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

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: James Dempsey Pennington Private Pilot Certificate Number 3342350 FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS §§61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF DJI PHANTOM 3 PROFESSIONAL/YUNEEC Q500 TYPHOON 4K/DJI INSPIRE 1 UNMANNED AIRCRAFT SYSTEMS PURSUANT TO §333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on November 28th 2015 James Dempsey Pennington 128 Harvest Ridge Acworth, GA 30102 404-907-3728TABLE OF CONTENTS 

### GLOSSARY OF ABBREVIATIONS iii

........................................................................ SUMMARY 1

............................................................................................................. INTRODUCTION AND INTERESTS OF THE PETITIONER 1

.................................. BACKGROUND 1

...................................................................................................... BASIS FOR PETITION 1

........................................................................................... A. Name And Address Of The Petitioner 3

.................................................................... B. The Specific Sections of 14 C.F.R. from which the Petitioner Seeks Exemption and Rationale 3

......................................................................................................... C. The Reasons why Granting the Petitioner’s Request would be in the Public Interest; That is, How it Would Benefit the Public as a Whole. 7

.............................. D. The Reasons Why Granting the Exemption would not Adversely Affect Safety, or How The Exemption Would Provide A Level of Safety at Least Equal to that Provided by the Rule from which the Petitioner Seeks Exemption. 8

....................... E. A Summary That Can Be Published In The Federal Register stating: The Rules From Which The Petitioner Seeks Exemption. 18

..................................................... F. Any Additional Information, Views, or Arguments Available to Support the Petitioner’s Request. 18

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

### CONCLUSION 18

...................................................................................................... APPENDICES 20

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

ii

### GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level AOI Area of Interest ATC Air Traffic Control ATO Air Traffic Organization AV Aerial Vehicle P3P DJI Phantom 3 Professional CFR Code of Federal Regulations COA Certificate Of Authorization FAA Federal Aviation Administration FAR Federal Aviation Regulation GCS Ground Control Station GPS Global Positioning System LOL Loss Of Link NAS National Airspace System NOTAM Notice To Airman PIC Pilot In Command Q500 Yuneec Q500 Typhoon 4K Section 333 FAA Modernization and Reform Act of 2012 (FMRA) §333 SO Safety Observer SOP Standard Operating Procedures sUAS Small Unmanned Aircraft System (weighing less than 50 pounds) UA Unmanned Aircraft UAS Unmanned Aircraft System VFR Visual Flight Rules VLOS Visual Line Of Sight VMC Visual Meteorological Conditions VTOL Vertical Take-Off and Landing

iii

## SUMMARY James Dempsey Pennington, herein also referred to as “petitioner,” seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a) (2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to § 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit the petitioner to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography of real estate and events, inspection, and landscape over certain areas of the United States. 

## INTRODUCTION AND INTERESTS OF THE PETITIONER The petitioner provides his clients with expertise and knowledge in advanced photography/video solutions using aviation/aeronautical applications to increase efficiency, productivity, marketability and effectiveness. The petitioner he has over 9 years and 500 hours in aviation manned-PIC experience in single engine aircraft. The petitioner holds an FAA Private Pilot fixed-wing aircraft certificate (number: 3342350). The objective of the petitioner's aerial video and photography operations is to provide high quality imaging for a variety of commercial, public, and residential uses, specifically targeting:

• Construction sites (predevelopment, development and post development),

• Appraisals,

• Real estate marketing ,

• Real estate land and structural inspections, and

• Event videography and photography. 

## BACKGROUND The petitioner seeks an exemption to operate P3P, DJI Inspire and Eunice Q500 systems for compensation or hire within the NAS. The P3P, DJI Inspire and Q500 are vertical take off and landing (VTOL) unmanned aircraft (UA) with a Ground Control Station (GCS) utilizing a 5.8GHz remote control system. All three platforms have four main rotors and utilize lithium polymer (LiPo) batteries to power the electric motors. The P3P, DJI Inspire and Q500 operated by The petitioner will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking. Technical specifications for the each aircraft is provided in their respective appendix at the end of this petition. 

