UNITED ST AT ES OF AMERI CA DEP AR TMENTOF TRANSPOR TA TI ON FEDERAL

A VI AT IO N ADMINISTRA TI ON WA SHI NGT ON, DC

Regulatory

Docket No. _______________

IN THE MA

TTER OF THE PETITION FOR EXEMPTI ON OF:

Scott Richard Carr Licensed Private Pilot

FOR AN EXEMPTION SEEKING R ELIEF FROM THE REQUIREMENTS OF TI TLE 14 OF THE CODE OF FEDERAL

REGULA

TI ONS SECTI ONS 61.1 13(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) CONCERNI NG COMME RCI A L OPERA TI ON OF A DJ I INSPI RE 1 UNMANNED AI RCRAFTSYSTEMS PURSUANT TO SECTI ON 333 OF THE F AA MODERNIZA

TI ON AND REFORM ACTOF 2012 (PUBLIC LA W 11 2

- 95)

Submitted on September 3 , 2015

Scott Carr 957 Maine Av e Clovis, CA

93619 Scott.carr777@gmail.com (559)

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- 4128TA BLE OF CONTENTS Page

GLOSSAR

Y OF ABBREVIA

TI ONS.................................................................................................................3

SUMMAR

Y.

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

IN TRODUCTION AND INTERESTS OF PETITIONER......................................................4

BACKGROUND............................ .........................................................................................5

BASI S FOR PETITION........................................................................................................... 5

NAME AND ADDRESS OF PETITIONER................................................................6

THE SPECI FI C SECTIONS OF 14 C.F .R. FROM WHI CH SCOTTR CARR SEEKS EXEMPTI ON.........................

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

THE EXTENT O F REL IEF SCOTTR CARR SEEKS AND THE REASON SCOTTR CARR SEEKS THE RELIEF...

..................... 9

THE REASON S WHY

GRANTING SCOTTR CARR REQUEST WOUL D BE IN THE PUBLIC INTEREST

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

THE REASONS WHY

GRANTING TH E EXEMPTI ON WOULD NOT ADVERSEL

Y A FFECTSAFETY

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

CONCL USION................................................................................................................... ....19GLOSSAR Y OF ABBREVIA

TI ONS

AGL Above Ground Level AOI Area of Interest AT C Air T

raffic Control AT O Air T

raffic Organization AV Aerial V

ehicle CFR Code of Federal Regulations COA Certificate of Authorization FA A Federal Av iation Administration FA R Federal Av iation Regulation GCS Ground Control Station GPS Global Positioning Sy stem LO L Loss of Link NAS National Airspace S ys tem NOT AM Notice to Airman PI C Pilot I n Command Section 333 FA A Modernization and Reform Act of 2012 (FMRA) SO Safety

Observer SOP Standard Operating Procedures UA Unmanned Aircraft UAS Unmanned Aircraft Sy stem VFR Vi sual Flight Rules VLOS Vi sual L ine of Site VMC Vi sual Meteorological Conditions VTOL Ve rtical T

akeof f and Landing DJI UA

V manufacturer ESC Electronic speed control FPV First Person V iew LI

- PO Lithium Poly mer battery RCV Radi o Controlled vehicle**SUMMAR Y** 

Scott Richard Carr seeks exemption from the requirements of 14 C.F .R §§ 61.1 13(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 Sy stem pursuant to Section 333 of the F AA Modernization and Reform Act of 2012 (FMRA). Th is exemption will permit SCOTTR CARR to operate an Unmanned Aircraft Sy stem (UAS) for the commercial purpose of conducting ae ria l video and photography for real estate ph otograph y and landscape over certain areas of the United States.

**INTRODUCTION AND INTERESTS OF**  **T HE PETITIONER** 

My name is SCOTTR CARR. I have been a licensed ( private pilot) since 1996 with knowledge of all current F AA regulations . My

flight experience consists of PI C of both a Cessna 150 and Cessna 172. Along with general aviation experience, I am a 15 year experienced expert operator of multiple t ypes of RCV A ircraft including Multi rotor, Ducted Fan fixed Wi ng, Quadcopters and General fixed wing.

Th e objective of SCOTTCARR ’ aerial video and photograph y operations is to provide high qualit y imaging for a variety

of C ommercial & Residential properties including Retail, I ndustrial, Multi

Family , Hotel, Of

fice, Land and Single Family Residence properties for client marketing purposes. Scott R Carr will also provide knowledge of UAS and promote safe UAS operations.**BACKGROUND**

Unmanned Aircraft Sy stems: DJIPhantom 3, DJ I Inspire 1 UASs SCOTTR CARR seeks an exemption to operate DJI s ys tems for compensation or hire within the NAS. The DJ I Phantom 3 and DJII nspire 1 are vertical takeof f and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic ta blet or smart phone s ys tems. The DJI Phantom 3 has a maximum gross weight of approximately 2 pounds 14 ounces, while having a length of 16 inches width of 16 inches, height of 8 inches, and a maximum speed of approximately 29 knots. The DJ I Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 1 1.8 inches, and a maximum speed of approximately 42 knots. The DJ I Phantom 3 and DJII nspire 1UAs are equipped with four main rotors; driven by L ithium Poly

mer battery powered electric motors.

The DJ I Phantom 3 and DJII nspire 1 UAs that will be operated b y SCOTT R CARR 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 Markings.

