particular regulation and the FAA has ruled on it in previous Exemption #11208. For the r easons stated in Condition #30 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt
from 14 C.F.R. 45.11.



### 14 C.F.R. 45.23(b) : Display of Marks; General

Title 1 4, Part 45, Section 45.23(b) of the Code of Federal Regulations states that;

 “ When marks include only the Roman capital letter “N” and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provision ally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “light

- sport,” “experi mental,” or “provisional,” as applicable.”

In a previous grant of exemption (Exemption #11062) it was determined by the FAA that the exemption of sUAS operators from this provision was warranted so long as the aircraft, “have identification (N

Number) mark ings in accordance with 14 C.F.R. 45 (c) if the markings are as large as practicable.” As is stated in Proposed Condition #30 above, the Petitioner will mark their aircraft with markings as large as practicable and therefore should be exempt from 14 C.F.R . 45.23(b).



### 14 C.F.R. 45.27 : Marking of the Aircraft

– Rotorcraft

According to Title 14, Part 45, Section 45.27, of the Code of Federal Regulations, the operator of a rotorcraft;

 Must display on that rotorcraft horizontally on both surfaces of the cabi n, fuselage, boom, or tail, the marks required by 14 C.F.R. 45.23.

For the same reasons stated in the request for exemption from 14 C.F.R. 45.23, the Petitioner believes it should be exempt from 14 C.F.R. 45.27. More clearly, due to Condition #30 above, w hich states that the Petitioner will mark their aircraft with markings as large as practicable, the Petitioner respectfully asks for exemption from 14 C.F.R. 45.27.PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 33



### 14 C.F.R. 45.29 : Size of Marks

According to Title 14, Part 45, Section 45.29, of the C ode of Federal Regulations, the operator of an aircraft;

 Must display on markings on the aircraft meeting the size requirements of this section  2

- 12 inches high depending on the aircraft type  Width 2/3s wide as the characters are high  1/6 th as thick as the characters are high  Not less than 1/4 th the character width  Uniform

For the same reasons stated in the request for exemption from 14 C.F.R. 45.23, the Petitioner believes it should be exempt from 14 C.F.R. 45.29. More clearly, due to Condition #30 above, which states that the Petitioner will mark their aircraft with markings as large as practicable, the Petitioner respectfully asks for exemption from 14 C.F.R. 45.29.



### 14 C

. F

. R

. 61.3 : Requirement for Certificates, Ratings, and Authorizations

Title 14, P art 61, Section 61.3, of the Code of Federal Regulations pertains to the need for a Private Pilot’s license to operate an Unmanned Aerial Vehicle. The Petitioner seeks exemption from this rule to the extent that this rule requires a sUAS operator to hold a Private Pilot’s License. Clearly, the goal of this particular rule is to ensure the skill of any Pilot In Command matches the operating area in which they are flying. However, it is the Petitioner’s belief that the measure of a Private Pilot’s License and the training that went into it is not necessarily connected to that Pilot’s ability to operate a small unmanned aircraft at low altitudes. Particularly, the requirement of a Private License yields potential
PICs that have been trained in multi

- thousa nd

- pound, manned aircraft, flying at hig h altitudes in comparison to 55 lbs. or less, battery

- powered craft, operated at 400 feet AGL or below. For this reason, it is the belief of the Petitioner that they be exempt from this rule as the requirement of a Private Pilot’s license is unnecessary. Furthermore, it is sta ted as such on the FAA website. 7

“ The FAA also made two other changes to the Section 333 exemption process last week:

 The agency now allows operations under the se exemptions by people who hold a recreational or sport pilot certificate. Previously, Section 333 operators were required to have at least a private pilot certificate. The newly added certificates are easier to obtain, and therefore less costly, than a p rivate pilot certificate. ”

The authorization of Recreational and Sport Pilot Certificates as an alternative to a Private License points to a Private License as being a non

- requirement according to the FAA’s integration office. This further
evidence shows that the Petitioner should be exempt from the aforementioned regulation. Clearly, the Petitioner’s requirement of all PICs (Proposed Condition #4) to hold at least a Recreational or SportPETITIONER

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Pilot’s Certificate yields an authorized level of training accordin g to the FAA’s own website and in turn, shows that such a requirement by the Petitioner offers an equivalent level of safety as is provided by existing rules.

Furthermore, Proposed Conditions #4, 6, 7, 8, and 9, among others, show the Petitioner’s commit ment to safety and arguments for exemption from this rule.



### 14 C.F.R. 61.23(a) and (c) : Medical Certificates

– Requirements and Duration

According to Title 14, Part 61, Section 61.23 (a) & (c), of the Code of Federal Regulations, the operator of
an airc raft is required to hold a Medical Certificate in various Pilot In Command Situations. As is stated in Proposed Condition #4 above, the Pilot in Command will have at least a Sport’s Pilot’s License and at least a valid U.S. Driver’s license, which has bee n ruled by the FAA in previously granted exemptions as a suitable alternative to a valid medical certificate for the authorized flights of unmanned systems. Furthermore, the FAA has posted on its website this new policy. 7 Due to Condition #4 above and the current FAA Policy displayed below, the Petitioner believes it should be granted exemption from 14 C.F.R. 61.23(a) and (c).

“ The FAA also made two other changes to the Section 333 exemption process last week:

 The agenc y now allows operations under these exemptions by people who hold a recreational or sport pilot certificate. Previously, Section 333 operators were required to have at least a private pilot certificate. The newly added certificates are easier to obtain, an d therefore less costly, than a private pilot certificate.

 A third class medical certificate is no longer required. Now, a Section 333 operator only needs a valid driver’s license to satisfy the medical requirement. This change is consistent with the

age ncy’s approach for sport pilot certificate holders, who may fly light sport aircraft with a driver’s license and no FAA medical certificate. ”



### 14 CFR 61.101(e) (4) and (5) : Recreational Pilot Privileges and Limitations

In Title 14, Part 61, Section 61.10 1(e) (4) & (5), of the Code of Federal Regulations, the FAA states that;

Except as provided in paragraphs (d) and (i) of this section, a recreational pilot may not act as pilot in command of an aircraft

— for compensation or hire or in furtherance of a busi ness.

As can be seen on the FAA’s website (https://www.faa.gov/news/updates/?newsId=82485);

“ The FAA also made two other changes to the Section 333 exemption process last week:

 The agency now allows operations under these exemptions by people who hold a recreational or sport pilot certificate. Previously, Section 333 operators were required to have at least aPETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 35

private pilot certificate. The newly added certificates are easier to obtain, and therefore less costly, than a private pilot certificate.”

With the intention of Section 333 Exemptions being the integration of commercial unmanned systems into the National Airspace System, it is clear that the allowed pilot certificates now authorized by the FAA do not adhere to 14 C.F.R. 61.101 (e) (4) and (5) and thu s, it is the belief of the Petitioner that they should be exempt from 14 C.F.R. 61.101 (e) (4) and (5) because this Petition for Exemption is for the expressed purpose of conductin g commercial operations of sUAS in an effort to earn compensation and/or fur ther the business of the Petitioner. As is stated in Proposed Condition #4 above, it is the intention of the Petitioner to provide commercial sUAS flights to customers through the use of a flight crew, consisting of a Pilot In Command that holds at least a Recreational or Sport Pilot Certificate. Therefore, in all likelihood, many PICs employed by the Petitioner will have these specific Certificates and as such, will need to be able to fly for compensation.

Furthermore, as is stated on the FAA’s own web site and as is highlighted below ;

“ The FAA also made two other changes to the Section 333 exemption process last week:

 The agency now allows operations under these exemptions by people who hold a recreational or sport pilot certificate. Previously, Section 333 operators were required to have at least a private pilot certificate. The newly added certificates are easier to obtain, and therefore less costly, than a private pilot certificate. ”

Therefore, it is highly likely that many potential PICs will have th ese Certificates as they are less costly and easier to obtain than a commercial Pilot’s License as an example. For these reasons, it is clear that the Petitioner should be granted an exemption from 14 C.F.R. 61.101 (e) (4) and (5).



### 14 CFR 61.113 (a) & (b) : Private Pilot Privileges and Limitations

– Pilot In Command

Title 14, Part 61, Section 61.113 of the Code of Federal Regulations states that;

Except as provided in paragraphs (b) through (h) of this section, no person who holds a private pilot
certi ficate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an
aircraft.

Clearly this specific regulation conflicts with the Petitioner’s desire to provide commercial sUAS flights in the United States. Furthermore, some of the Petitioner’s PICs will have Private Pilot Licenses and as such they will be operating an aircraft (the sUAS) for compensation or hire under the proposed Petition for Exemption.

With the intention of Section 333 Exemptions being the integration of commercial unmanned systems into the National Airspace System, it is clear that the allowed pilot certificates now authorized by the FAA, including a private pi lot’s license

, do not adhere to 14 C.F.R. 61.113 and thus, it is the belief of the Petitioner that they should be exempt from 14 C.F.R. 61.113 because this Petition for Exemption is forPETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 36

the expressed purpose of conducting commercial operations of s UAS in a n effort to earn compensation and/or further the business of the Petitioner. As is stated in Proposed Condition #4 above, it is the intention of the Petitioner to provide commercial s UAS flights to customers through the use of a flight crew, consisting of a Pilot In Command that holds at least a Recreational or Sport Pilot Certificate (but who may also hold a Private License). In addition, the FAA has granted over 800 Section 333 Exemptions to businesses and individuals looking to provide commercial/compe nsation

- based sUAS flights.

Furthermore, looking at 61.113 (b), which states; A private pilot may, for compensation or hire, act as pilot in command of an aircraft in connection with any business or employment if:

 The flight is only incidental to that b usiness or employment; and  The aircraft does not carry passengers or property for compensation or hire.

The Petitioner seeks exemption from these rules as it is the Petitioner ’ s goal to fly s UAS missions for compensation or hire. Additionally, the speci fic provision pertaining to not flying aircraft that carry property for compensation or hire is something the Petitioner would like to be exempt from as well

. Various forms of property may be carried on a s UAS, including; Camera Systems, Digital Imagery,
Sensors , and the like.

For all these reasons

, the Petition er seeks exemption from 14 C.F.R. 61.113 (a) and (b).



### 14 C

. F

. R . 61.315(a)(c): Privileges and Limits of Sport Pilot’s License

In Title 14, Part 61, Section 61.315(a), of the Code of Federal Reg ulations, the FAA states that;

If you hold a sport pilot certificate you may act as pilot in command of a light

- sport aircraft, except as specified in paragraph (c) of this section. Paragraph (c) reads the following;

You may not act as pilot in command of a light

- sport aircraft:

(1) That is carrying a passenger or property for compensation or hire.

(2) For compensation or hire.

(3) In furtherance of a business.

(4) While carrying more than one passenger.

(5) At night.

(6) In Class A airspace.PETITIONER

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– DMZ Marketing, LLC. 37

(7) In Class B, C, and D airspace, at an airport located in Class B, C, or D airspace, and to, from, through, or at an airport having an operational control tower unless you have met the requirements specified in §61.325.

(8) Outside the United States, unless you have prior authorization from the country in which you seek to operate. Your sport pilot certificate carries the limit “Holder does not meet ICAO requirements.”

(9) To demonstrate the aircraft in flight to a prospective buyer if you are an aircraft salesperson.

(10) In a passenger

- carrying airlift sponsored by a charitable organization.

(11) At an altitude of more than 10,000 feet MSL or 2,000 feet AGL, whichever is higher.

(12) When the flight or surface visibility is less than 3 statute miles.

(13) Without vis ual reference to the surface.

(14) If the aircraft:

(i) Has a VH greater than 87 knots CAS, unless you have met the requirements of §61.327(b).

(ii) Has a VH less than or equal to 87 knots CAS, unless you have met the requirements of §61.327(a) or have log ged flight time as pilot in command of an airplane with a VH less than or equal to 87 knots CAS before April 2, 2010.

(15) Contrary to any operating limitation placed on the airworthiness certificate of the aircraft being flown.

(16) Contrary to any limit on your pilot certificate or airman medical certificate, or any other limit or endorsement from an authorized instructor.

(17) Contrary to any restriction or limitation on your U.S. driver's license or any restriction or limitation imposed by judicial or a dministrative order when using your driver's license to satisfy a requirement of this part.

(18) While towing any object.

(19) As a pilot flight crewmember on any aircraft for which more than one pilot is required by the type certificate of the aircraft or the regulations under which the flight is conducted.

The Petitioner requests exemption from numerous provisions contained in 14 C.F.R. 61.315 (a)(c). Particularly, the Petitioner requests exemption from the following subparts of 14 C.F.R. 61.315 (c); 1, 2, 3, 9, and 18. Furthermore, the Petitioner believes that the remaining subparts (4, 5, 6, 7, 8, 10, 11, 12, 13, 14, 15, 16, 17, and 19) will be adhered to via proposed conditions conta ined in “ Proposed Conditio ns of the Exemption ” above. Specifically, subparts 4, 5, 6, 7, 8, 10, 11, 12, 13, 14, 15, 16, 17, and 19 are covered by Proposed Conditions 1, 6 & 24, 6, 6, 1, 1, 3, 6 & 28, 6 & 28, 5, 25, 25, and 4 respectively.PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 38

Additionally, pertaining to subparts 1, 2, 3, 9, 18, and 19, the Petitioner seeks exemption due to both unnecessary burdens on the Petitioner as well as an equivalent level of safety as is provided by these existing subparts of 14 C.F.R. 61.315 (a)(c). Arguments for each subpart are contained b elow.

Subpart (1) of 14 C.F.R. 61.315 (c) states that a Sport

- Certified Pilot may not operate an aircraft if that aircraft is carrying passengers or property for hire/compensation. This is an unnecessary burden on the Petitioner as;

1. They will not be carry ing any pass e ngers as they are flying Unmanned Systems, and;
2. There will be situations in which the Petitioner carries property for compensation.