## BASIS FOR PETITION Petitioner, James Dempsey Pennington, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), § 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate the P3P, DJI Inspire and Q500 UASs in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a)

Page of 1 28& (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, The petitioner's operation of P3P, DJI Inspire and Q500 UASs meet the conditions of FMRA § 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingly, the petitioner requests relief from §§91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate. The petitioner submits that the requested relief is proper since an equivalent level of safety will be ensured. The petitioner will use experienced personnel and/or technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the manufacturer’s operating documents. Furthermore, The petitioner will document and maintain all maintenance records for the aforementioned UASs. Relief from certain requirements of § 61.113(a) and (b), entitled Private Pilot Privileges and Limitations: Pilot in command, is requested by the petitioner to the extent necessary to allow a Pilot in Command (PIC) holding a sport pilot or higher level certificate, as well as an airman medical certificate or state-issued driver’s license, to operate the P3P, DJI Inspire and/or Q500 UASs in a manner consistent with this exemption

. The petitioner seeks relief from § 91.7(a), entitled Civil Aircraft Airworthiness, because the petitioned UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As a result, the petitioner submits that he will ensure that the P3P, DJI Inspire and Q500 UASs are in an airworthy condition, prior to every flight, by determining that the UASs are in compliance with the operating documents (i.e., manufacturer’s owner’s and instruction manuals), and that the aircraft are in a condition for safe flight. The petitioner also seeks an exemption from the requirements of § 91.121, entitled Altimeter Settings, as the P3P, DJI Inspire and Q500 UASs will not have a typical barometric altimeter onboard. However, altitude information of the P3P, DJI Inspire and Q500 UASs will be provided to the PIC via Global Positioning System (GPS) equipment and radio communication telemetry data link, which downlinks from the UAS to the GCS for active monitoring of the flight path. This altitude information, combined with The petitioner's operation of the P3P, DJI Inspire and Q500 UASs within visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to § 91.121. Additionally, The petitioner seeks an exemption from the requirements of § 91.151(b), entitled Fuel requirements for flight in VFR conditions. The petitioner submits that safety will not be affected by operation of the P3P, DJI Inspire and Q500 UASs during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration of approximately 2 0 minutes for the intended photo shoot and, assuming normal cruising speed, to fly after that for at least 2.5 minutes for recovery and landing. In accordance with 14 C.F.R. § 11.81, The petitioner provides the following information in support of its petition for exemption:

Page of 2 28A. Name And Address Of The Petitioner The name and address of the Petitioner and point of contact is: James Dempsey Pennington 128 Harvest Ridge Acworth, GA 30102 404-907-3728 Email: jim.pennington@me.com B. The Specific Sections of 14 C.F.R. from which the Petitioner Seeks Exemption and Rationale 1. The Petitioner Seeks Exemption From The Requirements of §61.113(a) and (b)

. §61.113, entitled “Private Pilot Privileges and Limitations: Pilot in Command,” subsections (a) and (b) prescribe the following, in relevant part: (a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PIC of an aircraft. (b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment i f: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. Rationale: Relief from § 61.113(a) and (b) is requested to the extent necessary to allow operations of a PIC holding a sport pilot or higher level certificate, as well as a current and valid airman medical certificate/state-issued driver’s license. This zrelief is requested since the limitations set forth in §61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. As set forth more fully below, the petitioner submits that an equivalent level of safety will be maintained because a PIC will not be permitted to operate the P3P, DJI Inspire and Q500 UASs unless that PIC has met certain flight-hour and currency requirements, demonstrating that the PIC is able to safely operate either the P3P, DJI Inspire 1 or Q500 UAS in a manner consistent with the operational specifications as described in this exemption, including evasive and emergency maneuvers, and maintaining appropriate distances from people, vessels, vehicles and structures. Further, The petitioner submits that all flights of the P3P, DJI Inspire and Q500 sUASs, conducted by the PIC pursuant to the grant of this petition, will not be carrying passengers or property/cargo for compensation or hire. 2. The Petitioner Seeks Exemption From The Requirements of §91.7(a)

. §91.7, entitled Civil aircraft airworthiness, subsection (a), states the following:
Page of 3 28(a) No person may operate a civil aircraft unless it is in an airworthy condition. Rationale: Relief from §91.7(a) entitled Civil Aircraft Airworthiness, is requested to the extent required to allow the petitioner to determine that the P3P, DJI Inspire and Q500 sUASs are in airworthy condition prior to every flight by ensuring that the sUAS is in compliance with the operating documents (i.e. the manufacturer’s user’s manual)