**BASIS FOR PETITION**

Petitioner, SCOTTR CARR , pursuant to the provisions of the Federal Av iation Regulations (14 C.F .R. § 1 1.61) and the F

AA Modernization and R eform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Sy stems, hereby petitions the Administrator to commerciall y operate the DJIPhantom 3, DJ I Inspire 1 UASs in the National Airspace Sy stem (NAS), and for an exemption from th e requirements of 14 C.F .R §§ 61.1 13(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, SCOTTR CARR operation of DJ I Phantom 3 and DJII nspire 1 UASs meets the conditions of FMRA

Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F .R. Part 21, Subpart H.

Accordingly

, SCOTT R CARR requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that onl y appl y to aircraft with an airworthiness certificate.

SCOTTR CARR submits that the requested relief is proper since an equivalent level of safety wi ll be ensured. SCOTTR CARR will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techn iques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJIPhantom 3 and DJ I Inspire 1 Instruction Manual) . Furthermore, SCOTTR CARR will document and maintain all maintenance records for the DJ I Phantom 3 and DJII nspire 1 UASs.

Relief from certain requirements of Section 61.1 13(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested b y SCOTT R CARR to the extent necessary to allow a Pilot in Command (PI C) holding a private pi lot or higher level certificate, as well as an airman medical certificate, and who has demonstrated, b y meeting minimum flight

- hour and currency requirements, that the PI C is able to safely operate the DJ I Phantom 3 and DJ I Inspire 1 UASs in a manner cons istentwith this exemption, including evasive and emergency maneuvers and maintaining appropriate

distances from people, vessels, vehicles and structures.

SCOTTR CARR seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the DJIPhantom 3 and DJ I Inspire 1 UASs do not require an airworthiness certificate in accordance with 14 C.F .R. Part 21, S ubpart H. As such, SCOTTR CARR submits that he will ensure that the DJ I Phantom 3 and DJII nspire 1UASs are in an airworthy condition, prior to every

flight, by determining that the UASs are in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJIPhantom 3 and DJ I Inspire 1 Instruction Manual), and that the aircraft are in a condition for safe flight.

SCOTT R CARR also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings, as the DJ I Phantom 3 and DJII nspire 1 UAs will not have a t ypical barometric altimeter onboard. However, altitude information of the DJ I Phantom 3 and DJ I Inspire 1UAs will be provided to the PI C via Global Positioning Sy stem (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with SCOTTR CARR operation of the DJ I Phantom 3 and DJ I Inspire 1 UASs within visual line of sight, at or below 500 feet AGL, will ensure a level of safet y equivalent to Section 91.121.

Additionally

, SCOTTR CARR seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in V FR conditions. SCOTTR CARR submits that safety will not be affected b y operation of the DJ I Phantom 3 and DJII nspire 1 UAs during day light hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration of approximately 15.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

In accordance with 14 C .F .R. § 1 1.81, SCOTTR CARR provides the following information in support of its petition for exemption:

**A. Name and**  **Addr ess**  **of the**  **Petitioner**

**.** The name and address of the Petitioner and point of contact is: SCOTTR CARR 957 MAINE AV E CL OVI S , CA

93619 (559)

- 203

- 4128 Email: scott.carr777@gmail.com**B. The**  **Specific Sections of**  **14 C.F .R. f**  **ro m Which SCOTT R CARR**  **Seeks Exemption.**

**1. SCOTT R CARR**  **Seeks Exemption Fr om**  **The Requir ements Of Section 61.1**  **13(a) And (b).**  Section 61.1 13, 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 (PI C) of an aircraft that is carry ing pass engers or property for compensation or hire; nor may that person, for compensation or hire, act as PI C of an aircraft. b. A private pilot may

, for compensation or hire, act as PI C of an aircraft in connection with any business or employ

ment if

— i. The flight is onl y incidental to that business or employment; and ii. The aircraft does not carry passengers or property

for compensation or hire. **2. SCOTT R CARR**  **Seeks Exemption Fr om**  **The Requir ements Of Section 91.7(a).**  Section 91.7, entitled civil aircraft airworthiness, subsection (a), stat es the following: (a) No person may operate a civil aircraft unless it is in an airworthy condition. **3. SCOTT R CARR**  **Seeks Exemption Fr om**  **The Requir ements Of Section 91.121.**  Section 91.121, entitled Altimeter settings, sub section ( a), states the following, in part:

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

-- Below 18,000 feet MSL, to

— i. The current reported altimeter setting of a station along the route and within 100

n autical 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 appr opriate available station; 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. **4. SCOTT R CARR**  **Seeks Exemption Fr om**  **The Requir ements Of Section 91.151(b)** 

**.** Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states the following: (b ) No person may begin a flight in a r otor craft under VFR condi tions unless (considering wind and for ecast weather conditions) ther e is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly afte r that for at least 20 minutes. **5. SCOTT R CARR**  **Seeks Exemption Fr om**  **The Requir ement Of Section 91.405(a).**  Section 91.405, entitled Maintenance require d, subsection (a), s tates 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, ha ve discrepancies repaired as prescribed in part 43 of this chapter[.] **6. SCOTT R CARR**  **Seeks Exemption Fr om**  **The Requir ements**  **Of Section 91.407(a)**  Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration, subsecti on (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 b y a person authorized un der § 43.7 of this c hapter [.] **7. SCOTT R CARR**  **Seeks Exemption Fr om**  **The Requir ements Of Sections 91.409(a)(1)**  **And 91.409(a)(2).**  Section 91.409, entitled Inspections, subsection (a), states the following: (a) Except as provided in paragraph (c) of this section, no person may o perate 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 b y 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. SCOTT R CARR**  **Seeks Exemption Fr om**  **The Requir ements Of Sections 91.417(a)**  **And 91.417(b).**  Section 91.417, entitled Maintenance records, subsections (a ) and (b), state the following:

a. Except for work performed in accordance with §§ 91.41 1 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: 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 Administrat or) of the work performed; and ii. The date of complet ion of the work performed; and iii. The signature and certificate number of the person approving the aircraft for return to service. Records containing the following information:

