**IN THE MATTER OF THE PETITION FOR EXEMPTION OF: R. C. Tripp**  **SSN #: 094** 
**- 50** 
**- 0432** 
**FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF**

**TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS**  **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 OPERATI**  **ON OF a) DJI PHANTOM 3 and b) DJI INSPIRE 1**  **UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM AC**  **T OF 2012**

**(PUBLIC LAW 112**
**- 95)**  Submitted on June 10, 2015
R. C. Tripp Regnal Tripp, Owner 143 Marion Oaks Drive Ocala, Florida 34473 352

- 817

- 4857 langerppirt@aol.com

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

THE EXTENT OF RELIEF AND THE REASON R. C. Tripp SEEKS THE RELIEF ...............................

..............................
THE REA SONS WHY GRANTING R. C. Tripp’s REQUEST WOUL D BE IN THE PUBLIC IN TEREST .....................................................

..............................
THE REASONS WHY GRANTING THE EXEMPTI ON WOULD NOT ADVERSEL Y AFFECT SAFETY............................................................................................................2

**GLOSSARY OF ABBREVIATIONS**

AGL Above Ground Level
AOI Area of Interest
ATC Air Traffic Control
ATO Air Traffic Organization
AV Aerial Vehicle
CFR Code of Federal Regulations
COA Certificate of Authorization
FAA Federal Aviation Administration
FAR Federal Aviation Regulation
GCS Ground Control Station
GPS Global Positioning Sy stem
LOL Loss of Link
NAS National Airspace Sy stem
NOTAM Notice to Airman
PI C Pilot I n Command
Section 333 FAA Modernization and Reform Act of 2012 (FMRA)
SO Safety Observer
SOP Standard Operating Procedures
UA Unmanned Aircraft3

UAS Unmanned Aircraft Sy stem
VFR Visual Flight Rules
VLOS Visual L ine of Site
VMC Visual Meteorological Conditions
VTOL Vertical Takeoff and Landing

**SUMMARY** R. C. Tripp seeks exemption from the requirements of 14 C.F.R §§ 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 FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit R. C. Tripp to operate an Unmanned Aircraft Sy stem (UAS) for the commercial purpose of conducting aerial video and photography for real estate photography , wedding videograph y, special events, film sets and landscape over certain areas of the United States.

**INTRODUCTION AND INTERESTS OF THE PETITIONER** My name is Regnal Tripp, Owner/President of R. C. Tripp

. Itis my goal to provide my

customers with solutions that will increase their efficiency , productivity a nd effectiveness. R. C. Tripp also provides clients with the highest qualit y digital content for use in their commercial, personal, and non

- pro fit multimedia projects. T he objective of R. C. Tripp’s aerial video and photograph y operations is to provide high quality imaging for a variet y of commercial, public, and residential uses, specifically targeting:

• Real Estate Videograph y and Photograph y

• Wedding Videograph y and Photograph y

• Land survey

& appraisals

• Equipment I nspections

• Roof I nspections

• C onstruction sites4

• Agriculture

• C ommercial messages for Television.

• Search and Rescue Operations

**BACKGROUND**

Unmanned Aircraf

t Sy stems: DJIPhantom 3 , and DJII nspire 1 UASs R. C. Tripp seeks an exemption to operate DJ I sy stems for compensation or hire within th e NAS. The DJ I Phantom 3 and DJII nspire 1 are vertical takeoff and landing (VTOL) Unman ned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone sy stems. The DJ I Phantom 3 has a maximum gross wei ght of approximately

2 pounds 8 ounces, while hav ing a length of 16 .2 inches width of 16 inches, height of 8 inches, and a m aximum speed of approximately 30 knots. The DJII nspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of approximately

42 knots. The DJ I Phantom 3 and DJII nspire 1 UAs 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 by DRONE NY, Inc. will be registered in accordance with 49 U.S.C. 44103 , Registration of Aircraft , as well as 14 C.F.R Part 47, Aircraft Registration , and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking

. **BASIS FOR PETITION** Petitioner, R. C. Tripp , pursuant to the provisions of the Fede ral Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereb y petitions the Administrator to commerciall y o perate the DJ I Phantom 3 , DJI Inspir e 1 UASs in the National Airspace Sy stem (NAS), and for an exemption from the requirement s of 14 C.F.R §§ 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 l imited operating area associated with the unmanned aircraft and its operation, R. C. Tripp 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 accordan ce with 14 C.F.R. Part 21, Subpart H. Accordingl y, R.C. Tripp 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 apply to aircraft with a n airworthiness certificate.5 R. C. Tripp submits that the requested relief is proper since an equivalent level of safet y will be ensured . I will use experienced personnel or technicians to p erform maintenance, alterations or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Lo g, and DJ I Phantom 3 and DJ I Inspire 1 Instruction Manu al). Furthermore, I will document and maintain all maintenance recor ds for the DJI Phantom 3 and DJII nspire 1 UASs. R. C. Tripp seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness , b ecause 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, Su bpart H. As such, R. C. Tripp submits that he will ensur e that the DJ I Phantom 3 and DJ I In spire 1 UASs are in an airworthy condition, prior to every

flight, by determining that the UASs are in compliance with the operating documents (i.e., Monthly Maintenanc e Log, and DJ I Phantom 3 and DJII nspire 1 I nstruction Manual), and that the aircraft are in a condition for safe flight. R. C. Tripp 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 ty pical barometric altimeter onboard. However, altitude informat ion of the DJI Phantom 3 and DJ I Inspire 1UAs will be provided to the PI C via Global Positioning Sy stem (GPS) equipment an d 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 R. C. Tripp’s operat ion of the DJ I Phantom 3 and DJ I Inspire 1 UASs within vis ual line of sight, at or below 4 00 feet AGL, will ensure a level of safet y equivalent to Section 91.121. Additionally , R. C. Tripp seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flig ht in VFR conditions. R. C. Tripp s ubmits that safet y will not be affected b y operation of the DJIPhantom 3 and DJ I Inspire 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 approx imately 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fl y after that for at least 4.5 minutes.

In accordance with 1 4 C.F.R. § 11.81, R. C. Tripp provides the following information in support of its petition for exemption: **A. Name and Address o**  **f The Petitioner.** The name and address of the Petitioner and point of contact is: Regnal Tripp , DBA R. C. Tripp 143 Marion Oaks Drive Ocala, Florida, 344 736

Tel: (352) 817

- 4857 Email: langerppirt@aol.com **B. The Specific Sections o**  **f 14 C.F.R. From Which R. C. Tripp Seeks**  **Exemption. 1. R. C. Tripp**  **Seeks Exemption f rom The Requirements Of Section Part 21,**  **Subpart H** 14 C.F.R. Part 21, Subpart H, establishes the procedural requirements for the issuance of airworthiness certificates as required by 14 C.F.R. §91.203(a)(1)

**2 . R. C. Tripp**  **Seeks Exemption f rom The Requirements Of Section**  **91.7(a).** Section 91.7, entitled Civil aircraft airworthiness , subsection (a), states the following: (a) No person may

operate a civil aircraft unless it is in an airworthy condition. **3 . R. C. Tripp**  **Seeks Exemption f rom The Requirements Of Section**  **91.121.** Section 91.121, entitled Altimeter settings , 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, b y reference to an altimete r 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 parag raph (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. **4 . R. C. Tripp**  **Seeks Exemption f rom The Requirements Of Section**  **91.151(b).** Section 91.151, entitled Fuel requirements for flight in VFR conditions , subsection (b), states the following: (b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather 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. **5 . R. C. Tripp**  **Seeks Exemption f rom The Requirement Of Section**  **91.405(a).**7 Section 91.405, entitled Maintenance required , subsection (a), states the following: Each owner or operator of an aircraft

— (a) Shall have that aircraft inspected as 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 . R. C. Trip**  **p Seeks Exemption f**  **rom The Requirements Of Section 91.407(a)(1)**  Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration , subsection (a)( 1), states the following: (a) No person may operate any

aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

-- (1) It has been approved for return to service by a person authorized under § 43.7 of this chapter[.] **7 . R. C. Tripp**  **Seeks Exemption From The Requirements 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 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 b y a perso n 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 . R. C. Tripp**  **Seeks Exemption f rom The Requirements Of Section**  **s 91.417(a) a**  **nd 91.417(b).** Section 91.417, entitled Maintenance records , subsections (a) and (b), state the following: (a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the 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 airf rame) and each engine, propeller, rotor, and appliance of an aircraft. The records must include