. The petitioner seeks the requested relief because the P3P, DJI Inspire and Q500 sUASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, The petitioner will ensure that the P3P, DJI Inspire and Q500 sUASs are in airworthy condition based upon its compliance with the operating documents (i.e., Manufacturer’s Instruction Manuals) prior to every flight, and further, determine that the aircraft are in condition for safe flight

. 3. The Petitioner Seeks Exemption From The Requirements of §91.121

. §91.121, entitled Altimeter S ettings, subsection (a), states the following, in part: (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

— (1) Below 18,000 feet MSL, to

— (i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure. Rationale: Relief from § 91.121, entitled Altimeter Settings, may be required to allow flight operations of the P3P, DJI Inspire and Q500 sUASs, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any altitude information concerning sUAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), The petitioner seeks the requested relief because the P3P, DJI Inspire and Q500 sUASs altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight. Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply with the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level of safety will be maintained since the P3P, DJI Inspire and Q500 sUASs are equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the PIC with altitude (AGL) information of the UA on the heads-up display of the GCS.
Page of 4 284. The Petitioner Seeks Exemption From The Requirements of §91.151(b)

. §91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states the following: (a) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes. Rationale: Relief from §91.151(b) entitled “Fuel Requirements for Flight in VFR Conditions,” is requested to the extent required to allow flights of the battery powered P3P, DJI Inspire and Q500 sUASs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 15 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 2.5 minutes. The petitioner seeks the requested relief because without an exemption from § 91.151(b), the flight time duration of the battery powered P3P, DJI Inspire and Q500 sUASs will severely constrain the practicality of any aerial video or still photo flight operations that the petitioner proposes to conduct pursuant to this petition. Significantly, as set forth below, the technical specifications of the P3P, DJI Inspire and Q500 sUASs, the operating documents and the petitioner's proposed operating limitations, ensure that the petitioner will safely operate the battery powered sUASs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total duration of 15 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 2.5 minutes. 5. The Petitioner Seeks Exemption From The Requirement of §91.405(a)

. § 91.405, entitled Maintenance required, subsection (a), states the following: 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[.] 6. The Petitioner Seeks Exemption From The Requirements of §91.407(a)(1) § 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration, subsection (a)(1), states the following: (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

— (1) It has been approved for return to service by a person authorized under § 43.7 of this chapter. 7. The petitioner Seeks Exemption From The Requirements of §91.409(a)(1) and 91.409(a)(2)

. Page of 5 28§91.409, entitled Inspections, subsection (a), states the following: (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months , it has had - (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by § 43.7 of this chapter or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. 8. The petitioner Seeks Exemption From The Requirements of §§91.417(a) and 91.417(b)

. §91.417, entitled Maintenance records, subsections (a) and (b), state the following: (a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preventive maintenance, and alteration and records of the 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; (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 aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or Safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms prescribed by §43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold.
Page of 6 28(3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service. Rationale: Since §§91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, the petitioner requests relief from these sections because the P3P, DJI Inspire and Q500 sUASs do not require airworthiness certificates. As set forth more fully below, the sUASs meet the conditions of FMRA § 333 for operation without an airworthiness certificate. Accordingly, the petitioner will use trained technicians to perform maintenance, alterations, or preventive maintenance on the sUASs using the methods, techniques, and practices prescribed in the sUAS operating documents (i.e., the Aerial Operations Manual and Manufacturer’s Instruction Manual). Furthermore, the petitioner will document and maintain all maintenance records for the s UASs. C. The Reasons why Granting the Petitioner’s Request would be in the Public Interest; That is, How it Would Benefit the Public as a Whole. Granting the present petition will further the public interest by allowing the petitioner to safely, efficiently, and economically perform aerial video/photography of construction sites (predevelopment, development and post development), appraisals, real estate marketing, real estate land and structural inspections, and event videography and photography over certain areas of the United States. Additionally, use of the sUASs will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of the petitioner's proposed operation of the sUASs will be realized without implicating any privacy issues.
1. The Public Will Benefit From Decreased Congestion Of The NAS