1. The total time in service of the airframe, each engine, each propeller, and each rotor

. 2. The current status of life

- limited parts of each airframe, engine, propeller
, rotor, and appliance. 3. The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. 4. 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. 5. The current status of applicable airworthiness directives (AD) and safet y directives including, for each, the method of complianc e, the AD or safet y directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required. 6. Copies of the forms prescribed b y § 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: i. The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded b y other work or for 1 ye ar after the work is performed. ii. 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. iii. A list of defects fu rnished to a registered owner or operator under § 43.1 1 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.**C. The Ex tent Of Relief SCOTT R CARR**  **Seeks And**  **The Reason SCOTT R CARR Seeks** 

**The Relief. 1.**  **Ex tent Of Relief SCOTT R CARR**  **Seeks And**  **The Reason SCOTT R CARR Seeks Relief**  **Fr om**  **Section 61.1 13(a)**  **And (b).** Relief from Section 61.1 13(a) and (b) entitled Private pilot privileges and limitations: Pilot in command, is requested to the exte nt necessary to allow a PI C holding a private pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met certain flight

- hour and currenc y requirements, to conduct the proposed UAS flight operations for compensation or hire. This relief is requested since the limitations set forth in S ection 61.1 13(a) and (b) state that a private pilot may

, for compensation or hire, act as PI C of an aircraft in connection with an y business or employ

ment if: (1) The flight is only incidental to that business or employ ment; and (2) The aircraft does not carry passengers or prop erty for compensation or hire. As set forth mor e full y below, SCOTTR CARR submits that an equivalent level of safety will be maintained because no PI C will be allowed to operate the DJ I Phantom 3 UAS or DJ I Inspire 1 UAS unless that PI C has met certain flight

- hour and currency requir ements, demonstrating that the PI C is able to safely operate either the DJ I Phantom 3 or DJII nspire 1 UAS in a manner

co nsistent with the operations specifications a s described in this exemption, including evasive and emergency maneuvers, as well as maintain ing appropriate distances from people, vessels, vehicles and structures. Further, SCOTTR CARR submits that all fligh ts of the DJ I Phantom 3 and DJII nspire 1 UASs, conducted b y the PIC pursuant to the grant of this Petition: (1) will be incidental to SCOTTR CARR ' business; and (2) will not carry passengers or propert y for compensation or hire. **2. Ex**  **tent Of Relief SCOTT R CARR**  **Seeks And**  **The Reason SCOTT R CARR Seeks Relief**  **Fr om**  **Section 91.7(a).** Relief from Section 91.7(a) entitled Civil aircraft airw orthiness, is requested to the extent required to allow SCOTT R CARR to determine that the DJ I Phantom 3 and DJI Inspire 1 UAS s are in airworth y condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., SCOTTR CARR Aerial Operations Manual, Monthly Maintenance Lo g, and DJIPhantom 3 and DJ I In spire 1 Instruction Manual). SCOTT R CARR seeks the requested relief bec ause the DJ I Phantom 3 and DJ I Inspire 1 UASs do not require an airworthiness certificate in acco rdance with 14 C.F .R. Part 21, Subpart H. Therefore, SCOTT R CARR will ensure that the DJ I Phantom 3 and DJ I In spire 1 UA Ss are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJIPhantom 3 and DJ I Inspire 1 Instruction Manual) prior to every flight, and further
, determine that the airc raft are in condition fo r safe flight, as stated in the conditions and limitations below

. **3. Ex**  **tent Of Relief SCOTT R CARR Seeks**  **And The Reason SCOTT R CARR**  **Seeks Relief Fr**  **om Section 91.121.**  Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight ope rations of the DJ I Phantom 3 and DJII nspire 1 UASs, which utilize a barometric pressure

sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PI C at the ground contr ol station (GCS). Sinc e the F AA requires that any altitude information concerning UAS operations be reported to air traf fic control (A

TC) in feet above groun d level (AGL), SCOTTR CARR seek s the requested relief because the DJI Phantom 3 and DJII nspire 1 UA’s 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 statedbelow

. As more full y set forth herein, an equivalent level of safet y will be maintained since the

DJIPhantom 3 and DJ I Inspire 1 UAs are equipped with a barometric pressure sensor and GPS equipment, which auto matically ensures that a ground level pressure setting will be established prior to each flight, and provides the PI C with altitude information of the UA on the heads

- up display of the GCS. **4. Ex**  **tent Of Relief SCOTT R CARR Seeks**  **And The Reason SCOTT R CARR**  **Seeks Relief Fr**  **om Section 91.151(b).**  Relief from Section 91.151(b) entitled Fuel requirements fo r flight in VFR conditions, is requested to the extent required to allow flights of the battery powered DJ I Phantom 3 and DJI Inspire 1 UAs during daylight hou rs in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 15.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fl y after that for a t least 4.5 minutes. SCOTTR CARR seeks t he requested relief because without an exe mption from Section 91.151(b), the flight time duration of the battery

powered DJ I Phanto m 3 and DJII nspire 1 UAs will severel y constrain the practicality

of any aerial video or stil l photo flight operations that SCOTTR CARR proposes to conduct pursuant to this Petition. Significantly