The most likely of these situations will happen when a Petitioner is carrying a device or measurement tool owne d by another person for compensation. This may includ e an imaging sensor owned by a third party for example. If a third party company owns the actual sensor but wants the Petitioner to utilize the tool on the Petitioner’s aircraft, the Petitioner will be flying with property for compensation. This compensation is related to the risk of loss while the camera is operating on the Unmanned System as well as the aerial perspecti ve achieved by the sensor on a s UAS that would otherwise be impossible to obtain i f th e partner company only had the sensor. This example is common in many industries in which ground tools (such as cameras) are utilized on unmanned systems. Without exemption from this rule the Petitioner would have to either purchase the 3rd par ty sen sor for use on their own s UAS or forego the compensation opportunity because they cannot carry the client’s tool and thus, not get the information the client desires. For this reason, it would be a significant burden to utilize a s UAS commercially without the ability to carry multiple sensors that may not be personally owned by the
Petitioner.

Furthermore, it is the belief of the Petitioner that an equivalent level of safety would be provided if exempt from this rule because of the extensive trai ning the P IC would have on the s UAS prior to flying commercially. This training will be in excess of the existing requirement to have at least a Sport Pilot’s or Recreational Certificate . Thus, the PIC will have sufficient manned aircraft and unmanned aircraft

tra ini ng to successfully operate the s UAS without endangering the public. The training procedures and training materials for the PIC can b e found in Exhibits 1 and 4 below.

In addition to subpart (1) of 14 C.F.R. 61.315 (a)(c), the Petitioner also requests exemption from subpart (2) which states that an operator with a Sport Pilot’s License may not operate an aircraft for compensation. As has been highlighted previously, the directive from Congress passed to the FAA via the FAA Modernization and Reform Act of 2012 was to integrate commercial UAV operations into the National Airspace System. Furthermore, in numerous previously filed and granted Petitions for Exemption under Section 333, it has been stated by the FAA that;

 The agency now allows operations un der these exemptions by people who hold a recreational or sport pilot certificate.

This statement, combined with the initiative behind Section 333 exemptions (the commercial integration of UAV operations in the National Airspace System) shows that the FAA has found in favor of the idea that commercial UAV operations can be conducted by people who hold a recreational or sport pilot certificate. Additionally, this same argument can be made in regard to subpart (3) of 14 C.F.R.PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 39

61.315 (a)(c), which states th at a Sport

- Certified Pilot may not operate an aircraft in furtherance of a business. The FAA defines “Furtherance of a Business” as;

 A flight, even if incidental to your employment or the business you intend to conduct, and not required by your business o r employment, would be considered “in furtherance of a business.” 10

Clearly, based on this description, an aerial operation that is “in furtherance of a business” would be considered a lesser form of commercialization than flights for hire or compensation as these types of flights are incidental to a business as opposed to directly related to the business, which is what a flight for compensation would likely be. Therefore, it is the belief of the Petitioner that they be exe mpt from this rule for the same justification as is proposed regarding 14 C.F.R. 61.315 (a)(c) (1) and (2).

On top of subparts (1), (2), & (3) of 14 C.F.R. 61.315 (a)(c), the Petitioner also seeks relief from subpart (9) which states that a Sport

- Certifi ed Pilot may not operate an aircraft to demonstrate that aircraft for sale. The Petitioner seeks exemption from this rule as they will be carrying an inventory/stock/fleet of UAV aircraft in an effort to operate a commercial service business. Furthermore, this inventory/stock/fleet will turnover from time to time as new aircraft are added and old aircraft are released by the company. In this event it will be important for the Petitioner to have the capability of showing off the aircraft to prospective buy ers so that they can get the best price for their used systems. Plus, with PICs already being heavily trained and experienced with commercial flights, there is no added risk to allowing a qualified PIC to demonstrate the aircraft for sale to prospective b uyers. The demonstration after all would be equivalent or less dangerous than a commercial flight that the PIC already performs on a frequent basis as part of their job as a commercial s UAS Pilot.

The Petitioner also seeks exemption from 14 C.F.R. 61.31 5 (c) (18) which states that a Sport

- Certified Pilot may not operate an aircraft while towing an object. It is the belief of the Petitioner that they be exempt from this rule as the maximum takeoff weight of their aircraft will never exceed the max takeof f weight specifications highlighted by the manufacturer. These max takeoff weights are the maximum weight these aircraft can carry (including themselves) and still fly effectively. Thus, any object being towed by the aircraft will have to weigh equal to or less than the maximum allowable weight in order to maintain or come under the max takeoff weight specifications highlighted by the manufacturer. Additionally, Proposed Condition 36 f rom the “ Proposed Conditions of the Exemption ” above, highlights reasoning as to why the Petiti oner believes their commercial s UAS flights in which objects are towed, would provide an equivalent level of safety as is provided by the existing rule. Particularly, the required and add itional training necessary for a PIC to become an Object Towing PIC shows the skills that would be required to tow objects.

Furthermore, with the continued innovation in the world of sensors, it will be necessary for the Petitioner to be able to tow objec ts, such as tow

- behind sensors, in order to remain competitive with their competition. Tow

- behind sensors might measure air quality , capture imagery, or perform various other data collection methods. Competing vehicles for these tow

- behind sensors would include ATVs, Motorcycles, Manned Aircraft, and the like. All of these potential alternatives are more expensive to operate, more dangerous to operate, and dirtier to operate. Each alternative would cost multiple thousands of dollars to purchase, are lar ger, powered by combustion engines, and carry flammable fuel. Additionally, they produce negative effects on the environment. For the reasons stated above, the Petitioner believe s they should be exempt from 14 C.F.R. 61.315 (c) (18).PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 40



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

Title 14, Part 91, Section 91.7 (a) of the Code of Federal Regulations states; no person may operate a civil aircraft unless it is in an airworthy condition. Proposed Condition #13 pertains to this particular regulation and t he FAA has found in favor of previous Exemption #11062, 11063, and 11064, which contained this rule. For the reasons stated in Condition 13 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.7 (a) and the proposed condition offers an equivalent level of safety as is currently provided by the existing rule.



### 14 C.F.R. 91.9(b)(2) : Civil Aircraft Flight Manual

Title 14, Part 91, Section 91.9 (b) ( 2) of the Code of Federal Regulations states;

No person may operate a U.S.

- registered civil aircraft for which an Airplane or Rotorcraft Flight Manual is not required by Part 21.5 of this chapter, unless there is available, in the aircraft, a current appr oved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any
combination thereof

. Proposed Condition #20 pertains to this particular regulation and the FAA has found in favor of previous Exemption s #11062, 11063, an d 11064, which contained a request for exemption from this rule. For the reasons stated in Condition 20 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.9 (b) (2). Furthermore, the proposed condition offers an equivalent level of safety as is currently provided by the existing rule as the Operating manuals about which this rule pertains are available to the operator at all times on the ground , just as they would be if the aircraft was carrying the operator. Thus, any information the operator desires about the aircraft or its operating guidelines, can be found within documents within arm’s reach of the operator or on a digital device, such as a Smart Phone or tablet , easily accessible to the operator.



### 14 C.F.R. 91.9(c) : Civil Aircraft Marking, Placards

Title 14, Part 91, Section 91.9 (c) of the Code of Federal Regulations states; No person may operate a
U.S.

- registered civil aircraft unles s that aircraft is identified in accordance with part 45 of this chapter

. Proposed Condition #30 pertains to this particular regulation and the FAA has found in favor of pr evious Exemptions which contained a request for exemption from this rule. For the reasons stated in Condition 30 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exe mpt from 14 C.F.R. 91.9 (c). Furthermore, the proposed condition offers an equivalent level of safety as is currently provided by the existing rule as the FAA has previously determined that exemption from these requirements is warranted provided that the aircraft “have identification (N

- Number) markings in accordance with 14 C.F.R. Part 45, Subpart c, if the markings are as large as practicable.” 11PETITIONER

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– DMZ Marketing, LLC. 41



### 14 C.F.R. 91.103 : Preflight Action

Title 14, Part 91, Section 91.103 of the Code of Federal Regulations states;

Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. This information must include

—

(a) For a flight under IFR or a flight not in the vicinit y of an airport, weather reports and forecasts, fuel requirements, alternatives available if the planned flight cannot be completed, and any known traffic delays of which the pilot in command has been advised by ATC;

(b) For any flight, runway lengths at airports of intended use, and the following takeoff and landing distance information:

(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data is required, the takeoff and landing dista nce data contained therein; and

(2) For civil aircraft other than those specified in paragraph (b)(1) of this section, other reliable information appropriate to the aircraft, relating to aircraft performance under expected values of airport elevation and r unway slope, aircraft gross weight, and wind and temperature.

Proposed Conditions # 3, 6, 12, 1 6, 17, 20, 22, 23, 24, and 28 pertain to this particular regulation and the FAA has found in favor of previous Exemptions which contained a request for exempti on from this rule, including Exemptions #11062, 11063, and 11064. For the reasons stated in Conditions 3, 6, 12, 16, 17, 20, 22, 23, 24, and 28 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.103. Furthermore, the proposed conditions offer an equivalent level of safety as is currently provided by the existing rule as Preflight Planning is integral to the Petitioner’s sUAS flights and each mi ssion will be carefully planned, taking into consideration weather, power requirements, aircraft operating guidelines, and more, as seen in the proposed conditions above.



### 14 C.F.R. 91.105 : Flight Crewmembers at Stations

Title 14, Part 91, Section 91. 105 of the Code of Federal Regulations states;

(a) During ta keoff and landing, and while en route, each required flight crewmember shall

—
(1) Be at the crewmember station unless the absence is necessary to perform duties in connection with the operation of the aircraft or in connection with physiological needs; and

(2) Keep the safety belt fastened while at the crewmember station.PETITIONER

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– DMZ Marketing, LLC. 42

(b) Each required flight crewmember of a U.S.

- registered civil aircraft shall, during takeoff and landing, keep his or her shoulder harness fastened while at his or her assigned duty station. This paragraph does not apply if

—

(1) The seat at the crewmember's station is not equipped with a shoulder harness; or

(2) The crewmember would be unable to perform required duties w ith the shoulder harness fastened.

Proposed Condition #4 pertains to this particular regulation and the FAA has found in favor of previous Exemptions which contained a request for exemption from this rule, including Exemption #11185. For
the reason stat ed in Condition #4 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.105. Furthermore, 14 C.F.R. 91.105 doesn’t really apply to the Petitione r ’s aircraft as all the aircraft requested b y the Petitioner weig h below 55 lbs. and do not carry a physical crew. As such, there is no cockpit or other operating area within the vehicle where a prospective crewmember would harness themselves in. Instead , all operations of the sUAS are executed from the ground from a designated operating area, in which, each crewmember has an assigned position at which they will stand during the operation. Generally, this standing area would be near the ground station fo r the PIC and in a pre

- designated area (which is determined by the PIC) for the VO. Utilizing pre

- determined standing areas for both the PIC and VO will ensure safe operating procedures of the Unmanned Vehicle.



### 14 C.F.R. 91.109 : Flight Instruction

Ti tle 14, Part 91, Section 91.109 of the Code of Federal Regulations states;

(a) No person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. Howeve r, instrument flight instruction may be given in an airplane that is equipped with a single, functioning throwover control wheel that controls the elevator and ailerons, in place of fixed, dual controls, when

—
(1) The instructor has determined that the fl ight can be conducted safely; and

(2) The person manipulating the controls has at least a private pilot certificate with appropriate category and class ratings.

(b) An airplane equipped with a single, functioning throwover control wheel that controls the elevator and ailerons, in place of fixed, dual controls may be used for flight instruction to conduct a flight review required by§ 61.56 of this chapter, or to obtain recent flight e xperience or an instrument proficiency check required by § 61.57 when

—
(1) The airplane is equipped with operable rudder pedals at both pilot stations;

(2) The pilot manipulating th e controls is qualified to serve and serves as pilot in command during the entire flight;PETITIONER

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– DMZ Marketing, LLC. 43

(3) The instructor is current and qualified to serve as pilot in command of the airplane, meets the requirements of§ 61.195(b) , and has logged at least 25 hours of pilot

- in

- command flight time in the make and model of airplane; and

(4) The pilot in command and the instructor have determined the flight can be conducted safely.

(c) No person may operate a civil aircraft in simulated instrument flight unless

—
(1) The other control seat is occupied by a safety pilot who possesses at least a private pilot certificate with category and class ratings appropriate to the aircraft being flown

. (2) The safety pilot has adequate vision forward and to each side of the aircraft, or a competent observer in the aircraft adequately supplements the vision of the safety pilot; and

(3) Except in the case of lighter

- than

- air aircraft, that aircraft is equipped with fully functioning dual controls. However, simulated instrument flight may be conducted in a single

- engine airplane, equipped with a single, functioning, throwover control wheel, in place of fixed, dual controls of the elevator and ailerons, w hen

—
(i) The safety pilot has determined that the flight can be conducted safely; and

(ii) The person manipulating the controls has at least a private pilot certificate with appropriate category and class ratings.

(d) No person may operate a civil aircr aft that is being used for a flight test for an airline transport pilot certificate or a class or type rating on that certificate, or for apart 121 proficiency flight test, unless the pil ot seated at the controls, other than the pilot being checked, is fully qualified to act as pilot in
command of the aircraft.

Proposed Conditions #4, 7, 8, and 9 pertain to this particular regulation and the FAA has found in favor of previous Exemptions wh ich contained a request for exemption from this rule, including Exemptions #11062, 11063, and 11064. For the reasons stated in Conditions #4, 7, 8, and 9 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.109.



### 14 C.F.R. 91.113(b) : Right

- of

- Way Rules

Title 14, Part 91, Section 91.113(b) of the Code of Federal Regulations states;

(b) General. When weather conditions permit, regardless of whe ther an operation is conducted under instrument flight rules or visual flight rules, vigilance shall be maintained by each person operating an aircraft so as to see and avoid other aircraft. When a rule of this section gives another aircraft the right

of

- w ay, the pilot shall give way to that aircraft and may not pass over, under, or ahead of it unless well
clear.

Proposed Conditions #6 and 32 pertain to this particular regulation and the FAA has found in favor of previous Exemptions which contained a reques t for exemption from this rule, including Exemption #11238. For the reasons stated in Conditions #6 and 32 (“ Proposed Conditions of the Exemption ”)PETITIONER

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– DMZ Marketing, LLC. 44

above, it is the belief of the Petitioner that they be exempt fr om 14 C.F.R. 91.113(b). Due to the fact that all the Petitioner’s sUAS operations will take place under the guidance of a PIC and VO within Line of Sight of the aircraft, it is the belief of the Petitioner that their proposed operations offer an equivalen t level of safety as is provided by the existing rule.