-- (i) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of completion of the work performed; and8 (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 b e 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 s tatus of applicable airworthiness directives (AD) and safet y directives including, for each, the method of compliance, the AD or safet y directive number and revision date. If the AD or safet y directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms prescribed b y § 43.9(d) of this chapter for each major alteration to the airframe and currentl y installed engines, rotors, propellers, and appliances. (b) The owner or ope rator 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 b y other work or for 1 ye ar 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. (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. **C. The**  **Extent Of Relief R. C. Tripp See**  **ks a nd The Reason R. C. Tripp**  **Seeks The Relief. 1. R. C. Tripp**  **Seeks Exem ption f**  **rom t he Requirements Of Section Part 21,**  **Subpart H** Given the size and limited operating area associated with the UAS to be utilized by R. C. Tripp an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safet y under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§ 44701(f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, spee d, operational capability , and proximity to airports and populated areas of the particular UAS. In all cases, an anal ys is of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will9

be at least as safe, or safer, than a conventional rotorcraft operating with an airworthiness certificate without the restrictions and conditions of the proposed UAS operations.

**2 Extent Of Relief R. C. Tripp**  **See ks And The**  **Reason R. C. Tripp Seeks Relief From**  **Section 91.7(a)**

. Relief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to the extent required to allow R. C. Tripp to determin e that the DJIPhantom 3 and DJ I Inspire 1 UASs are in airworth y condition prior to every flight b y ensuring that the UAS is in compliance with the operating doc uments (i.e., the Aerial Operations Manual, Monthly Maintenanc e Lo g, and DJ I Phantom 3 and DJ I Inspire 1 Instruction Ma nual). R. C. Tripp seeks the requested relief b ecause the DJIPhantom 3 and DJ I Inspire 1 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subp art H. Therefore, R. C. Tripp will ensur e that the DJ I Phantom 3 and DJ I Inspire 1 UASs are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenanc e Lo g, and DJIPhantom 3 and DJ I Inspire 1 Instruction Manual) prior to every flight, and further, determine that the aircraf t are in condition for safe flight, as stated in the conditions and limitations below. **3. Extent Of Relief R. C. Tripp**  **See ks And The Reason R. C. Tripp**  **Seeks Relief From Section 91.121.**  Relief from Section 91.121, entitled Altimeter settings , may be r equired to allow flight operati ons 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 control station (GCS). Since the FAA requires that an y altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above gr ound level (AGL), R. C. Tripp seeks the requested relief b ecause the DJ I Phantom 3 and DJ I Inspir e 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 stated below. As more fully set forth herein, an equivalent level of safet y will be main tained since the DJ I Phantom 3 and DJII nspire 1 UAs are equipped with a barometric pressure sensor and GPS equipment, which automaticall y 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. Extent Of Relief R.C. Tripp**  **Se e**  **ks And The Reason R. C. Tripp Seeks Relief**  **From Section 91.151(b).** Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to allow flights of the batte ry powered DJ I Phantom 310

and DJ I Inspire 1 UAs during day light hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fl y after that for at l east 4.5 minutes. R. C. Tripp seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered DJ I Phantom 3 and DJ I Inspire 1 UAs will severely constrain the practicality of an y aerial video or sti ll photo fligh t operations that R. C. Tripp proposes to conduct pursuant to this Petition. Significantl y, as set forth below, the technical specificati ons of the DJ I Phantom 3 and DJI Inspire 1 UASs, the DJ I Phantom 3 and DJII nspire 1 operating documen ts, and R. C. Tripp’s proposed operating limitat ions, ensure that R. C. Tripp will safely operate t he battery powered 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 fl y for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruis ing speed, to fl y after that for at least 4.5 minutes. **5. Extent Of Relief R. C. Tripp**  **See ks And The Reason R. C. Tripp**  **Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b).**  Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) onl y apply to aircraft with an airworthi ness certificate, R. C. Tripp requests relief from these Sections b ecause the DJ I Phantom 3 and DJII nspire 1 UASs do not require airworthiness certificates. A s set forth more fully below, the DJI Phantom 3 and DJ I Inspire 1 UASs meet the conditions of FMRA Section 333 for operation without an airworthiness certific ate. Accordingl y, R. C. Tripp will use trained technicians to perform mai ntenance or preventive ma intenance on the UASs using the methods, techniques, and practices prescribed in the UAS operating doc uments (i.e., the Aerial Operations Manual, M onthly Maintenance Log, and DJ I Phantom 3 and DJII nspire 1 Instruction Manual). Furthermore, R. C. Tripp wi ll document and maintain all maintenance records for the DJ I Phantom 3 and DJII nspire 1 UASs