, as set forth below, the technical specifications of the DJ I Phantom 3 and DJI Inspire 1 UASs, the DJ I Phantom 3 and DJII ns pire 1 ope rating documents, and SCOTTR CARR proposed oper ating limitations, ensure that SCOTTR CARR will safely operate the battery powered DJ I Phantom 3 and DJII nspire 1 UAs during day light hours in visual meteorological conditions (VMC), under visual flight ru les (VFR), with enough battery power to fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. **5. Ex**  **tent Of Relief SCOTT R CARR Seeks**  **And The Reason SCOTT R CARR**  **Seeks Relief Fr**  **om Sections 91.405(a), 9**  **1.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b).**  Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) onl y apply to aircraft with an air

worthiness certificate, SCOTTR CARR requests relief from these Sections because the DJIPhantom 3 and DJII nspire 1 UAS s do not require airworthiness certificates. As set forth more fully below, the DJI Phantom 3 and DJII nspire 1 UASs meet the conditions of FMRA

Section 333 for operation without an airworthine ss certificate. Accordin gl y, SCOTTR CARR will use trained techn icians to perform maintenance, alterations, or preventive maintenance on the UASs usin g the methods, techniques, and practices prescribed in the UAS ope rating documents (i.e., SCOTTR CARR Aerial Operations Manual, M onthly Maintenance Lo g, and D JIPhantom 3 and DJ I Inspire 1 Instruction Manual) . Furthermore, SCOTTR CARR will document and maintain all maintenance records for the DJ I Phantom 3 and DJ I Inspire 1 UASs.

**D. The Reason**  **s Why Granting SCOTT R CARR**  **Request Wo**  **uld Be In The Public Inter**  **est: That**  **Is, How It Wo**  **uld Benefit The Public As**  **A Whole.** 

Granting the present Petition will further the public intere st by allowing SCOTTR CARR too safely

, efficiently

, and economically

perform aerial video and photography of construction sites, real estate, and landscape over certain areas of the United States. Additionally

, use of the DJIPhantom 3 and DJ I Inspire 1 UASs will decrease congestion of the NAS, reduce pollution, crashes and accidents caused by pilot error a nd provide significant benefits to the economy . Notabl y, t he benefits of SCOTTR CARR ’ proposed operation of the DJ I Phantom 3 and DJII nspire 1 UASs will be realized without implicating any privacy issues.**1. The Public Will Benefit Fr**  **om Decr**  **eased Congestion Of**  **The NAS.**

The DJ I Phantom 3 and DJII nspire 1 UAs are battery powered and serve as a safe, ef ficient, and economical alternative to the manned aircraft traditionally utilized to obtai n aerial imagery

. By reducing the amount of manned aircraft needed to p erform aerial acquisitions, an exemption allowing the use of a DJ I Phantom 3 or DJII nspire 1 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safet y of life and propert y in the a ir and on the ground. Furthermore, b y reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The DJ I Phantom 3 and DJ I Inspire 1 UAs do not require an airport t o t akeof f or land. Likewise, a reduction of manned aircraft conducting aerial video and photog raphy missions would result in fewer aircraft that must be handled by air traf fic control during the ground, takeoff, departure, arrival, and landing phases of flig ht operations. **2. The Public Will Benefit Fr**  **om T**  **he Safety And Efficien**  **cy Of The DJI Phantom 3 and DJI**  **Inspir e 1 UASs.**  Conducting aerial acquisitions with the DJIPhantom 3 and DJ I Inspire 1 UASs, instead of manned aircraft, will greatly benefit the public by

drasticall y reducing the levels of air and noise pollution generated during traditional aerial video and still photograph y flight operations. By using battery

power and electric motors, the DJ I Phantom 3 and DJ I Inspire 1 UASs produce no air pollution, and is the most viable environmentally conscious alternati ve to the cabin class, six cy linder internal combustion engine aircraft that are ty pically utilized for aerial video and photography

, while burning approximately 20

- 30 gallons per hou r of leaded avi ation fuel. The DJIPhantom 3 and DJ I Inspire 1 UAs, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAs ar e propelled by battery powered electric motors, rather than an internal combustion engine. By us ing the DJ I Phantom 3 and DJ I Inspire 1 UASs to perform aerial acquisitions, the substantial risk to life and propert y in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduc ed or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJ I Phantom 3 and DJII nspire 1 UAs (weighing approximately 2 pounds 14 ounces and 6 pounds 7.5 ounces respectively

, at their maximum gross weights wi th lengths of 16 inches and 17.3 inches respectively

, widths of 16 inches and 17.7 inches respectively , and with no fuel on board), has less ph ys ical potential for collateral damage to life and propert y on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing approximately

6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacit y of 180 gallons). **3. Performing**  **Aerial Vi**  **deo and Photography Operations Wi**  **th The DJI Pha**  **n tom 3 and**  **DJI Inspir**  **e 1 UASs Will Benefit The Economy** 

**.** In addition to being safe and efficient, the DJ I Phanto m 3 and DJII nspire 1 UASs are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJ I Phantom 3 and DJII nspire 1 UASs will allow United States based companies, like BOESE PROPER TY MANGEMENT , to remain competitive and co ntribute to growth of the U.S. economy . Specifically