### 14 C.F.R. 91.119 : Minimum Safe Altitudes

Title 14, Part 91, Section 91.119 of the Code of Federal Regulations states;

Except when necessary for takeoff or landing, no person may operate an airc raft below the following altitudes:

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface.

(b) Over congested areas. Over any congested area of a city, town, or settlem ent, or over any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft.

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.

(d) Helicopters, powered parachutes, and weight

- shift

- control aircraft. If the operation is conducted without hazard to persons or property on the surface

—

(1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) of this section, provided each person operating the helicopter complies with any routes or altitudes speci fically prescribed for helicopters by the FAA; and

(2) A powered parachute or weight

- shift

- control aircraft may be operated at less than the minimums prescribed in paragraph (c) of this section.

Proposed Condit ions #3, 6, 25, 26, 28, 29, 34 , 37, 38, an d 39 pertain to this particular regulation and the FAA has found in favor of previous Exemptions which contained a request for exemption from this rule.
For the reasons stated in Condit ions #3, 6, 25, 26, 28, 29, 34 , 37, 38, and 39 (“ Proposed Conditions of the Exemption ”) above and because the Petitioner has a MPTOM , it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.119.

Each of the Proposed Conditions above create sUAS operations with eq uivalent safety to what the typical manned mission under 14 C.F.R. 91.119 would provide. Remember, when comparing to manned operations with manned flight craft, a sUAS is much smaller and light

- weight. Consider the fact that a manned aircraft weighs thou sands of pounds, carries flammable fuel, and is powered by a combustionPETITIONER

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– DMZ Marketing, LLC. 45

engine. Clearly, carrying out a mission utilizing a sUAS would provide for a safer operation than would a
conventional aircraft under 14 C.F.R. 91.119.



### 14 C.F.R. 91.121 : Altimeter Se ttings

Title 14, Part 91, Section 91.121 of the Code of Federal Regulations states;

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

—
(1) Below 18,000 feet MSL, to

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

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

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

(2) At or above 18,000 feet MSL, to 29.92′′ Hg.

(b) The lowest usable flight level is determined by the atmospheric pressure in the area of operation as shown in the following table:

Current altimeter setting Lowest usable flight level

29.92 (or higher) 180

29.91 through 29.42 185

29.41 through 28.92 190

28.91 through 28.42 195

28.41 through 27.92 200

27.91 through 27.42 205

27.41 through 26.92 210

(c) To convert minimum altitude prescribed under§§ 91.119 and 91.177 to the minimum flight level, the pilot shall take the flight level equivalent of the minimum altitude in feet and add the appropriate
numb er of feet specified below, according to the current reported altimeter setting:PETITIONER

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Current altimeter setting Adjustment factor

29.92 (or higher) None

29.91 through 29.42 500

29.41 through 28.92 1,000

28.91 through 28.42 1,500

28.41 through 27.92 2,000

27.91 through 27.42 2,500

27.41 through 26.92 3,000

Proposed Condition #3 pertains to this particular regulation and the FAA has found in favor of previous Exemptions, particularly Astraeus Aerial, which contained a request for exemption from this rule based on the idea that an equivalent level of safety could be provided so long as the Unmanned Aircraft was operated below 400 feet AGL, within Visual Line of Sight, and operated with a live, GPS

- based, Altitude
read

- out. For the reasons stated in Conditi on #3 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.121 because they are receiving a live,
GPS

- Altitude, read

- out on each flight, they are operating below 400 feet AGL, and they are operating within Visual Line of Sight. Furthermore, as can be seen in Proposed Condition #3, each flight conducted by the Petitioner will begin with a zero

- altitude start point.



### 14 C.F.R. 91.151(a) : Fuel Requ irements for VFR Flight Conditions

Title 14, Part 91, Section 91.151(a) of the Code of Federal Regulations states;

(a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is eno ugh fuel to fly to the first point of intended landing and, assuming normal cruising speed

—

(1) During the day, to fly after that for at least 30 minutes; or

(2) At night, to fly after that for at least 45 minutes.

Proposed Condition #17 pertains to this particular regulation and the FAA has found in favor of previous Exemptions, particularly Astraeus Aerial, which contained a request for exemption from this rule based on an equivalent level of safety being provided by a sUAS when ending a flight with at least 25% battery life remaining. Clearly, a percent battery life remaining is a better measure for safety when using a sUAS because the current battery capacities achieved by these types of v ehicles (including all the sUAS proposed in this Petition f or Exemption) often do not allow for flight times of over 25 minutes, which isPETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 47

far less than even the reserve time limits mandated by 14 C.F.R. 91.151(a). For the reasons stated in Condition #17 (“ Proposed Conditi ons of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.151(a) because they can achieve an equivalent level of safety by terminating their flights with 25% battery life remaining.



### 14 C.F.R. 91.203(a) and (b) : Civil Aircraft

– Certifications Required

Title 14, Part 91, Section 91.203(a) and (b) of the Code of Federal Regulations states;

(a) Except as provided in§ 91.715 , no person may operate a civil aircraft unless it has within it the following:

(1) An appropriate and current airworthiness certificate. Each U.S. airworthiness certificate used to comply with this subparagraph (except a special flight permit, a copy of the applicable operations specifications issued under§ 21.197(c) of this chapter, appro priate sections of the air carrier manual required by parts 121 and 135 of this chapter containing that portion of the operations specifications issued under § 21.197(c) , or an authorization under § 91.611 ) must have on it the registration number assigned to the aircraft under part 47 of this chapter

. However, the airworthiness certificate need not have on it an assigned special identification number before 10 days after that number is first affixed to the aircraft. A revised airworthiness
certificate havin g on it an assigned special identification number that has been affixed to an aircraft may only be obtained upon application to an FAA Flight Standards district office.

(2) An effective U.S. registration certificate issued to its owner or, for operation w ithin the United States, the second copy of the Aircraft Registration Application as provided for in§ 47.31(c) , or a registration certification issued under the laws of a foreign country.

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under§ 91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

Proposed Condition #20 pertains to this particular reg ulation and the FAA has found in favor of previous Exemptions, particularly Exemptions #11062, 11063, and 11064, which contained a request for exemption from this rule. Additionally, all required paperwork will be available to the PIC and VO on the ground as these are Unmanned Systems as opposed to manned aircraft. This paperwork may be in
hard

- copy form or available through a link on the internet, such as a Google Drive account for example.



### 14 C.F.R. 215 : ATC Transponder and Altitude Reporting Equipme nt and Use

Title 14, Part 91, Section 91.215 of the Code of Federal Regulations states;

(a) All airspace: U.S.

- registered civil aircraft. For operations not conducted under part 121 or 135 of this chapter , ATC transponder equipment installed must meet the performance and environmentalPETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 48

requirements of any class of TSO

- C74b (Mode A) or any class of TSO

- C74 c (Mode A with altitude reporting capability) as appropriate, or the appropriate class of TSO

- C112 (Mode S).

(b) All airspace. Unless otherwise authorized or directed by ATC, no person may operate an aircraft in the airspace described in paragraphs (b)(1) through (b)(5) of this section, unless that aircraft is equipped with an operable coded radar beacon transponder having either Mode 3/A 4096 code capability, replying to Mode 3/A interrogations with the code specified by ATC, or a Mode S capability, reply ing to Mode 3/A interrogations with the code specified by ATC and intermode and Mode S interrogations in accordance with the applicable provisions specified in TSO C

- 112, and that aircraft is equipped with automatic pressure altitude reporting equipment ha ving a Mode C capability that automatically replies to Mode C interrogations by transmitting pressure altitude information in 100

- foot increments. This requirement applies

—
(1) All aircraft. In Class A, Class B, and Class C airspace areas;

(2) All aircra

ft. In all airspace within 30 nautical miles of an airport listed in appendix D, section 1 of this part from the surface upward to 10,000 feet MSL;

(3) Notwithstanding paragraph (b)(2) of this section, any aircraft which was not originally
certificated wi th an engine

- driven electrical system or which has not subsequently been certified with such a system installed, balloon or glider may conduct operations in the airspace within 30 nautical miles of an airport listed in appendix D, section 1 of this part pr ovided such operations are conducted

—
(i) Outside any Class A, Class B, or Class C airspace area; and

(ii) Below the altitude of the ceiling of a Class B or Class C airspace area designated for an airport or 10,000 feet MSL, whichever is lower; and

(4) All aircraft in all airspace above the ceiling and within the lateral boundaries of a Class B or Class C airspace area designated for an airport upward to 10,000 feet MSL; and

(5) All aircraft except any aircraft which was not originally certificated with an engine

- driven electrical system or which has not subsequently been certified with such a system installed, balloon, or glider

—
(i) In all airspace of the 48 contiguous states and the District of Columbia at and above 10,000 feet MSL, excluding the air space at and below 2,500 feet above the surface; and

(ii) In the airspace from the surface to 10,000 feet MSL within a 10

- nautical

- mile radius of any airport listed in appendix D, section 2 of this part, excluding the airspace below 1,200 feet outside of the lateral boundaries of the surface area of the airspace designated for that airport.

(c) Transponder

- on operation. While in the airspace as specified in paragraph (b) of this section or in all controlled airspace, each person operating an aircraft equi pped with an operable ATC transponder maintained in accordance with § 91.413 of this part shall operate the transponder, including Mode C equipment if installed, and shall reply on the appropriate code or as assigned by ATC.PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 49

(d) ATC authorized deviations. Requests for ATC authorized deviations must be made to the ATC facility having jurisdiction over the concerned airspace within the time periods specified as follows:

(1) For opera tion of an aircraft with an operating transponder but without operating automatic pressure altitude repo rting equipment having a Mode C apability, the request may be made at any time.

(2) For operation of an aircraft with an inoperative transponder to the airport of ultimate destination, including any intermediate stops, or to proceed to a place where suitable repairs can be made or both, the request may be made at any time.

(3) For operation of an aircraft that is not equipped with a transponder, the requ est must be made at least one hour before the proposed operation.

Proposed Conditions #3, 25, 26, and 27 pertain to this particular regulation. Clearly, by following the aforementioned Proposed Conditions, and particularly all the reporting requirements contained in an
ATO

- Issued COA, the Petitioner can provide an equivalent level of safety as is provided by the existing rule and ensure adequate compliance with reporting standards as set forth in the rule.



### 14 C.F.R. 91.403 : General

Title 14, Part 91 , Section 91.403 of the Code of Federal Regulations states;

(a) The owner or operator of an aircraft is primarily responsible for maintaining that aircraft in an airworthy condition, including compliance with part 39 of this chapter

. (b) No person may pe rform maintenance, preventive maintenance, or alterations on an aircraft other than as prescribed in this subpart and other applicable regulations, including part 43 of this chapter

. (c) No person may operate an aircraft for which a manufacturer's mainten ance manual or instructions
for continued airworthiness has been issued that contains an airworthiness limitations section unless the mandatory replacement times, inspection intervals, and related procedures specified in that section or alternative inspect ion intervals and related procedures set forth in an operations specification approved by the Administrator underpart 121 or 135 of this chapter or in accordance with an inspection program approved under § 91.409(e) have been complied with.

(d) A person m ust not alter an aircraft based on a supplemental type certificate unless the owner or operator of the aircraft is the holder of the supplemental type certificate, or has written permission
from the holder.

Proposed Conditions #13, 14, and 15 pertain to t his particular regulation. Clearly, by following the aforementioned Proposed Conditions the Petitioner can provide an equivalent level of safety as is provided by the existing rule and ensure adequate compliance with maintenance standards as set forth
in the rule.PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 50



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

Title 14, Part 91, Section 91.405(a) of the Code of Federal Regulations states;

Each owner or operator of an aircraft

—
(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter ;
Proposed Conditions #13, 14, and 15 pertain to this particular regulation. Clearly, by fol lowing the aforementioned Proposed Conditions the Petitioner can provide an equivalent level of safety as is provided by the existing rule and ensure adequate compliance with maintenance standards as set forth
in the rule.



### 14 C.F.R. 91.407(a)(1) : Oper ation after Maintenance or Alteration

Title 14, Part 91, Section 91.407(a)(1) of the Code of Federal Regulations states;

(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

—
(1) It has been approved for return to service by a person authorized under§ 43.7 of this chapter.

Proposed Conditions #13, 14, and 15 pertain to this particular regulation. Clearly, by following the aforementioned Proposed Conditions the Petitioner can pro vide an equivalent level of safety as is provided by the existing rule and ensure adequate compliance with maintenance standards as set forth
in the rule.



### 14 C.F.R. 409(a)(1) and (2) : Inspections

Title 14, Part 91, Section 91.409(a)(1) and (2) of the Code of Federal Regulations states;

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

—
(1) An annual inspection in accordance with part 43 of this chapt er and has been approved for return to service by a person authorized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter

.PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 51

No inspection performed under paragraph (b) of this section may be substituted for any inspection required by this paragraph unless it is performed by a person authorized to perform annual inspections and is entered as an “annual” inspection in the required maintenance records.

Proposed Conditions #13, 14, and 15 pertain to this particular regulation. Clearly, by following the aforementioned Proposed Conditions the Petitioner can provide an equivalent level of safety as is provided by the existing rule and ensure adequate compliance with maintenanc e standards as set forth
in the rule.



### 14 C.F.R. 91.417(a) and (b) : Maintenance Records

Title 14, Part 91, Section 91.417(a) and (b) of the Code of Federal Regulations states;

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

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100

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

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

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

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

(2) Records containing the following information:

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

(ii) The current status of life

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

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

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

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

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 52 (vi) Copies of the forms prescribed by§ 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall r etain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed.

(2) The records spec ified in paragraph (a)(2) of this section shall be retained and transferred
with the aircraft at the time the aircraft is sold.

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

Proposed Conditions #13, 14, and 15 pertain to this particular regulation. Clearly, by following the aforementioned Proposed Conditions the Petitioner can provide an equivalent level of safety as is provided by the existing rule and ensure adequate compliance with maintenance standards as set forth
in the rule.