. The sUASs are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of UASs would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground. Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The petitioned UASs do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations.
2. The Public Will Benefit From The Safety And Efficiency of the Petitioned UASs

. Conducting aerial acquisitions with a UAS, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, the P3P, DJI Inspire and Q500 UASs produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, four or six cylinder internal combustion
Page of 7 28engine aircraft that are typically utilized for aerial video and photography (while burn approximately 20-30 gallons per hour of leaded aviation fuel). The UASs, while reducing the carbon footprint of aerial image acquisitions, also eliminates noise pollution, as the UA are propelled by battery powered electric motors, rather than an internal combustion engine. By using the petitioned UASs to perform aerial image acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, UASs (weighing approximately under 5 pounds respectively, at their maximum gross weights with (and with no fuel on board) has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar operation s. 3. Performing Aerial Video and Photography Operations With The P3P, DJI Inspire and Q500 UASs Will Benefit The Economy. In addition to being safe and efficient, the petitioned UASs are also an economical alternative to using manned aircraft to conduct similar aerial imaging operations. As such, operation of the sUASs will allow United States-based companies, like the petitioner’s, to remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery powered s UASs is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft. By operating the petitioned sUASs, companies, such as the petitioner’s, can remain competitive and profitable and, therefore, provide greater job stability to employees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through commercial use of the UASs, provides a stable workforce that increases consumer spending, improves local, state, and federal tax revenues and allows companies to invest in research and development in order to remain competitive both in the United States and abroad.
4. There Are No Privacy Issues

. Similar to the manned aerial acquisition flight operations that have been conducted for decades, the petitioner's proposed operation will not implicate any privacy issues. Specifically, the UASs will be operated only in compliance with operating documents (i.e. Aerial Operations Manual and Instruction Manuals) which requires property owner involvement, as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F. R. § 91.119. D. The Reasons Why Granting the Exemption would not Adversely Affect Safety, or How The Exemption Would Provide A Level of Safety at Least Equal to that Provided by the Rule from which the Petitioner Seeks Exemption.

Page of 8 281. Reasons why the P3P, DJI Inspire and Q500 sUASs Meet the Conditions of the FAA Modernization and Reform Act of 2012 (FMRA) §333

. In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, The petitioner's operation of the P3P, DJI Inspire and Q500 sUASs meet the conditions of FMRA § 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. §333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA § 333 states the following, in part: (a) In General.--Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act. (b) Assessment of Unmanned Aircraft Systems.--In making the determination under subsection (a), the Secretary shall determine, at a minimum

— (1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security; and (2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1). (c) Requirements for Safe Operation.--If the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system. In seeking this exemption, the petitioner submits that the P3P, DJI Inspire and Q500 sUASs can operate safely in the NAS pursuant to FMRA § 333, as demonstrated by: (a) the characteristics of the s UASs; (b) the pilot certification requirement; and (c) the specific operating limitations.
A. The Specifications Of the P3P, DJI Inspire and Q500 UAS’s Demonstrate Its Safe Characteristics. The P3P, DJI Inspire and Q500 sUASs do not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability. (i) Technical Specifications of the P3P, DJI Inspire and Q500 UASs. — The technical specifications of the P3P, DJI Inspire and Q500 sUASs are set forth by the sUAS specifications and data sheet, attached hereto as Appendix A, B and C.