, with the rising cost of aviation fuel an d the Environment al Protection Agency (“EP A”) regulatory

actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology i n order to remain competitive. Operating the battery powered DJIPhantom 3 and DJ I In spire 1 UAS s is one such technology that not only allows companies greater operational flexibility co mpared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft.By

operating the DJ I Phantom 3 and DJII n spire 1 UASs, companies such as BOESE PROPER TY MANAGEMENT , can remain competitive and profitable, and therefore, provide greater job stability

to employ ees 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 DJ I Phantom 3 and DJII nspire 1 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. Ther**  **e Ar**  **e No Privacy Issues.** Similar to the manned aerial acquisition flight operation s that have been conducted for decades, SCOTTR CARR proposed operation of the D JIPhantom 3 and DJ I Inspire 1 UASs would not implicate any

privacy issues. Specifically

, the D JIPhantom 3 and DJII nspire 1 UASs will be operated onl y in compliance with operat ing documents (i.e., SCOTTR CARR Aerial Operations Manual, Monthly Maintenanc e Log, and DJIPhantom 3 and DJII nspire 1 Instruction Manual) which requires propert y owne r involvement as well as local law enforcement notification, and in accordance with the Federal Av iation Regulations, including the minimum altitude requirements of 14 C.F .R. § 91.1 19.

**E. The Reasons**  **Why Granting The Exemption W ould Not**  **Adversely Affect Safety**  **, Or How**  **The Exemption W** 

**ould Pr ovide**  **A Level Of Safety**  **At Least Equal To**  **T hat Pr**  **ovided By The Rule**  **Fr om**  **Which SCOTT R CARR Seeks Exemption.** 

**1. Reasons Why**  **The DJI Phantom 3 and DJI Inspir e 1 UAs Meet The Conditions Of The**  **FA A**  **Modernization and Reform Act of 2012 (FMRA) Section 333.**  In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, SCOTTR CARR ’ operation of the DJ I Phantom 3 and DJI Inspire 1 UASs meet the conditions of FMRA Sectio n 333, and will not require an airworthiness certificate in accordance with 14 C.F .R. Part 21, Subpart H. Secti on 333 provides authority for a UAS to op erate without airworthiness certificati on and sets forth requirements for considering whether a UAS will create a hazard to user s of the NAS or the public, or otherwise pose a threat to national security . Specificall y, FMRA

Section 333 states the following , in part:

**a.** In General.

-- Notwithstanding an y other requirement of this subtitle, and not later than 180 day s after the date of enactment of this Act, the Sec retary of T ransportation shall determine if certain unmanned aircraft sy stems may operate s afely

i n the national airspace sy stem before completion of the plan and rulemaking required by section 332 of this Act or the guidance required b y section 334 of this Act. **b.** Assessment of Unmanned Aircraft S ys tems

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

— **i.** Which ty

pes of unmanned aircraft s ys tems, 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

n ational airspace s ys tem or the public or pose a threat to national security ; and whether a certifi cate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States C ode, is required for the operation of unmanned aircraft s ys tems identified under paragraph (1).

**c.** Requirements for Safe Operation

. - - If the Secretary determines under this section that certain unmanned aircraft sy stems may operate safely

in the national airs pace s ys tem,the Secretary shall establish requirements for the safe operation of such aircraft s ys tems in the national airspace sy stem.
In seeking t his exemption, SCOTTR CARR submits that the DJIPhantom 3 and DJ I Inspire 1 UASs can operate safely in the NAS pu rsuant to FMRA Section 333, as demonstrated by : (a) the characteristics of the DJ I Phantom 3 and DJII nspire 1 UASs; (b) the pilot certification requirement; and (c) the s pecific operating limitations. i. **The Specifications Of The DJI Phantom 3 and**  **DJ I Inspir**  **e 1 UASs Demonstrate**  **Its Safe Characteristics.** The DJ I Phantom 3 and DJII nspire 1 UASs 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 operationa l capability

. ii. **Te chnical Specifications Of**  **The DJI Phantom 3 and DJI Inspir e 1 UASs.**  The DJ I Phantom 3 and DJII nspire 1 Specifications and Data Sheet, attached hereto as Appendix A and B, set the technical specifications of the DJ I Phantom 3 and DJ I Inspi re 1 UASs forth

. iii. **The DJI Phantom 3 and DJI Inspir e 1 UASs**  **Autonomous Flight And**  **Navigation Modes Enable The UASs T**  **o Remain Within A**  **Defined Operational**  **Ar ea.**  The DJ I Phantom 3 and DJII nspire 1 UASs may be ope rated in both manual and fully autonomous fli ght modes. A complete description of the flight and navigational modes of the DJ I Phantom 3 and DJ I In spire 1 UASs is provided at pages 25

- 35 of the DJ I Phantom 3 and pages 12

- 16 and 45

- 50 of the DJ I In spire 1 User Manuals, attached hereto as Exhibit C and D. iv. **The DJI Phantom 3 and DJI Inspir e 1 UAS**  **s Ar**  **e Designed For A**  **utomatic Return T**  **o Home Point Or**

**Hover In**  **The Event Of Loss Of**  **The Contr ol**  **Link Or Navigation.**  When the Control L ink is lost, the DJIPhantom 3 an d DJ I Inspire 1 UAs will remain stationary

, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phan tom 3 and DJII nspire 1 UAs do not reacquire control link data from the GCS, the UAs will assume that the Control L ink is lost and the UAs will return to the home position (i.e., failsafe mod e ) via GPS, and will descend to the takeof f position and shutdown. A complete description of the Failsafe Functions of the DJ I Phantom 3 UAS are set forth at pages 27 through 29 and for the DJ I In spire 1 at pages 13 through 15 of the DJ I Phantom 3 and DJI Inspire 1 User Manuals, attached hereto as Exhibit C and D.