## Privacy

When discussing the use of s mall Unmanned Aerial Vehicles, the question of privacy frequently comes up. The reason for this is clear as small unmanned aircraft, despite their incredible uses as a tool, also have the potential to be used for nefarious activities, such as spying for example. This presents a risk to the personal privacy of individuals. Furthermore, in less extreme cases of invasion of privacy, a small unmanned craft might accidently capture imagery that would comprise someone’s privacy. Due to these potential privacy risks it is imperative for operators of small unmanned craft to use their aircraft

res ponsibly and focus on mitigating any of the potential privacy risks their aircraft creates. The Petitioner is particularly aware of the privacy concerns of individuals and due to this is extremely focused on providing privacy not only for individuals, but also for customers.


## Public Interest and Safety

According to the Federal Aviation Administration Guidelines for Section 333 Exemptions

, there are three main criteria a successful Petition for Exemption under Section 333 should have;

1. The Petitioner must submit a request for exemption from a rule or set of rules contained in 14
C

. F

. R

. that the Petitioner believe s will be a burden for their operations.

2. The Petitioner must provide a level of safety at least equal to that provided by the rule from
which the Petitioner is seeking a n exemption, and;

3. The Petitioner’s request must be in the Public Interest.

To satisfy these main guidelines, the following information will cover the justification of the proposed commercial operations under Section 333 requested by this Petition. More clearly, the followingPETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 53

arguments will show how each of the proposed applications/use

- cases are in the public interest and promote safety.

Specifically, the sUAS flights proposed in this petition will increase safety for the following applications; Agriculture, Cinematography, Closed

- Set Filming, Fire Services, Infrastructure, Insurance, Land Inspection, Law Enforcement, Search and Rescue, and Real Estate. Furthermore, it wi ll be seen that the

us e of sUAS by the Petitioner will also promote safety and reduce negative environmental impacts. This will be achieved because of the lower risks associated with a small, plastic, battery

- powered sUAS, as compared to a manned, multi

- thousand

- pound, combust ion

- engine

- powered, flammable

- fuel

- carrying
aircr aft. Plus, with most sUAS data

- capture happening at low altitudes, because of the enhanced da ta resolution possible at low altitudes, customers of sUAS services are getting better, more accurate data,
while at the same time the public is avoiding the potentially hazardous practice of ultra

- low

- flying manned aircraft. Clearly, the combination of better, more accurate data, coupled with the enhanced safety of a sUAS over manned aircraft, produces a viable com mercial operation that promotes the public interest. Evidence of this can be found in the industry

- specific examples below.

In addition to the aforementioned safety benefits and promotion of public interest s, it should also be
noted that all the sUAS ai rcraft utilized by the Petitioner satisfy the directives passed to the Federal Aviation Administration by Congress in t he Reform Act of 2012 . Specifically, all of the Petitioner’s aircraft satisfy the size, weight, speed, operating capabilities, proximity to airports, proximity to populated areas, and visual line of sight rules and requirements laid out by Congress. Furthermore, due to the FAA precedent of requiring, at minimum, a Sport Pilot’s Certificate, the FAA can be assured that all commercial fligh ts proposed in this Petition do not pose a threat to National Security as all PIC’s will have already been vetted by the Department of Homeland Security. For these reasons and for the numerous arguments contained herein, this Petition for Exemption provid es strong justification for approval of commercial operations for the above

- stated sUAS in the above

- stated applications and use

cases under Section 333, pursuant to the operating procedures and requirements described herein.

Furthermore, contained in th e FAA Modernization and Reform Act of 2012 was Congress’ clear initiative to integrate commercial sUAS flights into the National Airspace System. With this initiative it is definitive that Congress believ es that the integration of commercial sUAS into the National Airspace System is within the Public Interest as they are, obviously, elected representatives of the public assigned with the duty of driving policy that promotes the Public Interest. Thus, in addition to the industry

specific examples below, it should also be considered t hat the integration of all sUAS , pursuant to their safe integration to the NAS and providing of at least an equivalent level of safety as is provided by the current FAA rules, is inherently within the public interest.

Please look below to find more detailed descriptions as to why each of the applications highlighted above can provide a benefit to the public as a whole and r easons why the exemption would not adversely affect safe ty

.



### AgriculturePETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 54

Precision Agriculture is an industry that has seen a significant influx of sUAS use over the past few years. With this influx of Unmanned Aerial Vehicle Technologies, farmers and their Ag partners have become more efficient and effective in making various Ag

- related management decisions.

There is an adage that points to the importance of agriculture to the public that reads, “...once in your life you need a doctor, a lawyer, a pol iceman, and a preacher, but every day, three ti mes a day, you need a farmer.” 15 This adage really highlights the importance of agriculture to the public as a whole, as the Ag industry, and particularly farmers, are the people who provide the general publi c with one of their three essential needs, food.

What sUAS provide to the Ag Industry are a method by which to collect information and make management decisions that are more data

- driven and thus, more effective. Consider the use of sUAS to provide target ed scouting and aerial imaging/mapping to farmers and their Ag partners (Agronomists, Crop Consultants, Seed Dealers, etc.).

Every year millions of acres of farmland are scouted by a variety of people, whether it is the farmers themselves, or an Ag partn er of theirs, such as a Cooperative Agronomist, Crop Consultant, Field Intern, or other third party Ag partner. The idea behind scouting is to collect in

- season information about the crops and fields in question. As an example, a typical crop scouting in tern will get a set of field maps from their boss at the Coop every morning. These field maps will be for a variety of fields and crop types around the area and owned by a variety of farmers. The task of these interns is to go out in those fields
and col lect information relating to; Nutrient Deficiencies, Insect Pressure, Plant Diseases, Compaction, Plant Populations, and the like. They then take this information and report back to their agronomist or directly to the farmer. The farmer then takes this i nformation and makes management decisions based
on it.

The example above really highlights how a Precision

- focused farmer utilizes information to make a management decision and thus, increase yields and grow more food. This is obviously in the public
interest as it is estimated by the UN’s Food and Agricultural Organization (“FAO”) that by the year 2050 Global Food Production will have to increase by 70% of where it is today in order to feed a population
that is estima ted to grow to over 9 billion. 16

Where sUAS come into play is that they provide even more efficiency and data

- driven decision

- making than we even use today. Why is this? It is because a sUAS can provide a new perspective to look at agricultural crops and in turn provide a new data

- set from which inform ation can be derived and decisions can be made. Consider the same example as we highlighted above, with the crop scout walking a set of fields, taking a tissu e sample, and returning the lab

- data to the farmer so that the
farmer can make an In

- Season manag ement decision. Now consider this example if that crop scout were equipped with the same types of sUAS utilized by the Petitioner.

First of all, the scout would be much more efficient. A recent study at the University of Wisconsin

Whitewater showed that scouting with a sUAS was up to 80% more efficient than walking an entire
field. 17 Considering this efficiency fact alone, a scout is going to be much more efficient each day, which allows him/her to scout more acres and thus provide more information to mo re farmers to make data

driven decisions and produce more food as a whole. However, efficiency is not the only benefit.PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 55

In addition to efficiency, a scout can also be more targeted, meaning they can pinpoint areas of the field most in need of a thorough walk

- through and go straight to those spots as opposed to walking randomly through the field (which is the standard practice for many scouts). By gaining an aerial perspective with a sUAS, scouts can view the entire field in a video or picture quickly an d in turn, see blotches of discoloration or diseased crop instantly. Using the internal GPS Guidance System onboard the aircraft, this scout can also georeference their imagery, meaning each picture they take can be tagged with a
Geo

- coordinate (Latitude and Longitude). This allows them to pinpoint an area of distress in the field, get the geo

- tag, input it into their Smart Phone or Tablet, and walk straight to that area of distress. This is both efficient and vital to the farmer and his crop. While a t ypical crop scout might completely miss a distressed area of a field (due to the lack of an aerial perspective), a targeted scout with a sUAS is going to have the opportunity to point out all the issues in the field and in turn manage those areas to
minimi ze the damage (yield loss).

The same University of Wisconsin

- Whitewater study that found the increased efficiency statistics associated with sUAS use for crop scouting also found that when sUAS crop scouting is coupled with the recommended management app lications, farmers see, on average, a 7

- 10 bushel increase in production (corn). 18

With the majority of farms i n America (87% accordin g to the EPA’s 2007 Ag Census) 19 being in dividually or family

- owned, th e yield increases provided by enhanced scouting techniques utilizing UAVs increases revenues for farmers, which, in turn, powers local economies.

In addition to the basic benefits provided by a sUAS in terms of efficiency and targeted scouting of problem areas, there is also the benefit of using more advanced payloads to pull even more information from an aerial assessment utilizing a sUAS. Consid er the increasing popularity of Near

- Infrared and Thermal Infrared Imaging payloads. Both these payload types provide information to the farmer that can help in management decisions and management practices.

Furthermore, it should also be considered that these steps forward in efficiency a nd management

prac tices are accomplished while utilizing a safe and effective sUAS Tool that is not only maintaining the safety of the National Airspace but also taking into consideration customer and public privacy as well as eliminating the risks associated with the alternative form of imagery

- capture using a manned aircraft.

Referring back to the 4

- D analysis of UAV use, it is clear that the ag ricultural applications of data

- capture point to the use of UAV systems over manned aircraft because;

 Dull

– Ag flight s require repetition as crop stress and/or animal health needs to be checked frequently. In some applications, daily or even hourly flights may be necessary. Due to this requirement of high repetition, a sUAS is well suited for the job over a manned airc raft, which would basically require a full time pilot on

- call 24 hours a day.

 Dangerous

– Ag flights have the potential to carry a high degree of risk, especially when flying low over crops or cattle. Really, any low altitude flight in a manned aircraft is more dangerous than a high altitude flight because of the increase in obstacles and less margin for

error.PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 56

 Dirty

– Ag flights have the potential to be carried out in hazardous environments. As stated above, operating within a cattle herd with several aggressive bulls is a hazardous environment and an environment which is better navigated by a non

- huma n, such as a
sUAS.

 Deep

– Ag flights can sometimes be beyond the range of manned platforms. First, sUAS have the ability to fly at lower altitudes and thus capture higher resolution data than what a manned aircraft could do. Additionally, flights aro und structures on a farm or near a farm (such as silos, barns, radio towers, etc.) could potentially be hazardous for a manned aircraft
while a micro

- drone has a lot more maneuverability in tight spaces.

Therefore, the promotion of the public interest de scribed above coupled with the enhanced safety provided by sUAS flights in Agriculture, strongly supports the granting of this petition.

Additionally, the following previously granted exemptions point to the FAA’s acceptance of sUAS use in the Agriculture Industry as being within the public interest.

 Exemption Numbers:

o 11110

o 11136

o 11167

o 11192

o 11222



### Cinematography

The Aerial Cinematography I ndustry is an industry that has been operating for many years to capture
cinema

- quality footage from low altitudes. Initially

, this type of cinematography was captured using fixed wings and helicopters, but in more recent years, the business has started to utilize UAVs. The reason the industry has transitioned to these small aircraft is because newer UAV systems have been able to capture the quality video the industry is looking for but at a much lower cost and with significantly lower risks.

One of the reasons manned aircraft cinematography is so expensive is because of the dangers associated with flying a 6,000 pound aircraft, filled with flammable fuel, powered by a combustion engine, at low altitudes and over people. The insurance costs alone for these types of activities are high and accidents have happened in the industry. Some of these accidents have even lead to casualties. A couple years ago, 10 people died when two helicopters crashed while filming the French Realty Show, “Dropped.” 20 Whenever you have manned aircraft operating at low altitudes there are added risks. These risks include ground structures, confined spaces, and mor e. Additionally, when you have mannedPETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 57

aircraft, any accidents are much more catastrophic than if you had the same situation with unmanned aircraft. Once again, this is because of the size and flammable fuel carried on

- board manned aircraft. A
small Unma nned Aircraft does not have these attributes, plus, because there are no people on board, the chances of causalities is lower because there is no pilot.

It is important to remember that the weight of the UAVs utilized by the Petitioner will weigh no more
than 55 pounds and contain no crew, flammable fuel, or combustion engine. This limited weight and size will significantly reduce the potential for casualties or mass property damage in the case of a crash. Furthermore, the use of electric power by the Petitioner’s UAVs is much more environmentally

- friendly
than tha t of a manned aircraft, which are carrying a significant amount of unnecessary weight using
carbon

- based fuel sources. Therefore, in addition to the increased safety obtained by a UAV performi ng aerial cinematography, there is also the added public benefit of a healthier environment.

Furthermore, while traditional aerial cinematography utilizing conventional aircraft can perform in close proximity to people and property, it should be point ed out that a UAV is even safer than the traditional methods because of the limited size, weight, speed, operating conditions, and safety features included on the proposed aircraft within this petition. Additionally, as is highlighted in the FAA Moderniza tion and Reform Act of 2012, the integration of UAS into the National Airspace System is inherently in the public interest so long as it can be accomplished with at least an equivalent level of safety as is currently provided by existing FAA rules and regu lations.

On top of this, the utilization of sUAS in the Aerial Cinematography Industry falls in line with the 4D’s of UAS Intervention, which points to the Public Interest of using UAVs over manned aircraft. The reasoning for this can be seen below;

 Dul l

– Aerial Cinematography is an industry that requires repetitive flights. There are often multiple takes of the same scene in order to get the perfect shot with the perfect lighting. For this reason, the same flight has to occur several times in a short time period. This isn’t necessarily efficient for a manned aircraft because it needs to stay aloft during filming and due to this, wastes time and fuel waiting for successive shots. A UAV on the other hand can land in between shots and use significantly less power. Plus, because of the inherent risks of flying at low altitudes for manned aircraft (structures, people, obstacles, etc.), repetitive shots require repetitive risky flight operations.

 Dangerous

– Aerial Cinematography is almost always done at very low altitudes, which is very dangerous airspace for large, manned aircraft. There are more obstacles to consider at low altitudes and less margin for error. Therefore

, aerial cinematography flights using manned aircraft are more dangerous than if the same manned aircraft were operating at higher altitudes with less obstacles and more space. Thus, an unmanned craft is a safer alternative as it is more maneuverable in confined spaces and less damaging in the case of a crash.