Page of 9 28(ii) The P3P, DJI Inspire and Q500 sUAS’s Autonomous Flight And Navigation Modes Enable the sUASs To Remain Within A Defined Operational Area —The UASs may be operated in both manual and fully autonomous flight modes. (iii) The P3P, DJI Inspire and Q500 sUASs Are Designed For Automatic Return To Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation. — When the Control Link is lost, the P3P, DJI Inspire and Q500 will remain stationary in flight, for 3 seconds or more. If, after 3 seconds, the sUASs do not reacquire control link data from the GCS, the UAS will assume that the Control Link is lost and the UAS will return to the home position (i.e., “failsafe” mode) via GPS, and will descend to the takeoff position and shutdown.
B. Flight Operations of the P3P, DJI Inspire and Q500 sUASs are Limited to the Line of Sight (LOS) of a Certificated Pilot in Command (PIC) With A Safety Observer (SO). — The petitioner will only utilize certificated pilots who possess a current and valid airman medical certificate/state-issued driver’s license to act as a pilot in command (PIC) of the P3P, DJI Inspire and Q500 sUASs. Additionally, a safety observer (SO) will assist all pilots during flight time. C. Flights of the P3P, DJI Inspire and Q500 sUASs will be Conducted Pursuant to Specific Operating Limitations. — In seeking this exemption, the petitioner proposes to commercially operate the P3P, DJI Inspire and Q500 sUASs for the special purpose of conducting aerial video and photography over certain areas of United States, pursuant to the following specific operating limitations: 1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UAS's weighing less than 55 pounds maximum gross weight: the P3P, DJI Inspire and Q500 Unmanned Aircraft Systems. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant.
2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photography.
3. The UA may not be flown at an indicated groundspeed exceeding 43 knots (50 mph).
4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved by ATC. All altitudes reported to ATC must be in feet AGL.
5. The UAs must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other thancorrective lenses, as specified on the PIC’s FAA-issued airman medical certificate/stateissued driver’s license.
6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted.
7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The SO and
Page of 10 28PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the SO can perform the functions prescribed in the operating documents.
8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is not permitted to operate the camera or other instruments.
9. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations contained in the grant of exemption, and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if questions arise regarding updates or revisions to the operating documents.
10. Prior to each flight, the PIC must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the sUAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records.
11. Any UAS that has undergone maintenance or alterations that affect the sUAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraft records.
12. The pre-flight inspection must account for all potential discrepancies, e.g.inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents.
13. The operator must follow the sUAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements.
14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature of the person returning the sUAS to service.

Page of 11 2815. Each sUAS's operated under this exemption must comply with all manufacturer Safety Bulletins.
16. The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections.
17. The PIC must possess at least a sport pilot certificate and at least a current third-class medical certificate or state-issued driver’s license.
18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the sUAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. §61.51(b). Flights for the purposes of training the operator’s PIC's are permitted under the terms of the exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience-building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119.
19. sUAS operations may not be conducted during night, as defined in 14 C.F.R. §91.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized.
20. The UA may not operate within 5 nautical miles of an airport reference point as denoted on a current FAA published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request.
21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.
22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in accordance with the operating documents.
23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents.
24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UAS with 25% battery power remaining.
25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more
Page of 12 28than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requirements.
26. All aircraft operated in accordance with the exemption must be identified by serialnumber, registered in accordance with 14 C.F.R. part 47, and have identification (NNumber) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable.
27. Before conducting operations, the radio frequency spectrum used for operation and control of the UAS must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.
28. The documents required under 14 C.F.R. §91.9 and §91.203 must be available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made available to the Administrator or any law enforcement official upon request.
29. The sUAS must remain clear and yield the right of way to all manned aviation operations and activities at all times.
30. The sUAS may not be operated by the PIC from any moving device or vehicle.
31. Flight operations must be conducted at least 500 feet from all non-participating persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect non- participating persons from the UAS and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or;
b. The aircraft is operated near vessels, vehicles or structures where the owner/ controller of such vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, and

c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a).
32. All operations shall be conducted over private or controlled-access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted.
33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to
Page of 13 28the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

.

2. Reasons why an Exemption from the Requirements of §61.113(a) and (b) would not Adversely Affect Safety

. The petitioner submits that the equivalent level of safety established by §61.113(a) and (b) will be maintained because no PIC will be allowed to operate the sUASs unless that PIC has demonstrated, by meeting ten (10) flight-hours, that the PIC is able to safely operate the P3P, DJI Inspire and Q500 sUASs in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering the petitioner's proposed area of operations, and the operating limitations set forth-above, and the airmanship skills necessary to safely operate the P3P, DJI Inspire and Q500 sUASs, the petitioner submits that the additional manned airmanship experience of a privately certificated pilot would supplement the airmanship skills necessary for the petitioner's specific proposed flight operations. The FAA has previously granted relief from §61.113(a) and (b) specific to sUAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). The petitioner will not allow any PIC to operate the P3P, DJI Inspire and Q500 sUASs unless that PIC has demonstrated, by meeting minimum flight-hour requirements of the sUASs training requirements, that the PIC is able to safely operate the sUASs in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. §61.51(b), twenty-five (25) hours of total time as a sUAS rotorcraft pilot (with a minimum of 5 hours of those hours as a sUAS pilot operating the same make and model of sUAS to be used for operations under the exemption). As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during the petitioner's proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows: “In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR §61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make
Page of 14 28and model of UAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi-rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in thepreceding 90 days (for currency purposes). The FAA finds that at a minimum, the flighthour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the petitioner’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience-building flights can also be conducted under the grant of exemption to accomplish the required flight time. During training, proficiency, and experience-building flights the PIC is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119.”