v. **The DJI Phantom 3 and DJI Inspir e 1 GCS**  **And It’ s Operation.**  A complete description of the operation and specifica tions of the DJ I Phantom 3 and DJ I Inspire 1 GCS and flight control software is pr ovided at pages 32 through 43 of the DJ I Phantom 3 User Manual and pages 40 through 47 of the DJII nspire 1 User Manual. DJ I Phantom 3 and DJII nspire 1 User Manuals are attached hereto as Exhibits C and D. vi. **Flight Operations Of DJI Phantom 3 and DJI Inspir**  **e 1 UASs Are Limited**  **To The Line Of Sight Of**  **A Certificated Pilot in Co**  **mmand With A**  **Safety Observer** 

**.** SCOTTR CARR will only utilize certificated pilots who possess a current and valid airman medical certificate to act as a pilot in command (PI C ) of the DJI Phantom 3 and DJI Inspire 1 UASs. Additionally , a safet y observer will assist allpilots during flight time. vii. **Flights Of DJI Phantom 3 and DJI Inspir e 1 UAS**  **s Wi**  **ll Be Conducted Pursu**  **ant To**  **Specific Operating Limitations.** In seeking t his exemp tion, SCOTTR CARR proposes to commerciall y operate DJI Phantom 3 and DJ I Inspire 1 UASs for the special purpose of conducting aerial video and photography over certain areas of United States, pursuant to th e following specific operating limitations: 1. Opera tions authorized by this grant of exemption wi ll be limited to the following aircraft described in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: DJ I Phantom 3 and DJ I Inspire 1 Unmanned Aircraft Sy stems. Propos ed 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 UAs may

not be flown at an indicated airspeed exceeding 20 knots. 4. The UA

must be operated at an altitude of no more than 500 feet above ground level (AGL), as indicated b y the procedures specified in the operating documents unless a special request is made and approved b y AT C. A ll altitudes reported to AT C must be in feet AGL

. 5. The UAs must be operated within visual line of sight (VLOS) of the P IC at all times. This requires the PI C to be able to use human vision un aided by an y device other than corrective lenses, as specified on the PI C’ s FA A

- issued airman medical certificate. 6. The use of first person view (FPV) b y the PI C or safet y ob server (SO) is not permitted. 7. All operations must utilize a safet y observer (SO). The SO may be used to satisfy the VLOS requirement as long as th e PIC alway s maintains VLOS c apability

. The SO and PI C 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 he r designation for the duration of the flight. The PI C must ensu re that the SO can perform the functions prescribed in the operating documents. 8. The SO must not perform any other duties bey ond ass isting the PI C with seeing and avoiding other air traf fic and other ground based obstacles/obstru ctions 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

re quest. If a discrepancy

exists between the conditions and limitations contained in the grant o f exemption and the procedures outlined in the operating documents, the conditions and limitat ions contained in the grant of exemption take precedence and must be follo wed. Otherwise , the operator must follow the procedures as outlined in its operating documents. The ope rator may update or revise its operating documents. It is the operator ’s responsibility to tr ack such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if itpetitions for extension or amendment to the gran t of exemption. I f the operator determin es that any update or revision would af fect the basis upon which the F

AA granted the exe mption, then the operator must petition for amendment to its grant of exemption. The F AA’s U AS 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 ens ure that it is in a condition f

or safe flight. If the inspection reveals a condition that af fects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary

main tenance has been pe rformed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance an d alterations must be properly docu mented in the aircraft records. 11. Any UAS that has undergone main tenance or alterations that af fect the UA S operation or flight characteristics, e.g. replacement of a flight

cr itical component, must undergo a functional test flight. The PIC who conducts the functional tes t flight must make an entry in the a ircraft

recor ds. 12. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not alread y covered i n the relevant sections of the operating documents. 13. The operator must follow the UAS manufacturer ’s aircraft/component, maintenance, overhaul, replacement, inspectio n, and life limit requirements. 14. The operator must carry out its maintenance, i nspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspec tion, alterat ions, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description of work accompli shed, and the signature of the authorized perso n returning the UAS to service. 15. Each UASs operated under this exemption must comply with all manufacturer Safet y Bulletins. 16. The authorized person must make an entry in the air craft record of the corrective action taken against discrepancies discovered between inspections. 17. The PI C must possess at least a pr ivate pilot certificate and at least a current third

- class medical certificate. 18. The operator may

not permit any

PI C to operate unles s the PI C meets the operator ’s qualification criteria and demonstrates the ability to safel y operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and e mergency maneuvers and maintaining appropriate distances f rom persons, vessel s, 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 opera tor ’s PICs are permitted under the terms of the exemption. However, training operation s may only be conducted during dedicated training sessions. During training, proficiency , and ex perience

building flights, all persons not essential for flight operations are considered nonparticipants, and the PI C must o perate the UA withappropriate dist ance from nonparticipants in accord ance with 14 C.F .R. § 91.1 19. 19. UAS operations may

not be conducted during night, as defined in 14 C.F .R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required , a special request will be made at the F AA of fi ce 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 cu rrent F AA

- published aeronautical chart unless a letter of agreement with that airport’ s management is obtained, and the operation is conduc ted in accordance with a NOT AM as required b y the operator ’s COA. The letter of agreement with the airport managem ent 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 PI C. 22. If the UA

loses communications or loses its GPS s ignal, it must return to a pre

- determined location within the planned operating area and land or be recovered in accordance with the operating documents. 23. The PI C must abort the flight in the event of unpredicte d obstacles or emergencies in accordance with the operating documents. 24. The PI C is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fl y at normal cruising speed to the intended landing point and land the UA with 25 % battery power remaining. 25. The operator must obtain an Air T raf fic Organizati on (A