 Dirty

– Some aeri al cinematography is extreme in nature and may include things like airborne obstacles. While the Petitioner’s UAV system would be maintaining a safePETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 58 distance from this hazardous environment and remaining within line of sight, it is important to consider t hat unpredictable accidents can happen in which a bird might fly into a prop as an example. In this situation

, it would obviously be better to have a small unmanned craft than a large, manned aircraft, carrying a pilot and flammable fuel. As
was seen in t he Miracle on the Hudson Incident, birds can have a devastating effect on an aircraft if they damage a prop or get sucked into an engine.

 Deep

– Some aerial cinematography might require capabilities that only an unmanned aircraft can perform, such as f lying in extremely close proximity to structures or other obstacles at low speeds. This type of application would be impossible for most manned aircraft and if not impossible, fairly dangerous. For this reason

, an unmanned aircraft would be required.

A dditionally, the following previously granted exemptions point to the FAA’s acceptance of sUAS use in the Aerial Cinematography Industry as being within the public interest.

 Exemption Numbers:

o 11540

o 11153

o 12031



### Closed

- Set Filming

Closed

- Set Fi lming is an industry in which small Unmanned Systems could play a vital role moving forward. The reasons for this are simple. First, due to the significant advancements in video and image quality capable from many UAVs, the utilization of these aircraft and UAV camera payloads are practical in the filming industry. With 4k video capabilities, it is clear that the camera systems available for UAVs today are sufficient for many professional filming applications. Furthermore, when you consider the

amount o f aerial footage common in many of today’s movies, TV shows, and the like, it is clear that aerial imagery is important to this industry. However, until relatively recently, much of this imagery was captured from manned aircraft such as planes or helicopt ers. These methods of aerial data capture are acceptable, however, they come at a much higher cost than unmanned aerial imagery and with many
more risks.

Once again, it is important to consider the size comparison between manned aircraft and unmanned
ai rcraft. Where all of the Petition er’s aircraft weigh less than 55 pounds, most manned aircraft weigh thousands of pounds, carry flammable fuel, and are extremely dangerous in the case of a crash. Unmanned aircraft however, are very small and pose much few er safety risks than their larger cousins. Additionally, they are significantly less expensive to operate and easier/safer to maneuver in close

proximity, low

- altitude situations, where most closed

- set filming occurs.PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 59

The aerial views capable with a U AV give productions unique vantage points and unique shots. This is because they can be operated safely at very low altitudes in comparison to manned aircraft. This is the case due to their smaller size and superior operating capabilities when in close p roximity to people, property, structures, natural features and the like.

Capturing imagery at low altitudes with a UAV provides for increased safety of ground personnel. Furthermore, it provides the public good of allowing low altitude filming with a mu ch less deadly aircraft should an accident occur. Even though these film shoots are closed to non

- participants it is important to remember that some of these flights may take place near non

- participating people and property. In the case of a crash, it wo uld be much safer for the public for the crashing vehicle to be a small, battery

powered UAV, than a large, multi

- thousand

- pound, manned aircraft.

Additionally, the utilization of sUAS in the Closed

- Set Filming Industry falls in line with the 4D’s of UAS Intervention, which points to the Public Interest of using UAVs over manned aircraft. The reasoning for this can be seen below;

 Dull

– The Closed

- Set Filming Industry is an industry that requires repetitive flights. Often, multiple flights must be perfo rmed over the same area to capture multiple shots of the same scene. This could be performed by a manned aircraft, however, it may be more advantageous to utilize a UAV, especially in situations where a flight with a manned aircraft may be risky due
to ha zards at low

- altitudes. Although one flight in a manned aircraft over the area might be possible, multiple flights repeatedly expose that aircraft and the pilot to ground

- based threats, which over time expose the aircraft to increased chances of an accide nt.

 Dangerous

– Closed

- Set Aerial Imagery is often captured at low altitudes, which is very dangerous airspace for large, manned aircraft. There are more obstacles to consider at low altitudes and less margin for error. Therefore, Closed

- Set Filming using manned aircraft is more dangerous than if the same manned aircraft were operating at higher altitudes with less obstacles and more space. Thus, an unmanned craft is a safer alternative as it is more maneuverable in confined spaces and less damaging in the case of a crash.

 Dirty

– Some Closed

- Set Filming is captured in potentially hazardous environments. While the Petitioner’s UAV system would be maintaining a safe distance from these potential hazards and remaining within line of sight, it is important to consider that mistakes can happen in unpredictable situations. A flock of birds for example might quickly change directions and come into contact with the aircraft. Usually this isn’t a big deal, however, larger birds, such as geese

or cran es, could significantly damage a manned aircraft by breaking a prop, damaging a window, or being sucked into an engine. Each of these situations is dangerous for the crew onboard. Therefore, it is the belief of the Petitioner that this same type of impac t with a small UAV would be safer than a manned aircraft because in the worst case scenario, there isn’t the loss of human life or significant damage to property on the gro und as the sUAS weighs below 55 pounds and doesn’t carry flammable fuel.PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 60

 Deep

– Some Closed

- Set Filming might require capabilities that only an unmanned aircraft can perform, such as flying in close proximity to structures or other obstacles at low speeds. This type of application would be impossible for most manned aircraft and if not impossible, fairly dangerous. For this reason, an unmanned aircraft would be required.

Additionally, the following previously granted exemption points to the FAA’s acceptance of sUAS use in
the Closed

- Set Filming Industry as being within the publi c interest.

 Exemption Number:

o 13779



### Fire Services

The Fire Fighting and Fire Response Industries are industries in which small unmanned aircraft will play a vital role moving forward and will off er support services. These industries are known for their rapid response times which are needed in order to save lives and property. Furthermore, the situations and environments common in these industries require constant visual observance to monitor rea l

- time changes in a fire’s progression. Currently, much of this is done, especially in forestry fires, using aerial imaging from a manned aircraft flying a safe distance away. The imagery captured on these flights is vital for the successful outing of th e fire but also for the safety of the people on the ground. A fire can move quickly and change directions on a dime. Due to this it is important for firefighters on the ground to have a constant, real

- time assessment of what is happening around them. In most cases a firefighter may not be able to see everything that is happening around them because they have an inferior vantage point on the ground as compared to the vantage point an aircraft can capture from the air.

The Petitioner seeks exemption under Section 333 in an effort to gain the right to provide services to the Fire Industry in order to help them in situations where a fire needs to be viewed from the air quickly. Where a manned aircraft may take a while to get to the scene and expose pilots to a hazardous environment, the type of sUAS utilized by the Petitioner is rapidly deployable, meaning it can be in the air sending a real time feed to a fire captain in minutes. With that information the captain can communicate with his guys on the ground to make sure they don’t get trapped or caught in a difficult situation. This is clearly in the Public Interest as this type of technology keeps firefighters on the ground
safe.

Forest fires especially, are situations in which firefighters can get trapped if they cannot see where the flames are moving in real time. Back in 2013, 19 elite firefighters were killed in Arizona battling a forest fire that turned around on them due to a wind change. 21 Although any aircraft is difficult to fly in a
smoke

- filled situation and the Petitioner will always maintain visual line of sight, an aerial perspective, even from a distance, can be helpful to those on the ground.

While an aerial perspective of a blaze is helpful, the Petitioner understands the value manned airc raft can provide to a fire situation and will not fly the sUAS unless given permission by the proper authorities and after ensuring they will not be interfering with any manned aircraft efforts.PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 61

In addition to providing the public good of keeping firefig hters safe, it should also be noted that the use of a small unmanned aircraft also provides a low

- cost alternative to manned aircraft. This would in turn drive down the costs to a fire department for manned aircraft surveillance and potentially help lower the burden on the public who fund the fire departments through taxes.

Furthermore, a UAV is a safer alternative to a manned aircraft in many firefighting situations. This is the case because often these flights will happen at low altitudes where the ris k of collision with ground

based features, obstacles, or the like are greatest. A manned aircraft is not as well suited for these flying environments because they are bigger than sUAS, they carry a crew, they are not as maneuverable, and they carry flamma ble fuel. When you couple this with their higher costs to operate, it is clear that an unmanned craft can provide value in terms of cost savings and enhanced safety.

On top of this, the utilization of sUAS in the Firefighting/Fire Response Industry fal ls in line with the 4D’s of UAS Intervention, which points to the Public Interest of using UAVs over manned aircraft. The reasoning for this can be seen below;

 Dull

– The Fire Industry is an industry that requires repetitive flights. Often, especially wi th
fixed

- wing aircraft, a pilot must fly his plane over a specific area in which the blaze is occurring. Due to the fact that planes cannot effectively hover, the pilot must perform the same approach and flyover, over and over again in order to keep a con stant eye on the situation. The sUAS used by the Petitioner however, has the ability to hover in one spot, giving it the ability to maintain constant visual contact over the area of interest. When the pilot of a plane performs the same dull flight over a nd over, they may overlook an obstacle they have previously avoided. This can cause accidents. A UAV on the other hand is a bit more automated, meaning it can hover in place and use its onboard flight controller to automatically adjust for wind and
maint ain its position.

 Dangerous

– Aerial Fire Imagery is often captured at low altitudes, which is very dangerous airspace for large, manned aircraft. There are more obstacles to consider at low altitudes and less margin for error. Therefore, Fire flight s using manned aircraft are more dangerous than if the same manned aircraft were operating at higher altitudes with less obstacles and more space. Thus, an unmanned craft is a safer alternative as it is more maneuverable in confined spaces and less damagi ng in the case of a crash as it weighs significantly less and doesn’t carry a
crew or flammable fuel.

 Dirty

– Most Aerial Fire Imagery is captured in hazardous environments. While the Petitioner’s UAV system would be maintaining a safe distance from t hese potential hazards and remaining within line of sight, it is important to consider that mistakes can happen in unpredictable situations. If for instance, the wind were to change direction, blowing smoke into the flight path, the pilot of a UAV has aut omated fail

- safes that will bring the aircraft home automatically. A manned aircraft on the other hand is going to have to rely on a human to get it back safely.PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 62

 Deep

– Some Fire Imaging might require capabilities that only an unmanned aircraft can

pe rform, such as flying in close proximity to natural features or other obstacles at low speeds. This type of application would be impossible for most manned aircraft and if not impossible, fairly dangerous. For this reason an unmanned aircraft would be re quired.

Additionally, the following previously granted exemption points to the FAA’s acceptance of sUAS use in the Fire Support Industry as being within the public interest.

 Exemption Number:

o 13677



### Inf rastructure

Contained in the FAA Modernization and Reform Act of 2012 was Congress’ clear initiative to integrate commercial sUAS flights into the National Airspace System. With this initiative it i s definitive that Congress believes that the integration of sUAS into the National Airspace System is within the Public Interest as they are, obviously, elected representatives of the public assigned with the duty of driving policy that promotes the Public Interest. Furthermore, as it pertains to Infrastructure Inspection specifically, it should be noted that the utilization of sUAS is perfectly in line with Dull, Dirty, Dangerous, and Deep operations that the 4 D's of UAV Intervention have highlighted as suitable for Unmanned Aerial Systems. In particular, it can be seen that sUAS operations in the Industrial Inspection Industry are often;

 Dull

– Flights in the Inspection business are repetitive in nature, which means multiple flights and flight operation s will have to be conducted in close proximity to obstacles, such as industrial structures. The necessity of repeated inspections requires an on

- demand flight craft that can be called upon instantly to provide a visual inspection. It is for this reason t hat a sUAS is perfectly designed for such operations and why manned aircraft are not.

 Dangerous

– Obviously, visual inspections of infrastructure are inherently dangerous operations. This is the case because industrial inspections are generally of stand ing structures, such as water towers, bridges, cell towers, poles, power lines, etc. All of these industrial structures are standing obstacles that provide a hazard to low flying aircraft, and particularly to large, manned,
low

- flying aircraft. Therefore , it is better to use a small unmanned aircraft because operations are less risky due to the smaller size of the aircraft which increases a Pilot's margin for error.

 Dirty

– Industrial areas can often times be hazardous environments that pose potential health and safety threats to people and aircraft. For this reason

, it is much better to send in a small, unmanned aircraft than a large, manned aircraft. Consider a hazardous materials plant. Obviously it would be much better to have a robot flying over the plant than an aircraft carrying a person who could potential breath e in fumes.PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 63

 Deep

– For some industrial inspections, the inspection flight might only be able to be carried out by an unmanned aircraft due to the technology and maneuverability requi rements of the flight. Consider an industrial inspection of a wind turbine as an example. Wind Turbine Inspections take place in extremely hazardous areas for manned aircraft due to the many obstacles (all the turbines) in a confined airspace. In order to get a good look at the Turbine and its blades, a
close

- proximity flight would be required, which would take extreme maneuverability in small spaces, which just isn’t possible with most manned aircraft. Additionally, it would be beneficial
to have some sort of object avoidance technology in an environment like a wind turbine inspection situation. However, manned aircraft do not have this precise technology in most aircraft and instead, most flights are manually piloted. Unmanned craft do have this tech nology
however and two of the Petitioner’s aircraft, the DJI Pha n t o m 4 and DJI Matrice 100 have this option available

. This makes close

- quarter flights much safer. Thus, the use of this type of technology coupled with a UAV’s s uperior maneuverability, make a sUAS the perfect tool for industrial inspections.

Furthermore, it is important to look at the current alternatives for Industrial Inspections when judging the relative safety provided by a sUAS inspection. The most commo n of these various alternatives are ground

- based inspections, which are limited in effectiveness, crane

- lift inspections, which are highly dangerous and have a limited reach, physical climbing of the structure, which is dangerous and slow, and inspections conducted by manned aircraft, which are typically flammable

- fuel

- filled, combustion

engine, helicopters. A sUAS inspection is superior to each of these alternatives as it is at least as safe and in most cases, more safe than the aforementioned alternatives and it doesn’t fall victim to the various shortcomings of each of these substitute options.

Take ground

- based inspections as an example. One of the current inspection strategies used on turbines is the use of a telescope to find scorch marks on the tur bine blades. Clearly, this would be a less effective strategy than utilizing an unmanned aerial vehicle. Consider the resolution you’d have looking though a telescope at a wind turbine blade a couple hundred feet away as compared to a 4000x3000 pixel Ult ra

- HD image from 5 feet away using a UAV. Plus, a 4K image can be zoomed in on and remain in high resolution, meaning you could literally zoom in on your images from the UAV as if you were only a few inches away from the actual scorch mark.