.
**D. The Rea sons Why Granting R. C. Tripp’s**  **Request Would Be In The Public Interest; That Is, How It Would Benefit The Public As A Whole.**  Granting the pres ent Petition will further the public int erest b y allowing R. C. Tripp to safel y, efficientl y, and economically perform aerial video and photograph y of, real estate, wedding films, special events, precision agriculture, land survey & appraisal, construction sites, equipment & roof inspections, film sets 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, and provide significant benefits to the econom y. Notably , the benefits of R. C. Tripp ’s proposed operat ion of the DJ I Phantom 3 and DJ I In spire 1 UASs will be realized without implicating an y privacy issues. **1. The Public Will Benefit From Decreased Congestion Of The NAS.** 11

The DJ I Phantom 3 and DJII nspire 1 UAs 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 th e use of a DJI Phantom 3 or DJ I Inspire 1 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and propert y in the air and on the ground. Furthermore, by

reducing the number of manned aircraft operating in the NAS, congestion around airports caused b y arriving and departing aircraft will be re duced. The DJIPhantom 3 and DJ I Inspire 1 UAs do not require an airport to takeoff or land. Likewise, a reduc tion 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 Efficie ncy Of The DJI Phantom 3**  **and DJI Inspire 1 UASs.**  Conducting aerial acquisitions with the DJI Phantom 3 and DJ I Inspire 1 UAS’s, instead of manned aircraft, will greatl y 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 an d electric m otors, the DJ I Phantom 3 and DJ I Inspire 1 UASs produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cy linder internal combustion engine aircraft that are ty picall y utilized for aerial v ideo and photograph y, while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The DJ I Phantom 3 and DJII nspire 1 UAs, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAs are propelled by

battery powered electric motors, rather than an internal combustion engine. By using the DJ I Phantom 3 and DJ I Inspire 1 UAS’s to perform aerial acquisitions, the substantial risk to life and propert y in the air and on the ground, which is usually ass ociated with traditional manned aircraft flight operations, will be substantially reduced or completel y eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJ I Phant om 3 and DJ I Inspire 1 UAs (weighing approximately 2 p ounds 11 ounces and 6 pounds 7.5 ounces respectivel y, at their maximum gross weights with lengths of 16 inches and 17.3 inches respectivel y, widths of 16 inches and 17.7 inches respectivel y, and with no fuel on board), has less physical potential for colla teral damage to life and propert y on the ground, and in the air, compared to the manned aircraft that ty picall y conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capaci ty of 180 gallons). **3. Performing Aerial Video and Photography Operation**  **s With The DJI Phantom 3 and**  **DJI Inspire 1 UASs Will Benefit The Economy.**12

In addition to being safe and efficie nt, the DJ I Phantom 3 and DJII nspire 1 UASs are also an economical al ternative to using manned aircraft to conduct similar aerial operations. As such, operat ion of the DJ I Phantom 3 and DJ I Inspire 1 UASs will allow United States based com panies, like R. C. Tripp , to remain competitive and contribute to growth of the U.S. e conomy . 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 batte ry powered DJ I Phantom 3 and DJ I Inspire 1 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 c ost of a traditional manned aircraft. By ope rating the DJ I Phantom 3 and DJII nspire 1 UASs, c ompanies such as R. C. Tripp can remain competitive and profitable, and therefore, provide greater job stability to employ ees and contractors, which will ultim ately contribute to growth of the U.S. econom y. Improved financial performance of U.S. companies, through commercia l use of the DJ I Phantom 3 and DJII nspire 1 UASs, provides a stable workforce that increases consumer spending; improves local, state, and f ederal 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.**  R. C. Tripp ’s proposed operat ion of the DJ I Phantom 3 and DJ I Inspire 1 UASs will not implicate any

privacy issues. Specifi call y, the DJ I Phantom 3 and DJII nspire 1 UASs will be operated onl y in compliance with operating doc uments (i.e., the Aerial Operations Manual, Monthly Maintenanc e Log, and DJ I Phantom 3 and DJII nspir e 1 Instruction Manual) which requires propert y owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.