TO) issued Certificate of Wa iver or Authorization (COA) prior to conducting an y operations under the grant of exemption. This COA will also require the operator to requ est a Notice to Airman (NOT AM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the AT O issued CO A including class of airspace, altitude level an d potential transponder requirements. 26. All aircraft operated in accordance with the exemptio n must be identified by serial number, registered in accordance with 14 C.F .R. part 47, and have identifica tion (N

- Number) markings in accordance with 14 C.F .R. part 45, Subpart C . Markings must be as large as practicable. 27. Before conducting operations, the radio frequency s pectrum used for operation and control of the UA must compl y with the Federal Communicat ions Commission (FCC) or other appropriate government

ov ersight agency

requirements. 28. The documents required fewer than 14 C.F .R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS an y time the UAS is operating. These documents must be made available to the Administrator or an y law enforcement official upon request. 29. The UA

must remain clear and y ield the right of way to all manned aviation operation s and activities at all times. 30. The UAS may

not be operated b y the PIC from any moving device orvehicle. 31. Flight operations must be conducted at least 500 feet from all

nonparticipating persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehic les, and structures unless:

a. Barriers or structures are present that suf ficiently pr otect nonparticipat ing persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protectio n. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of th e 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 th e PI C has made a safet y assessment of the r isk of operating closer to those objects and determined that it does not present an undue hazard, and;

c. Operations nearer to the PI C, SO, operator traine es or essential persons do not present an undue hazard to those persons per § 91.1 19(a). 32. All operations shall be conducted over private or c ontrolled

- access propert y with permission from the land owner/controller or authorized repres entative. 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 transg resses the lateral or vertical boundaries of the operational area as defined by the applicab le COA must be reported to the FA A's UAS Integration Of fice (AFS

- 80) within 24 hours. Acc idents must be reported to the National Tr ansportation Safet y Board (NTSB) per instructions containe d on the NTSB W eb site: www .ntsb.gov

. **2. Reasons Why**  **An Exemption Fr om**  **The Requir eme**  **nts Of Section 61.1 13(a)**  **And (b) W**  **ould Not**  **Adversely Affect Safety** 

**.** SCOTT R CARR submits that the equivalent level of safet y established by Section 61.1 13(a) and (b) will be maintained because no PIC will be allowed to operate the DJI Phantom 3 and DJII nspire 1 UASs unless that PI C has de monstrated, by meeting minimum flight

- h our and currency requirements, that the PI C is able to sa fely operate the DJ I Phantom 3 or DJ I Inspire 1 UAS in a manner consistent with the ex emption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels , ve hicles and structures. Considering SCOTTR CARR ’ proposed area of operations, and the operating limitations set forth

- above; the parallel nature of privat e pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption N o. 1 1062); and the airmanship skills necessary to safel y operate the DJ I Phantom 3 or DJI Inspire 1 UAS, SCOTTR CARR submits that the additional manned airmanshi p experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for SCOTTR CARR ’ specific proposed flight operations. The F AA has previously

granted relief from Section 61.1 13(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11 0 62, 1 1063, 1 1064, 1 1065, 1 1066, 1 1067, 1 1080, 1 11 09, 1 111 0, 1 111 2, 1 11 36, 1 11 38, 1 11 50, 111 53, 1 11 56, 1 11 58, 1 11 59, 111 60, 1 11 61). SCOTTR CARR will not allow an y P IC to operate the DJ I Phantom 3 or DJ I Inspire 1 UAS unless that PI C has demonstrated, by m eeting minimum flight

- hour requirements or the DJ I Phantom 3 or DJII nspire 1 UAS training andcurrency requirements, that the PI C is able to safely operate the DJ I Phantom 3 or DJ I Inspire 1 UAS in a manner consistent with this exemption, including e vasiv e and emergency maneuvers and maintaining appropriate distances from people, vess els, vehicles and structures. Specifically

, the PIC must have accumulated and logged, in a manner consistent with 14 C.F .R. § 61.51(b), 25 hours of total time as a UAS rotorc raft pilot (with a minimum of 5 hours of those hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In addition to the hour requirements, the PI C must accomplish 3 takeof fs and landings in the prece ding 90 day s (for currency purposes). As in Exemption Nos. 1 1062, 1 11 38, and 1 11 53, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent leve l of safet y during SCOTTR CARR ’ proposed op erations. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe o perations, stating as follows: In Exemption No. 1 1062, the F AA required that prior to conducting ope rations for the purpose of motion picture filming (or similar operations), the PI C 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 p ilot with a multi

- rotor UAS. Prior to operations under Exemption No. 1 1062, the PI C must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption. For clarif ication, the F

AA 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 t ime. In addition to the hour requirements, the PI C must accomplish 3 takeof fs and landings in the preceding 90 day s (for currency purposes). The F

AA finds that at a minimum, the flight hour requirements in Exemption No. 1 1062 are appropriate to practice an d build proficiency

in the skills necessary

to safel y conduct the petitioner ’s proposed operations. The FA A also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Tr ain ing, 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 PI C is required to operate the UA

with appropriat e distances in acc ordance with 14 C.F .R 91.1 19.