Furthermore, consider the significant safety issues that are brought about by some of the other alternatives of infrastructure inspection. Using a lift for example exposes inspectors to electrocution risks, tipping risks, and more. Plus, with the limited reach achie vable by a lift, you often can’t lift an inspector high enough to inspect an entire structure. This is true of radio towers as an example. Many of the lifts available on the market cannot reach more than half way up most radio towers, which means
much of the tower cannot be inspected. A study from the Electronic Library of Construction Occupational Safety and Health found that, on average, 26 construction workers die each year resulting
from the use of aerial lifts. 22 Causes of death include, electrocut ion, boom collapse, falls, and more. In total, aerial

- lift

- related deaths account for 2

- 3% of construc tion related deaths each year. 22PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 64

Another dangerous strategy used for inspections is the physical climbing of infrastructure. This is typically done wit h ropes and straps. This is obviously dangerous as you have humans dangling high above the ground, where they are at risk of serious if not fatal injuries in the case of a fall. Plus, any poor weather that blows in during one of these climbs exposes thes e inspectors to various risks, including electrocution. Clearly, the use of an unmanned aircraft would be much safer than someone hanging off the side of a cell tower, water tower, or wind turbine as an example. In fact, OSHA, just this
past year, started reclassifying and reevaluating how it investigates worker injuries and deaths in the tower climbing industry, which has been dubbed the most dangerous job in America. In August of 2013, four tower climbers died in a two week span across the United States. 23 When you consider that the entire industry is made up of about 10,000 people, you can see the dangers associated with this industry and why the use of unmanned systems is needed.

Finally, when looking at the inspection strategy of using manned aircraft (typically helicopters) you can see the risks. First, the goal of most infrastructure inspections is to get a close

- proximity view of a structure. This goal in and of itself is dangerous for a manned aircraft as it requires a close flyby to a

st ructure. Additionally, many of the flights in the infrastructure industry require close proximity to more than one structure. Consider the practice of power line inspection and the use of helicopters. Not only do these aircraft have to stay focused on t he power pole they are next to, they must also pay attention to all the other poles and lines in their vicinity. Unfortunately, sometimes mistakes are made and typically the results are catastrophic, with fatalities and complete loss of the aircraft. The book Helicopter Crash Litigation by Gary C. Robb highlights the problem of helicopter accidents and the relatively frequent rate at which accidents occur. Specifically, it was found that, “from 2001 to 2005, the accident rate for civil helicopter use per 100,000 flight hours was forty percent (40%) higher than that for general aviation fixed

- wing ai rcraft. 24 The helicopter industry itself has acknowledged that the current helicopter accident rate is "excessive and unsustainable.” 24 Considering this fact, it should be noted that helicopters, which are already statistically more prone to accidents than fixed wings, are the vehicle of choice in the utility industry. It should also be noted that the environments presented by the utility industry are even mor e dangerous than general helicopter airspace due to the increase in obstacles and close proximity to infrastructure.

Taking all of this into consideration, it is clear that the use of unmanned aircraft for the purpose of infrastructure inspection provide s a public service while maintaining, and most often exceeding, the current safety achieved by the present rules and regulations governing the infrastructure inspection industry.

Accordingly, the Petitioner respectfully asks for exemption in order to comme rcially operate sUAS aircraft in the Infrastructure Inspection Industry.

Furthermore, it should also be noted that the following previously granted exemptions point to the FAA’s acceptance of sUAS use in the Infrastructure Inspection Industry as being wi thin the public
interest.

 Exemption Numbers:

o 11865
o 11813PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 65

o 11721



### Insurance

Another industry that is going to see huge potential in the next cou ple years through the utilization of sUAS aircraft is the insurance industry. One of the reasons for this is the obvious benefit an aerial perspective can be when assessing an insurance situation, be it a car accident, crop damage, building collapse, or t he like. The ability to get above the insured asset allows for a clearer perspective of the situation and provides a bird’s eye view of what happened. This allows for more accurate insurance estimates and in turn, more accurate payouts.

Using the examp le of crop insurance, it is clear to see the public benefit of utilizing sUAS aircraft for the purposes of insurance.

The crop insurance industry is a big business. Every year acres of a variety of crops are insured from loss with large crop insurance a gents throughout rural America. In the situation of a large thunderstorm or Tornado coming through an area, consider the amount of damage that can be done to a corn crop. If the corn is laid flat from high winds or is damaged significantly from hail, the farmer is going to experience some type of yield loss. The payout that farmer receives is going to be dependent on the extent of his yield loss as is determined by an insurance adjuster. To determine the farmer’s loss an adjuster might use a variety of strategies, including; remaining population counts, standard deviation calculations, and the like. However, when a large swath of area is damaged by a storm, insurance adjusters are spread thin trying to get accurate estimates for every field in the area. This can lead to overestimates, underestimates, and in general, incorrect or otherwise errored payouts. This can lead to losses for the insurance company, losses for the farmer, and premiums that are based on payouts that may be inaccurate.

However, b y utilizing sUAS aircraft, this could change, as the use of UAVs and software could allow for more efficient, automated practices. As an example, a software program that can use counting programs or image recognition technology to estimate losses would be much more automated and potentially more accurate than a team of adjusters who all might have slightly different biases when making assessments. Furthermore, the estimates and payouts as a whole across an entire insurance company would be much more consi stent, as the same software is reading all the imagery captured and thus, automation allows for consistency and confidence in operations.

The crop insurance example is just one example of how the insurance industry can benefit from the use
of sUAS aircra ft, however, this same principle can be see across a variety of applications in the broader insurance industry. The public benefit of this is clear, as having more accurate and consistent payouts makes insurance companies more efficient and thus, premiums are more accurate.

Furthermore, the insurance industry is another industry that sUAS should be used for according to the 4
D’s.

 Dull

– The insurance industry is another industry that may require repeated flights of the same

area or on

- demand flights. Consider crop insurance. In the situation where a small pocket of a

coun try received hail , only a couple farms or even a couple farm fields are actually affected.PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 66

Therefore, only one or two fields may need to be flown that day. It would b e much better to have a UAV in the adjuster’s vehicle so he can fly on

- demand that day only where there are issues, as opposed to hiring a manned aircraft to fly over and maybe only take a picture of one or a few fields. Furthermore, weather events may be sporadic, meaning as the adjuster goes from farm to farm, he isn’t sure if there is extensive damage or not and therefore

, it would be an expensive proposition to send a plane up when there isn’t a certainty that there is extensive damage to film.

 Dangerous

– Commercial sUAS Insurance flights might also be dangerous. Consider a damaged building or structure. It may be better to fly that dangerous structure with a small unmanned craft just in case that structure was threatening to collapse.

 Dirty

– Cons ider a hazardous spill that came as a result of a derailed train or overturned semi

trailer. This example is an insurance event in which an adjuster is going to want to assess the damage while avoiding a dangerous environment. Noxious fumes may be in the area and as such, the adjuster might want to fly the area with a sUAS.

 Deep

– Once again, sUAS allow for operators to capture high resolution data at low altitudes. This is true in the Insurance Industry as well and low altitude flight can be especia lly dangerous for manned aircraft. In particular, any high resolution data collection at low altitudes and in confined areas can be impossible for manned aircraft as their maneuverability is such that the confined area is too small for safe flight. Consi der a grain facility that is damaged in a tornado. That facility should be inspected at low altitudes, but there are a variety of obstacles, such as grain towers and cables, that would pose a threat to a manned aircraft.

Additionally, the following prev iously granted exemptions point to the FAA’s acceptance of sUAS use in the Insurance Industry as being within the public interest.

 Exemption Numbers:

o 11293

o 11857



### Land Inspection

The Land Information Industry is an industry poised to gain a lot from the utilization of sUAS aircraft. The aerial perspective these units can provide to a land surveyor or developer, is enormous. Land
Information cover s a broad range of land evaluation applications. One of the main applications that is currently being used is stitched, 3D mapping, which allows for operators to visualize a landscape in highly accurate 3D form. This allows for accuracy in the centimeter range, which can help landPETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 67

managers determine tile lines in agriculture, engineers develop drainage ditches for streams, planning commissions create plat maps for new developments, and architects design new building construction.

All of these applications are in the public interest. A land manager putting in tile lines in his agricultural fields helps quell runoff and erosion issues, which leads to higher yields, a healthier environment, and less pollution in our waterways. Additionally, the engineer who is developing drainage paths and ditches based on 3D mapping from a sUAS is going to prevent large

- scale flooding, which reduces damages to surrounding communities and, in turn, lowers insurance premiums for the country as a whole. In much the same way, planning commissions creating maps and running lines into a new development helps foster community growth and ensures the right amount of infrastructure for the community. Finally, the architect designing a new building will be better able to place that b uilding on solid ground and allow it to better fit in the surrounding landscape. This helps ensure the safety of the building while also ensuring the community looks nice.

Referring back to the 4

- D analysis of UAV use, it is clear that the Land Informatio n Services Industry has many applications of data capture that point to the use of UAV systems over manned aircraft because;

 Dull

– Land Information Flights may require a lot of repetition and/or rapid deployment of a data capture device to ensure data is captured at the right time. A government agency looking to quell runoff issues into local lakes and streams from agricultural fertilizers may want to examine 3D maps and drainage maps that are captured when it is raining or after a heavy rain. The charac teristics of these specific flight times will better show the results of water flowage as the flowage is happening or right after it happened. This allows for more accurate mapping and a better idea of the real world drainage issues in an area. Having th is information leads to better engineering which in turn leads to a healthier environment and community.

 Dangerous

– As the example above shows, the rapid deployment of a sUAS in a rain storm or right after a rain storm could be dangerous for a manned aircraft. Most private pilots who would be flying to take imagery like this would want to avoid weather so as to not have to be instrument rated or have to operate in non

- visual conditions. Cloud cover may be low during these rain events as well, which may make imagery from a manned aircraft impossible to capture. However, with a sUAS operating below the clouds, you could capture this imagery so long as you have the ability to follow VFR requirements. With weather often changing in an instant, a small opening in the clouds in one area might be all you need to fly a sUAS on a mapping mission while manned aircraft is grounded due to the overall weather in the surrounding area.

 Dirty

– Land Information flights by nature may occur in hazardous environ ments. A lot of the 3D mapping missions conducted in this industry are done in areas of high topography, which can be hazardous for manned aircraft at low altitudes.PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 68  Deep

– Once again, sUAS allow for operators to capture high resolution data at low
alt itudes. This is true in the Land Information Industry as well and low altitude flight can be especially dangerous for manned aircraft. In particular, any high resolution data collection at low altitudes and in confined areas can be impossible for manned aircraft as their maneuverability is such that the confined area is too small for safe flight.

Therefore, the promotion of the public interest described above coupled with the enhanced safety provided by sUAS flights in the Land Information Industry, s trongly supports the granting of this petition.

Furthermore, the following previously granted exemptions point to the FAA’s acceptance of sUAS use in Land Information/Management Industry as being within the public interest.

 Exemption Numbers:

o 11109

o 11204

o 11286



### Law Enforcement

The Law Enforcement Industry is an industry in which small unmanned aircraft will play a vital role moving forward. This industry is known for its rapid response times which are needed in order to save lives and property. Furthermore, the environments common in this industry require constant visual
observance to monitor real

- time changes in a situation. Currently, much of this is done through the use of helicopters which can provide an aerial vantage point in instances of running criminals, hostage situations, traffic situations, and more. The imagery captured on these flights is vital in order to
communicate with officers on the ground on how to best handle the situation. In many policing activities you want to be on the high

- ground or have an elevated vantage point from which to assess the conditions below. A UAV can provide this vantage point quickly, inexpensively, an d effectively.

The Petitioner seeks exemption under Section 333 in an effort to gain the right to provide services to the Law Enforcement Industry in order to help them in situations where conditions on the ground need to be viewed from the air quickly. W here a manned aircraft may take a while to get to the scene and expose pilots to a hazardous environment, the type of sUAS utilized by the Petitioner is rapidly deployable, meaning it can be in the air sending a real time feed to the police in minutes. Wi th the information captured during these flights, support personnel can relay information to officers on the ground in order to make sure they don’t get caught in a difficult situation. This is clearly in the Public Interest as this type of technology kee ps police officers on the ground safe.

While an aerial perspective of a police situation is valuable, the Petitioner understands the value manned aircraft can provide to a situation as well and will not fly the sUAS unless given permission by the proper authorities and after ensuring they will not be interfering with any manned aircraft efforts.PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 69

In addition to providing the public good of keeping police officers safe, it should also be noted that the use of a small unmanned aircraft also provides a low

- cost alternative to manned aircraft. This would drive down the costs to a police department for manned aircraft surveillance and potentially help lower the burden on the public who fund the police departments through taxes.

Furthermore, a UAV is a safer alternative to a manned aircraft in many situations. This is the case because often these flights will happen at low altitudes where the risk of collision with ground

- based features, obstacles, or the like, are greatest. A manned aircraft is not as well suited for these flying environments because they are bigger than sUAS, they carry a crew, they are not as maneuverable, and they carry flammable fuel. When you couple this with their higher costs to operate, it is clear that an unmanned craft can provid e value in terms of cost savings and enhanced safety.

Furthermore, aerial data may be collected more by a Police Department if that department had a low

cost solution. This is valuable to the public as more data can lead to better policing which in turn k eeps communities safer. Additionall y, situations where an aerial vantage point would be useful but do not warrant the price of hir ering a helicopter or plane, may be imaged with a UAV. For example, consider a
car accident. It would be nice to have an aerial perspective after the accident has happened. Based on the imagery the officers could study the skid marks and determine what exactly happened. Plus, all of
the data is documented and can be used for future litigation or insuranc e claims.