— Exemption No. 11138 at page 15. Accordingly, the petitioner will ensure safe operations by not allowing any PIC to operate the P3P, DJI Inspire and Q500 sUASs unless that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the sUASs in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.
3. Reasons why an Exemption from the Requirements of §91.7(a) would not Adversely Affect Safety. The equivalent level of safety established by §91.7(a) will be maintained because, prior to every flight, the petitioner will ensure that the P3P, DJI Inspire and Q500 sUASs are in an airworthy condition based upon the UAS’s compliance with its operating documents and as stated in the conditions and limitations herein. Additionally, the FAA has previously granted relief from § 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).
4. Reasons why an Exemption from the Requirements of §91.121 would not Adversely Affect Safety. The equivalent level of safety established by § 91.121 will be maintained because the altitude information of the P3P, DJI Inspire and Q500 sUASs will be provided to the PIC via GPS equipment and a radio communications telemetry data link (which downlinks from the UA to the GCS for active monitoring of the flight path and altitude). This altitude information, combined with the petitioner's operation of the P3P, DJI Inspire and Q500 sUASs within visual line of sight, at or below 400 feet AGL will ensure a level of safety equivalent to §91.121. The altitude information will be generated by GPS equipment installed on board the aircraft. Prior to each flight, a zero altitude initiation point is automatically established by the UAS's onboard equipment at ground level.

Page of 15 28The FAA has previously granted relief from § 91.121 specific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).
5. Reasons why an Exemption from the Requirements of §91.151(b) would not Adversely Affect Safety

. A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. §91.151(b) as a result of (1) the technical specifications of the P3P, DJI Inspire and Q500 sUASs; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, the petitioner will ensure that he will safely operate the battery powered the P3P, DJI Inspire and Q500 sUASs during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 15 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 2.5 minutes. Here, as in Exemption No. 11109, the technical specifications of the P3P, DJI Inspire and Q500 sUASs the limitations on the proposed flight operations and the location of the proposed operations, will ensure an equivalent level of safety established by 14 C.F.R. §91.151(b). Furthermore, safety will be ensured as the sUASs provide audible and visual warnings to the PIC at the GCS when the UAS experiences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery power. At the critically low battery level, the P3P, DJI Inspire and Q500 s UASs will descend and land automatically. Significantly, previous exemptions granted by the FAA concerning §91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in §91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from §91.151 specific to UAS in circumstances similar in all material respects to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).
6. Reasons why an Exemption from the Requirements of §§91.405(a), 91.407(a)(1), 91.409(a) (1) & (a)(2), And 91.417(a) &(b) would not Adversely Affect Safety. In seeking this exemption, the petitioner submits that the equivalent level of safety with regard to the regulatory maintenance and alteration requirements established by §§ 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because the petitioner will use trained technicians to perform maintenance, alterations, or preventive maintenance on the sUASs using the methods, techniques, and practices prescribed in the operating documents i.e., the Operations Manual and the P3P, DJI Inspire and Q500 Instruction Manuals. Furthermore, the petitioner will document and maintain all maintenance records for the P3P, DJI Inspire and Q500 sUASs. Since the P3P, DJI Inspire and Q500 sUASs will be inspected as prescribed by the operating documents, the petitioner will maintain the equivalent level of safety established by §§91.405(a), 91.409(a)(1), and 91.409(a)(2). The exemption sought will not adversely affect
Page of 16 28safety because the petitioner will use trained technicians to perform maintenance, alterations or preventive maintenance on the sUASs using the methods, techniques, and practices prescribed by the operating documents. Furthermore, the exemption sought would maintain an equivalent level of safety established by §§91.407, 91.417(a) and 91.417(b), because all maintenance of the P3P, DJI Inspire and Q500 sUASs will be performed by trained technicians. Maintenance will be documented and maintained utilizing a monthly maintenance log. Significantly, previous exemptions granted by the FAA concerning §91.405(a), 91.407(a) (1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the technical characteristics and operating limitations of the sUAS are considered. In consideration of the petitioner's proposed operating limitations, the operating documents, and the technical aspects of the P3P, DJI Inspire and Q500 sUASs, the petitioner submits that safety will not be adversely affected by granting exemption from 14 C.F.R. §§91.405(a), 91.407(a)(1) and (a)(2), 91.409(a) (2), and 91.417(a) and (b). The FAA has previously granted relief specific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).
7. The FAA May Prescribe Any Other Conditions For Safe Operation