Exemption No. 1 11 38 at page 15. Accordingly

, SCOTTR CARR will ensure safe operations b y not allowing any PIC to operate the DJ I Phantom 3 or DJI Inspire 1 UAS unless that PI C has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PI C is able to safely operate the DJ I Phantom 3 or DJII nspire 1 UAS in a manner consistent with th e exemption, including evasive and emergency maneuvers and maintaining appropriate distances from peo ple, vessels, vehicles and structures.**CONCLUSION** SCOTTR CARR seeks an exemption pursuant to 14 C.F .R. § 1 1.61 and Section 333 of the F AA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJ I Phantom 3 and DJII nspire 1 UASs 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 F AA A dministrator will be fulfilling the Congressional mandate of the F AA Modernization and Reform Act of 2012, while als o advancing the interests of the public, by allowin g SCOTT R CARR to safely , ef ficiently
, and economically

operate the DJ I Phantom 3 and DJII nspire 1 UA Ss commerciall y within the NAS. WHEREFORE, in accordance with the Federal Av iation Regulations and the FA A Modernization and Reform Act of 2012, Sect ion 333, SCOTTR CARR respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F .R Sections 61.1 13(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 SCOTTR CARR to operate the DJ I Phantom 3 and DJI Inspire 1 UASs commercially for the purpose of conducting aerial video and photography over certain areas of the United States.

Dated: SEPTEMB ER 3 , 2015 Submitted by Scott R Carr**APPENDIX**

**– A**  DJIPHANT OM 3 TECHNI CAL SPECIFICA

TI ONS

SCOTTR CARR only

utilizes safe and reliable UASs. DJIis an industry leader in small UAS production. DJ I UASs are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJ I software provides real

- time altitude and location information to the PI C via the linked monitor (smart phone/t ablet devices)

DJIPhantom 3 1.1 Aircraft 1.1.1 Supported Battery

– DJ I 6000AH L iPo Battery 1.1.2 We ight (Battery

& Propellers I ncluded)

– 2lbs 1 1.810oz (1242g) 1.1.3 Hover Accuracy

(Ready to Fly )

– Ve rtical: .8m; Horizontal: 2.5m 1.1.4 M ax Yaw Angular Ve locity

- 200/s 1.1.5 Max Ti lt Angel

- 35 1.1.1.6 Max Ascent Speed

– 6m/s 1.1.6 Max Descent Speed

– 2m/s 1.1.7 Max Flight S peed

– 15m/s (NOTRECOMMENDED) 1.2 Gimbal 1.2.1 Wo rking Current

– Static: 750mA; Dy namic: 900mA 1.2.2 Control Accuracy

- ±0.03 1.2.3 Controllable Range

– Pi tch:

- 90

- 0 1.2.4 Maxim um Angu lar Speed

– Pitch: 90/s 1.3 Camera 1.3.1 Operating Temperature Range

- 32F

- 104F (0C

- 40C) 1.3.2 Sensor Size

– 1/2.3” 1.3.3 Ef fective Pixels

– 14M 1.3.4 Resolution

– 4384x3288 1.3.5 HD V

ide o Recording

– 1080p30 & 720p 1.3.6 Recording Field of V iew

- 11 0/85**APPENDIX**

**– B**  DJII NSPI RE 1 TECHNICAL SPECIFICA

TI ONS

SCOTTR CARR only

utilizes safe and reliable UASs. DJIis an industry leader in small UAS production. DJ I UASs are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJ I software provides real

- time altitude and location i nformation to the PI C via the linked monitor (smart phone/tablet devices)

DJII nspire 1 1.1 Aircraft 1.1.1 Model

– T600 1.1.2 We ight (Battery

I ncluded)

– 6lbs 7.5291oz (2935g) 1.1.3 Hovering Accuracy

(GPS Mode)

– Ve rtical: 0.5m; Horizontal: 2.5m
1.1.4 Max Angular V

elocit y

– P itch: 300 /s; Yaw: 150 /s
1.1.5 Max Ti lt Angle

- 35 1.1.6 Max Ascent Speed

– 5m/s 1.1.7 Max Descent Speed

– 4m/s 1.1.8 Max Speed

– 22m/s (A TTImode, no wind

– NOT RECOMMENDED) 1.1.9 Max Flight Altitude

– 4500m 1.1.10 Max Wi nd Resistance

– 10m/s 1.1.11 Max Flight T ime

– Approximately 18 minutes 1.1.12 Motor Model

– DJ I 3510 1.1.13 Propeller Model

– DJ I 1345
1.1.14 Operating Temperature Range

– 14 F to 104 F (

- 10 C to 40 C) 1.1.15 Dimensions

– 17 1⁄4” x 17 3⁄4” x 12” 1.2 Gimbal 1.2.1 Model

– ZENMUSE X3 1.2.2 Output Power (with camera)

– Static: 9W; I n Motion: 1 1W 1.2.3 Operating Current

– Static: 750mA; I n Motion: 900mA
1.2.4 Angular V

ibration Range

- ±0.03 1.2.5 Mounting

– Detachable
1.2.6 Controllable Range

– Pitch:

- 90 to +30 ; Pan: ±320
1.2.7 Mechanical Range

– Pitch:

- 125 to 45 ; Pan: ±330
1.2.8 Max Controllable Speed

– Pitch: 120 /s; Pan: 180 /s 1.3 Tr ansmitter 1.3.1 Name

– C1 1.3.2 Operating Frequency

– 5.728

- 5.850GHz; 2.400

- 2.483GHz 1.3.3 Communicating Distance (unobstructed)

– 2000m 1.3.4 Output Power

– 9W
1.3.5 Operating Temperature Range

- 14 F to 104 F (

- 10 C to 40 C) 1.3.6 Battery

– 600mAh LiPo 2S F All specifications can be found in the attached user manual or at http://www .dji.com/product/inspire

- 1/spec