On top of this, the utilization of sUAS in the Law Enforcement Industry falls in line with the 4D’s of UAS Intervention, which points to the Public Interest of using UAVs over manned aircraft. The reasoning for this can be seen below;

 Dull

– The Law Enforcement Industry is an industry that requires potentially dull flights. Often, especially with helicopters, a pilot must maneuver their helicopter into position and then hover. Once the pilot begins to hover the actual flying can become dul l as the situation on the ground is more interesting. This may take away the pilot’s attention which could lead to accidents if the helicopter drifts into a ground

- based obstacle, such as a powerline for example. The sUAS used by the Petitioner however h as the ability to hover in one spot without human controls, giving it the ability to maintain constant visual contact over the area of interest. This automated function means the UAV can hover in place and use its onboard flight controller to automaticall y adjust for wind and maintain its GPS position within a few feet.

 Dangerous

– Aerial Law Enforcement Imagery is often captured at low altitudes, which is very dangerous airspace for large, manned aircraft. There are more obstacles to consider at low

a ltitudes and less margin for error. Therefore, Law Enforcement flights using manned aircraft are more dangerous than if the same manned aircraft were operating at higher altitudes with less obstacles and more space. Thus, an unmanned craft is a safer alt ernative as it is more maneuverable in confined spaces and less damaging in the case of a crash as it weighs significantly less and doesn’t carry a crew or flammable fuel.

 Dirty

– Most Aerial Law Enforcement Imagery is captured in hazardous environment s. While the Petitioner’s UAV system would be maintaining a safe distance from these potential hazards andPETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 70

remaining within line of sight, it is important to consider that mistakes can happen in unpredictable situations. If for instance, a criminal were to shoot at the aircraft, the results would be much less dangerous with an unmanned aircraft than a manned aircraft because there is no crew to get injured and if the UAV were to crash, the damage would be minimal due to its small size in comparison to a m anned aircraft.

 Deep

– Some Aerial Law Enforcement Imaging might require capabilities that only an unmanned aircraft can perform, such as flying in close proximity to structures or other obstacles at low speeds. This type of application would be impos sible for most manned aircraft and if not impossible, fairly dangerous. For this reason

, an unmanned aircraft would be required.

Additionally, the following previously granted exemption points to the FAA’s acceptance of sUAS use in
the Law Enforcement I ndustry as being within the public interest.

 Exemption Number

o 11419



### Real Estate

The Real Estate Industry was one of the first industries to be g ranted an Exemption under Section 333.
One of the reasons for this is the obvious benefit the utilization of a small unmanned aircraft can provide for the purposes of property and home sales. The ability to gain an aerial perspective of a property or hou se allows potential buyers a way of seeing the property in its entirety. When thinking about traditional real estate listings, there are often a series of photographs of the house or property, and its surroundings. However, these pictures are not necessa rily cong ruent, making it difficult to put one picture with the next picture and get a walk around of the property.

Furthermore, aerial cinematography for real estate has existed for many years, however it has previously been accomplished using manned fixed wing or helicopter aircraft. The expense of utilizing
this form of ci nematography is extremely high and prices many realtors and homeowners out of this
form of ma rketing. However, this form of marketing is very valuable and would likely be used by low

budget sellers and agents if it were available.

Additionally, utilizing manned aircraft to capture the type of aerial marketing possible with a sUAS poses signific ant threats and problems to a community. Obviously

, a low flying plane or helicopter would supply significant noise and annoyance among neighbors of a home being videoed from a plane or helicopter. It is for this reason that there are noise ordinances acr oss the country pertaining to manned aircraft. Obviously, a light

- weight sUAS will produce much less noise than a helicopter or plane operating at low altitudes. Furthermore, there is also substantially less risk associated with a sUAS performing a low

- a ltitude real estate flight, especially in populated neighborhoods. This is the case because if a manned aircraft goes down in a populated neighborhood there will likely be fatalities orPETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 71

significant damage to the plane and crash site. A sUAS on the other hand would likely cause little damage in the case of a catastrophic crash. Plus, because the sUAS proposed in this petition do not carry combustible fuel, the after

- effect damage is far less as well because there isn’t a risk of a fuel tank exploding or s tarting on fire.

Furthermore, when looking back at the 4D’s of UAV Use, it is clear that Real Estate photography and cinematography using small unmanned aircraft fits the 4D’s.

 Dull

– Real Estate flights for aerial cinematography are a sUAS use

- case mar ked by repetition and on

- demand access. More clearly, homes may need to be flown multiple
times and on

- demand. The key to a good real estate video is that it nicely highlights the features of the real estate being filmed and does so in good lighting cond itions. With a

manne d aircraft

, this is expensive to do. Plus, with many private pilots renting their aircraft, it would be hard to anticipate what time to rent the plane in order to have it in position at the perfect time.

 Dangerous

– Real Estate flights using manned ai rcraft would be highly dangerous in comparison to unmanned aircraft. The reason for this is because most flights take place low to the ground, right above houses and many times above highly populated neighborhoods. An accident with a manned aircraft in t hese conditions could be catastrophic, with potentially many casualties and a lot of property damage. An unmanned craft, like the ones described in this petition, would cause much less damage
in the case of an accid ent, as they are small, battery

- powered, and weigh under 55 lbs.

 Dirty

– Commercial UAV flights in the real estate industry can also be dirty, in that they can take place in potentially hazardous environments. Commercial real estate in particular, in which large factories or plants may be being sold, could pose hazardous environments that are best filmed by sUAS aircraft so as to not expose humans to hazardous waste, gases, or materials for example. Furthermore, decrepit or abandoned buildings that are dangerous to walk through or near, m ay be best flown using an
unmanned aircraft.

 Deep

– Once again, sUAS allow for operators to capture high resolution data at low altitudes. This is true in the Real Estate Industry as well and low altitude flight can be especially dangerous for manned ai rcraft. In particular, any high resolution data collection at low altitudes and in confined areas, such as in neighborhoods as an example, can be impossible for manned aircraft as their maneuverability is such that the
confined area is too small for safe flight.

Finally, because the proposed sUAS contained in this Petition are battery

- powered, they do not release environmentally hazardous emissions. Thus, utilizing these micro

- UAVs in place of manned aircraft benefits the public by promoting a healthi er environment.PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 72

By granting this Petition for Exemption and allowing commercial sUAS flights in the Real Estate Industry, the FAA will be contributing to economic growth by supporting the housing industry and commercial real estate industry, thereby str engthening the economy. Furthermore, all of this can be done by maintaining the safety of the National Airspace and people & property on the ground.

Additionally, the following previously granted exemptions point to the FAA’s acceptance of sUAS use in the Real Estate Industry as being within the public interest.

 Exemption Numbers:

o 11062

o 11109

o 11112

o 11213

o 11364



### Search and Rescue

The Search and Rescue Industry is an industry in which small unmanned aircraft will play a vital role moving forward. This industry is known for its rapid response times which are needed in order to save lives. Furthermore, the situations and environments common in this industry require documented
visual obs ervance over broad areas. Currently, much of this is done using aerial imaging from a manned aircraft. The imagery captured on these flights is vital not only when it comes to finding lost people but also in documenting areas that have already been searc hed. In a searching effort

, this is important because searchers don’t want to waste time looking in areas that have already been searched. Utilizing a UAV allows for searchers to get an aerial vantage point as well as document areas that have been
search ed accurately. For instance, a search crew could map the areas of interest using their UAV, stitching the images they get from the camera and have a georeferenced map of the area in question. In most cases this map is laid over Google Earth and can clear ly mark an area that has already been searched. Additionally, because the map is georeferenced, the user can pinpoint locations or objects of interest and pull a latitude and longitude for a more detailed search. This is a highly valuable attribute
of st itched imagery from a UAV.

In addition, a UAV can provide a superior vantage point for searchers operating on the ground. The UAV utilized by the Petitioner offers long

- range, high definition FPV which can be used by a team leader to relay to his ground searchers where to move next and if he sees anything of interest from the air.

The Petitioner seeks exemption under Section 333 in an effort to gain the right to provide services to the Search and Rescue Industry in order to help in situations where a vi sual inspection from the air is necessary. The Petitioner seeks this exemption because they believe the use of unmanned aircraft in this industry will provide a public good while maintaining the safety of the National Airspace System.PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 73

The Petitioner’s U AV is rapidly deployable meaning it can help in time

- sensitive rescue efforts. Additionally, with its ability to take high definition video and pictures while georeferencing all of its images, the Petitioner’s UAV can be a valuable asset to a Search and R escue Team. Plus, with the aerial perspective this type of UAV can provide, the chances of finding a lost or periled individual increase. Clearly, finding and saving lost people is a public good and one that can be bolstered through the use of

a UAV.

Furthermore, utilizing a UAV for this type of work is a safer alternative when compared to manned aircraft. This is the case because often these flights will happen at low altitudes where the risk of collision with ground

- based features, obstacles, or the like are greatest. A manned aircraft is not as well suited for these flying environments because they are bigger than sUAS, they carry a crew, they are not as maneuverable, and they carry flammable fuel. When you couple this with their higher costs to operate, it is clear that an unmanned craft can provide value in terms of cost savings and enhanced safety to the Search and Rescue Industry.

On top of this, the utilization of sUAS in the Search and Rescue Industry falls in line with the 4D’s of UAS

I ntervention, which points to the Public Interest of using UAVs over manned aircraft. The reasoning for this can be seen below;

 Dull

– The Search and Rescue Industry is an industry that requires dull flights. Often, especially
with fixed

- wing aircraft, a pilot must fly his plane over a specific area of interest in a very specific and straight

- line pattern. This is to ensure complete coverage of the search zone. This causes the pilot to fly the same straight line routes, one next to the other, over and ov er. The “dullness” of this flight might cause a pilot’s mind to wander which can lead to accidents. The sUAS used by the Petitioner however, have the ability to utilize preprogrammed flight routes, which can automate the process and allow for safer opera tions.

 Dangerous

– Aerial Search and Rescue Imagery is often captured at low altitudes, which is very dangerous airspace for large, manned aircraft. There are more obstacles to consider at low altitudes and less margin for error. Therefore, Search an d Rescue flights using manned aircraft are more dangerous than if the same manned aircraft were operating at higher altitudes with less obstacles and more space. Thus, an unmanned craft is a safer alternative as it is more maneuverable in confined spaces and less damaging in the case of a crash as it weighs significantly less and doesn’t carry a crew or flammable fuel.

 Dirty

– Aerial Search and Rescue Imagery is sometimes captured in hazardous environments. While the Petitioner’s UAV system would be m aintaining a safe distance from these potential hazards and remaining within line of sight, it is important to consider that mistakes can happen in unpredictable situations. For instance, if a UAV is being used to provide a live

- feed view of a
rescue situ ation, there may be a host of unpredictable hazards such as rock

- falls, crashing waves, avalanches, or the like. In each of these situations it would be better to have an expendable UAV system rather than a manned aircraft with lives onboard.PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 74

 Deep

– Some Search and Rescue imaging may require capabilities that only an unmanned aircraft can perform, such as flying in close proximity to natural features or other obstacles at low speeds. This type of application would be impossible for most manned aircr aft and if not impossible, fairly dangerous. For this reason an unmanned aircraft would be required.

Additionally, the following previously granted exemption points to the FAA’s acceptance of sUAS use in the Search and Rescue Industry as being within t he public interest.

 Exemption Number:

o 11419


## Regulations Requested for Exemption

Appendix 1: Regulations Requested for Exemption

– List

https://drive.google.com/file/d/0B8sknt2 zpxhMajc4dHA2bjE4bjg/view?usp=sharing



## Exhibit List

Exhibit 1 A : Dronefly, Inc. Operations Manual

https://drive.google.com/file/d/0B8sknt2zpxhMLTR5cjd0UkwyYk0/view?usp=sharing



### Exhibit 1B: Dronefly, Inc. Motion Picture and Television Operations Manual (“MPTOM”)

https://drive.google.com/file/d/0B8sknt2zpxhMUzlocnBNdDZaZlk/view?usp=sharing



### Exh ibit 2: Dronefly, Inc. Logbook Example

Below is a logbook example from the app that is running the Flight Logs for the Petitioner’s aircraft. The specific flight logs pictured are just an example and not specific to the Pet itioner’s prior flights. In addition to the logbook, please see the linked video ( https://www.youtube.com/watch?v=4afE

- rd6xoY ) that shows how the flight logs can be played back utilizing the same logging app for each flight.PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 75



### Exhibit 3: Dronefly, Inc. Visual Observer Training Procedures & Guide

Visual Observer Training Procedures

https://drive.google.com/file/d/0B8sknt2zpxhMNFllQVJZdHVsQ0E/view?usp=sharing



### Visual Observer Training Guide

https://drive.google.com/file/d/0B8sknt2 zpxhMbElBZTcwUi02aHM/view?usp=sharing



### Exhibit 4: Dronefly, Inc. Pilot In Command Training Guide

Pilot In Command Training Procedures

https://drive.google.com/file/d/0B8sknt2zpxhMNFllQVJZdHVsQ0E/view?usp=sharing



### Pilot in Command Training Guide

https://drive.google.com/file/d/0B8sknt2zp xhMREF0OHZLZ25Jc2M/view?usp=sharing



### Exhibit 5: DJI Phantom

http://www.dji.com/product/phantom



### Exhibit 6: DJI Phantom User Manual

http://download.dji

- innovations.com/downloads/phantom/en/PHANTOM_Advanced_Manual_en.pdfPETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 76