. In accordance with §333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. §21.16 entitled Special Conditions, the petitioner requests that the FAA prescribe special conditions for the intended operation of the P3P, DJI Inspire and Q500 sUASs, which contain such safety standards that the administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAs for the limited purpose of conducting aerial video and photography over certain areas of the United States for compensation or hire. FMRA § 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security and further, provides the authority for such UAS to operate without airworthiness certification in accordance with any requirements that must be established for the safe operation of the UAS in the NAS. Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. §21.16, for operation of the P3P, DJI Inspire and Q500 sUASs, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features of the aircraft. §21.16, entitled “Special Conditions,” states the following: If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, it may prescribe special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety

Page of 17 28standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent to that established in the regulations. —See 14 C.F.R. §21.16. Therefore, in accordance with FMRA §333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for the petitioner's intended operation of the UAS’s, which contain such safety standards that the administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). E. A Summary That Can Be Published In The Federal Register stating: The Rules From Which The Petitioner Seeks Exemption

. The petitioner seeks exemption from the requirements of 14 C.F.R §§ 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). A Brief Description Of The Nature Of The Exemption The petitioner Seeks: This exemption will permit the petitioner to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States. F. Any Additional Information, Views, or Arguments Available to Support the Petitioner’s Request. This p etition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) §333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. As such, the petitioner request for exemption may be granted pursuant to the authority of FMRA §333 and 14 C.F.R. Part 11, as set forth above. FMRA §333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security and further, provides the authority for such UAS to operate without airworthiness certification. As discussed in detail above, the petitioner will operate the P3P, DJI Inspire and Q500 sUASs safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security. 

## CONCLUSION As set forth herein, the petitioner seeks an exemption pursuant to 14 C.F.R. §11.61 and §333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the P3P, DJI Inspire and Q500 sUASs commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography over certain areas of the United States. By granting this petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing the petitioner to safely, efficiently, and economically operate the P3P, DJI Inspire and Q500 sUASs commercially within the NAS.
Page of 18 28WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, §333, the petitioner respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R §§61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit the petitioner to operate the aforementioned sUASs commercially for the purpose of conducting aerial video and photography over certain areas of the United States.
Respectfully submitted, //S// James Dempsey Pennington Petitioner

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## APPENDICES

A — DJI Phantom 3 Professional User’s Manual B — DJI Inspire Professional User’s Manual C — Yuneec Q500 Typhoon 4K User’s Manual D — DJI Phantom 3 Professional Specifications/Performance E — DJI Inspire Professional Specifications/Performance F — Yuneec Q500 Typhoon 4K Specifications/Performance

Page of 20 28APPENDIX A DJI Phantom 3 Professional User’s Manual https://dl.djicdn.com/downloads/phantom_3/en/ Phantom_3_Professional_User_Manual__V1.6.pdf

Page of 21 28APPENDIX B DJI Inspire Professional User’s Manual https://dl.djicdn.com/downloads/inspire_1/en/Inspire%20_1_User_Manual__V1.8.pdf

Page of 22 28APPENDIX C Yuneec Q500 Typhoon 4K User’s Manual http://www.yuneec.com/download/manuals/q500_4k_user_manual.pdf