### Exhibit 7: DJI Phantom Quick Start Guide

http://download.dji

innovations.com/downloads/phantom/en/PHANTOM_Quick_Start_Manual_v1.7_en.pd



### Exhibit 8: DJI Phantom Features

http://www.dji.com/product/phantom/feature



### Ex hibit 9: DJI Phantom Specifications

http://www.dji.com/product/phantom/spec



### Exhibit 10: DJI Phantom Flight Controller User Manual

http://download.dji

- innovations.com/downloads/nazam

- v2/en/NAZA

M_Quick_Start_Guide_v1.26_en.pdf


### Exhibit 11: DJI Phantom Lithium Polymer Battery Guide

http://download.dji

- innovations.com/downloads/phantom/Battery_and_Charger_Instruction.pdf



### Exhibit 12: DJI Phantom Pilot Training Guide

http://download.dji

- innovations.com/downloads/phantom

- 2

- vision/en/Phantom_2_Vision_Pilot_Training_Guide_en.pdf



### Exhibit 13: DJI Phantom 2

http://www .dji.com/product/phantom

- 2PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 77



### Exhibit 14: DJI Phantom 2 User Manual

http://download.dji

innovations.com/downloads/phantom_2/en/PHANTOM2_User_Manual_ v1.4_en.pdf



### Exhibit 15: DJI Phantom 2 Quick Start Guide

http://download.dji

innovations.com/downloads/phantom_2/en/PHANTOM2_Quick_Start_Guide_en. pdf



### Exhibit 16: DJI Phantom 2 Features

http://www.dji.com/product/phantom

- 2/feature



### Exhibit 17: DJI Phantom 2 Specifications

http://w ww.dji.com/product/phantom

- 2/spec



### Exhibit 18: DJI Phantom 2 Flight Controller User Manual

http://download.dji

- innovations.com/downloads/nazam

- v2/en/NAZA

M_Quick_Start_Guide_v1.26_en.pdf



### Exhibit 19: DJI Phantom 2 Smart Battery Safety Manual

http://download.dji

innovati ons.com/downloads/phantom_2_vision_plus/Smart_Flight_Battery_Safety_Guidelines.pdf



### Exhibit 20: DJI Phantom 2 Pilot Training GuidePETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 78

http://download.dji

- innovations.com/downloads/phantom

- 2

- vision/en/Phantom_2_Vision_Pilot_Training_Guide_en.pdf



### Exhibit 21: DJI Phantom 2 Vision

http://www.dji.com/product/phantom

- 2

- vision



### Exhibit 22: DJI Phantom 2 Vision User Manual

http://download.dji

- innovations.com/downloads/phantom

- 2

- vision/en/Phantom_2_Vision_User_ Manual_v1.8_en.pdf



### Exhibit 23: DJI Phantom 2 Vision Quick Start Guide

http://download.dji

- innovations.com/downloads/phantom

- 2

- vision/en/ Phantom_2_Vision_Quick_Start_en.pdf



### Exhibit 24: DJI Phantom 2 Vision Features

http://www.dji.com/product/phantom

- 2

- vision/feature



### Exhibit 25: DJI Phantom 2 Vision Specifications

http://www.dji.com/product/phantom

- 2

- vision/spec



### Exhibit 26: DJI Phantom 2 Vision Flight Controller User Manual

http://download.dji

- innovations.com/downloads/nazam

- v2/en/NAZA

M_Quick_Start_Guide_v1.26_en.pdf



### Exhibit 27: DJI Phantom 2 Vision Smart Battery Manual

http://download.dji

innovations.com/downloads/phantom_2_vision_plus/Smart_Flight_Battery_Safety_Guidelines.pdfPETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 79



### Exhibit 28: DJI Phantom 2 Vision Pilot Training Guide

http://download.dji

- innovations.com/downloads/phantom

- 2

- vision/en/Phantom_2_Vision_Pilot_Training_Guide_en.pdf



### Exhibit 29: DJI Phantom 2 Vision +

http://www.dji.com/product/phantom

- 2

- vision

- plus



### Exhibit 30: DJI Phantom 2 Vision + User Manual

http://download.dji

innovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Plus_User_Manual_v1.8_e n.pdf



### Exhibit 31: DJI Phantom 2 Vision + Quick Start Guide

http://download.dji

innovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Plus_Quick_Start_Guide_e n.pdf



### Exhibit 32: DJI Phantom 2 Vision + Features

http://www.dji.com/product/phantom

- 2

- vision

- plus/feature



### Exhibit 33: DJI Phantom 2 Vision + Specifications

http://www.dji.com/p roduct/phantom

- 2

- vision

- plus/spec



### Exhibit 34: DJI Phantom 2 Vision + Flight Controller User ManualPETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 80

http://download.dji

- innovations.com/downlo ads/nazam

- v2/en/NAZA

M_Quick_Start_Guide_v1.26_en.pdf



### Exhibit 35: DJI Phantom 2 Vision + Smart Battery Manual

http://download.d ji

innovations.com/downloads/phantom_2_vision_plus/Smart_Flight_Battery_Safety_Guidelines.pdf



### Exhibit 36: DJI Phantom 2 Vision + Pilot Training Guide

http://download.dji

innovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Plus_Pilot_Training_Guide _v1.1_en.pdf



### Exhibit 37: DJI Phantom 3 Standard

http://www.dji.com/product/phantom

- 3

- standard



### Exhibit 38: DJI Phantom 3 Standard User Manual

https://dl.djicdn.com/downloads/pha ntom_3_standard/en/Phantom_3_Standard_User_Manual_v1.4_e n_0112.pdf



### Exhibit 39: DJI Phantom 3 Standard Quick Start Guide

http://dl.djicd n.com/downloads/phantom_3_standard/en/En_Phantom_3_Standard_Quick_Start_Guid e_0419.pdf



### Exhibit 40: DJI Phantom 3 Standard Features

http://www.dji.com/product/phantom

- 3

- standardPETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 81



### Exhibit 41 : DJI Phantom 3 Standard Specifications

http://www.dji.com/product/phantom

- 3

- standard/info#specs



### Exhibit 42: DJI Phantom 3 Standard Flight Controller System

https://dl.djicdn.com/downloads/phantom_3_standard/en/Phantom_3_Standard_User_Manual_v1.4_e n_0112.pdf



### Exhibit 43: DJI Phantom 3 Standard Smart Battery Manual

http://dl.djicdn.com/downloads/phantom_3/en/Phantom_3_Intelligent_Flight_Battery_Safety_Guidelin es__en.pdf



### Exhibit 44: DJI Phantom 3 Standard Safety/Preflight Checklist and Guidelines Training

http://dl.djicdn.com/downloads/phantom_3/en/Phantom%203%20Safety%20Guideline s%20and%20Dis claimer.pdf



### Exhibit 45 : DJI Phantom 3 Advanced

http://www.dji.com/product/phantom

- 3

- adv



### Exhibit 46 : DJI Phantom 3 Advanced User Manual

http://download.dji

innovations.com/downloads/phantom_3/en/Phantom_3_Advanced_User_Manual_v1.2_en.pdf



### Exhibit 47 : DJI Phantom 3 Advanced Quick Start GuidePETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 82

http://download.dji

innovations.com/downloads/phantom_3/en/Phantom_3_Advanced_Quick_Start_Guide_en.pdf



### Exhibit 48 : DJI Phantom 3 Advanced Features

http://www.dji.com/product/phantom

- 3/feature



### Exhibit 49 : DJI Phantom 3 Advanced Specifications

http://www.dji.com/product/phantom

- 3/spec



### Exhibit 50 : DJI Phantom 3 Advanced Flight Controller System

http://www.dji.com/product/phantom

- 3/flight

- system



### Exhibit 51 : DJI Phantom 3 Advanced Smart Battery Manual

http://download.dji

innovations.com/downloads/phantom_3/en/Intelligent_Flight_Battery_Safety_Guidelines_en.pdf



### Exhibit 52 : DJI Phantom 3 Advanced Safety/P reflight Checklist and Guidelines Training

http://download.dji

- innovations.com/downloads/phantom_3/en/Safety_Guidelines_Disclaimer_en.pdf



### Exhib it 53 : DJI Phantom 3 Professional

http://www.dji.com/product/phantom

- 3



### Exhibit 54 : DJI Phantom 3 Professional User ManualPETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 83

http://download.dji

innovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.2_en.pdf



### Exhibit 55 : DJI Phantom 3 Professional Quick Start Guide

http://download.dji

innovations.com/downloads/phantom_3/en/Phantom_3_Professional_Quick_Start_Guide_en.pdf



### Exhibit 56 : DJI Phantom 3 Professional Features

http://www.dji.com/product/phantom

- 3/feature



### Exhibit 57 : DJI Phantom 3 Professional Specifications

http://www.dji.com/product/phantom

- 3/spec



### Exhibit 58 : D JI Phantom 3 Professional Flight Controller System

http://www.dji.com/product/phantom

- 3/flight

- system



### Exhibit 5 9 : DJI Phantom 3 Professional Smart Battery Manual

http://download.dji

innovations.com/downloads/phantom_3/en/Intelligent_Flight_Battery_Safety_Guidelines_en.pdf



### Exhibit 60 : DJI Phantom 3 Professional Sa fety/Preflight Checklist and Guidelines Training

http://download.dji

- innovations.com/downloads/phantom_3/en/Safety_Guidelines_Disclaimer_en.pdf



### Exhibit 61: DJI Phantom 4

http://www.dji.com/product/phantom

- 4PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 84



### Exhibit 62: DJI Phantom 4 User Manual

https://dl.djicdn.com/downloads/phantom_4/en/Phantom_4_User_Manual_en_v1.2_160328.pdf



### Exhibit 63: DJI Phantom 4 Quick Start Guide

https://dl.djicdn.com/downloads/phantom_4/en/Phantom_4_Quick_Start_Guide_v1.2_en_160317.pdf



### Exhibit 64: DJI Phantom 4 Features

http://www.dji.com/product/phantom

- 4



### Exhibit 65: DJI Phantom 4 Specifications

http://www.dji.com/product/phantom

- 4/info#specs



### Exhibit 66: DJI Phantom 4 Flight C ontroller System

https://dl.djicdn.com/downloads/phantom_4/en/Phantom_4_User_Manual_en_v1.2_160328.pdf



### Exhibit 67: DJI Phantom 4 Smart Battery Manual

https://dl.djicdn.com/downloads/phantom_4/en/Phantom_4_Intelligent_Flight_Battery_Safety_Guideli

nes_en.p df



### Exhibit 68: DJI Phantom 4 Safety/Preflight Checklist and Guidelines Training

https://dl.djicdn.com/downloads/phantom_4/en/Phantom_4_Disclaimer_and_Safety_Guidelines_v1.2_ en_160317.pdfPETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 85



### Exhibit 69 : DJI Inspire 1

http://www.dji.com/product /inspire

- 1



### Exhibit 70 : DJI Inspire 1 User Manual

http://download.dji

- innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.2_en.pdf



### Exhibit 71 : DJI Inspire 1 Quick Start Guide

http://download.dji

- innovations.com/downloads/inspire_1/en/Inspire_1_Quick_Start_Guide_en.pdf



### Exhibi t 72 : DJI Inspire 1 Features

http://www.dji.com/product/inspire

- 1/feature



### Exhibit 73 : DJI Inspire 1 Specifications

http://www.dji.com/ product/inspire

- 1/spec



### Exhibit 74 : DJI Inspire 1 Flight Controller System

http://www.dji.com/product/inspire

- 1/flight

- control



### Exhibit 75 : DJI Inspire 1 Smart Battery Manual

http://download.dji

innovations.com/downloads/inspire_1/en/Intelligent_Flight_Battery_Safety_Guidelines_en.pdf



### Exhibit 76 : DJI Matrice 10 0PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 86

http://dev.dji.com/en/products/flying

- platforms/matrice

- 100



### Exhibit 77 : DJI Matrice 100 User Manual

http://download.dji

- innovations.com/downloads/dev/Matrice/en/M100_User_Manual_v1.0_en.pdf



### Exhibit 78 : DJI Matrice 100 Features

http://dev .dji.com/en/products/flying

- platforms/matrice

- 100/features



### Exhibit 79 : DJI Matrice 100 Specifications

http://dev.dji.com/en/products/flying

- platforms/matrice

- 100/specs



### Exhibit 80 : DJI Matrice 100 Smart Battery Manual

http://download.dji

innovations.com/downloads/dev/Matrice/en/Intelligent_Fligh t_Battery_Safety_Guidelines_en.pdf



### Exhibit 81 : Aircraft List (Previously Approved Pursuant to Section 333 Exemption Process)

https://www.regulations.gov/#!documentDeta il;D=FAA

- 2007

- 3330

- 0007



## References

1.) 

### NTSB. Michael P. Huerta, Administrator, Federal Aviation Administration v. Raphael

Pirker . Washington, DC: National Transportation Safety Board, 17 Nov. 2014.
PDF. Aircraft Definition.

2.) 

### Administration, Federal Aviatio n. "FAA Streamlines UAS COAs for Section 333." FAA.gov

.

Federal Aviation Administration, 24 Mar. 2015. Web. 5 Nov. 2015.

3.) 

### Administration, Federal Aviation. "Section 333 Petition Guidance & Checklist." (n.d.): n.PETITIONER

– Dronefly, Inc. DOCUMENT PREPARER

– DMZ Marketing, LLC. 87 

### pag. FAA.gov . Federal Aviation Administratio n. Web. Conditions for a successful Exemption.

4.) 

### Watts, Adam C., Vincent G. Ambrosia, and Everett A. Hinkley. Unmanned Aircraft

Systems in Remote Sensing and Scientific Research: Classification and Consideration of Use . Basel, Switzerland:

w ww.mdpi.com/jour nal/remotesensing, 8 June 2012. PDF. "D's" of Unmanned
Aircraft Use.

5.) 

### SKYbrary. "Unmanned Aircraft Systems."

- SKYbrary Aviation Safety. N.p., n.d. Web.

20 July 2015.

6.) 

### Administration, Federal Aviation. "Public Guidance for Petitions for Exemption under

Sec tion 333." FAA.gov . Federal Av iation Administration, n.d. Web.

7.) 

### "FAA Summary Grants Speed UAS Exemptions." FAA Summary Grants Speed UAS

Exemptions. Federal Aviation Administration, n.d. Web. 20 July 2015. Permitting Recreational and Sport Pilot Certificate s.

8.) 

### FAR Part 91

- Basic VFR Weather Minimums, Code of Federal Regulations § 91.155

(2004). Print.

9.) 

### Administration, Transportation Security. "Vetting of Airmen Certificates and General

Aviation Airport Access and Security Procedures." Department of Homelan d Security . Office of Inspector General, 7 July 2011. Web. 5 Nov. 2015.

10.) 

### MacPherson, Rebecca B. "U.S. DOT / FAA

- Office of the Chief Counsel." Letter to Mr.

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## E xemption References

Exemption # 11467

Exemption # 11905

Exemption # 11797

Exemption # 12031

Exemption # 11865

Exemption # 11364

Exemption # 11587

Exemption # 11857

E xemption # 11293

Exemption # 11814

Exemption # 11540

Exemption # 11345