Page of 23 28APPENDIX D DJI Phantom 3 Professional Specifications/Performance AIRCRAFT Weight (including battery and propellers) — 1280 g Diagonal size (including propellers) — 590 mm Max Ascent Speed — 5 m/s Max Descent Speed — 3 m/s Hover Accuracy — Vertical: +/- 0.5m; H orizontal: +/- 1.5m Max Speed — 16 m/s (ATTI mode, no wind) Max Service Ceiling Above Sea Level — 120 m above takeoff point Operating Temperature — 0°C to 40°C GPS Mode — GPS/GLONASS GROUND CONTROL STATION Operating Frequency — 2.400 GHz-2.483 GHz Max Distance — Up to 5 km or 3.1 miles (unobstructed, free of interference) Video Output Port — USB Operating Temperature — 0°C- 40°C Battery — 6000 mAh LiPo 2S Receiver Sensitivity (1%PER) — -101 dBm ±2 dBm Transmitter Power (EIRP) — 20 dBm Working Voltage — 1.2 A @7.4 V

Page of 24 28APPENDIX E DJI Inspire Professional Specifications/Performance AIRCRAFT Model — T600 Weight (Battery Included) — 2935 g Hovering Accuracy (GPS mode) — Vertical: 0.5 m; Horizontal: 2.5 m Max Angular Velocity — Pitch: 300°/s; Yaw: 150°/s Max Tilt Angle — 35° Max Ascent Speed — 5 m/s Max Descent Speed — 4 m/s Max Speed — 22 m/s (ATTI mode, no wind) Max Service Ceiling Above Sea Level — 4500 m (Software altitude limit: 120 m above takeoff point) Max Wind Speed Resistance — 10 m/s Max Flight Time — Approximately 18 minutes Motor Model — DJI 3510H Propeller Model — DJI 1345T Indoor Hovering — Enabled by default Operating Temperature Range — -10° to 40° C Diagonal Distance — 559 to 581 mm Dimensions — 438x451x301 mm Power Spectral Density — 9.06mW/MHz GROUND CONTROL STATION Name — C1 Operating Frequency — 5.725~5.825 GHz; 2.400~2.483 GHz
Page of 25 28Maximum Transmitting Distance — Up to 5 km or 3.1 miles (unobstructed, free of interference)
EIRP — 10dBm@900m, 13dBm@5.8G, 20dBm@2.4G Video Output Port — USB, mini-HDMI Power Supply — Built-in battery Charging — DJI charger Dual User Capability — Host-and-Slave connection Output Power — 9 W Operating Temperature Range — -10° to 40° C Battery — 6000 mAh LiPo 2S

Page of 26 28APPENDIX F Yuneec Q500 Typhoon 4K Specifications/Performance AIRCRAFT Flight Time — up to 25 minutes Weight with Battery and Payload — 60.0 oz (1700g) Weight without Battery and Payload — 40.0 oz (1130g) Battery — 5400mAh 3S 11.1V LiPo (included) Charger — 3S 11.1V LiPo DC Balancing Smart Charger with AC Adapter (included) Transmitter — 10-channel 2.4GHz with 5.8GHz video downlink 3 Flight Modes — Smart (Follow Me and Watch Me), Angle and Home Maximum Flying Height — Default 122m (400ft) above Ground Level Maximum Rotation Rate — 65°/s Maximum Roll Angle — 35° Operating Temperature Range —

− 5°C to 80°C Radio Control Frequency Band — 2.4GHz Max. Descent Speed — 2m/s Max. Flight Speed — 17mph / 27 kph (Angle Mode) GROUND CONTROL STATION Type — ST10+ Operating System — AndroidTM Number of Channels — 10 Control Transmission Range (Optimum Conditions) — Up to 800m (2624.67 ft) Robust Radio Control Modulation — Yuneec Protocol Video Link Frequency Band — 5.8GHz Video Transmission Range (Optimum Conditions) — Up to 600m (1968.5 ft)
Page of 27 28Flight Systems Telemetry Data On Screen Display — Yes LED Backlit LCD Screen — Capacitive Multi-touch 5.5 ′′ Tactile (Vibrating) and Audible Feedback — Yes Built-in LiPo Battery Voltage / Capacity — 3.6V/5200mAh 18.72Wh Screen Resolution — 854 × 480px

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