**E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or**  **How The Exemption Would Provide A Level Of Safety At Least Equal To That Provi**  **ded By The Rule From Which R. C. Tripp Seeks Exemption.**  **1. Reaso ns Why The DJI Phantom 3**  **and DJI Inspi re 1 UAs Meet The Conditions Of**  **The FAA 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 a nd its operation, R. C. Tripp ’s operat ion of the DJ I Phantom 3 and DJI Inspire 1 UAS’s meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Section 333 provides authority for a UAS to operate without airworthine ss certification and sets forth requirements for considering whether a UAS will create a hazard to users of13

the NAS or the public, or otherwise pose a threat to national securit y. Specifically, FMRA Section 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 airspa ce 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 unmanne d 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, R. C. Tripp submit s that the DJ I Phantom 3 and DJII nspire 1 UASs can operate safel y in the NAS pursuant to FMRA Section 333, as de monstrated by : (a) the characterist ics of the DJIPhantom 3 and DJ I Inspire 1 UASs; (b) the pilot certification requirement; and (c) the specific operating limitations. **a. The Specificati ons Of The DJI Phantom 3**  **and DJI Inspire 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 operational capability

. **i. Technical Specificat**  **i ons Of The DJI Phantom 3**  **and DJI Inspire 1 UASs.** The technical specifications of the DJ I Phantom 3 and DJII nspire 1 UASs are set fo rth b y the DJIPhantom 3 and DJ I Inspire 1 Specifications and Data Sheet, attached hereto as Exhibit A and B

. **ii. The DJI Ph**  **antom 3 and DJI Inspire 1 UASs Autonomous Flight And**  **Navigation Modes Enable The UASs To Remain Within A Defined Operational Area.** 14

The DJ I Phantom 3 and DJII nspire 1 UASs may be operated in both manual and fully autonomous flight modes. A complete description of the flight and navigational modes of the DJ I Phan tom 3 and DJII nspire 1 UASs are provided at pages 2 341 of the DJ I Phantom 3 ; and pages 12

- 18 and 45

- 52 of the DJ I Inspire 1 User Manuals, attached hereto as Exhibit C and D. **iii. The DJI Phantom 3**  **and DJI Inspire 1 UASs Are Designed For Automatic Return To Home Point Or Hover In The Event Of Loss Of The Control Link Or**  **Navigation.** When the Contr ol L ink is lost, the DJIPhantom 3 and DJ I Inspire 1 UAs will remain stationary , in flight, for 3 seconds or more. If, after 3 second s, the DJ I Phantom 3 and DJI Inspire 1 UAs do not reacquire control link data from the GCS, the UAs will assume that the Co ntrol L ink 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. A complete description of the Failsafe Functio ns for the DJ I Phantom 3 UAS are set forth at pages 32 throu gh 34 of the DJ I Phantom 3 User Manual; and for the DJII nspire 1 at pages 13 through 15 of the DJ I Inspire 1 User Manual, attached hereto as Exhibit C and D. **iv. The DJI Phantom 3**  **and DJI Inspire 1 GCS And Its Operation.** A complete description of the opera tion and specificati ons of the DJ I Phantom 3 and DJII nspire 1 GCS and flight control software is provided at pages 7 through 17 of the DJI Phantom 3 User Manual; and pages 24 through 34 of the DJ I Inspire 1 Us er Manual. DJI Phantom 3 and DJ I Inspire 1 User Manuals are attached hereto as Exhibits C and D. **b. Flight Operations Of DJ**  **I Phantom 3 and DJI Inspire 1 UASs Are Limited To**  **The Line Of Sight Of A**  **Pilot in Command With A Safety Observer.**

**2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And**  **(b) Would Not Adversely Affect Safety.** R. C. Tripp submits that the equivalent level of safety established by

Section 61.113(a) and (b) will be maintained because no PIC will be allowed to o perate the DJ I Phantom 3 and DJII nspire 1 UASs unless that PIC has demonst rated that the PI C is a **3. Reasons Why An Exemption From The Requirements Of Section 91.7(a)**  **Would Not Adversely Affect Safety.** The equivalent level of safet y established b y Section 91.7(a) will be maintained because prior to every

flight, R. C. Tripp will ensur e that the DJ I Phantom 3 or DJ I Inspire 1 UAS is in an airworth y condition based upon the UAS’s compliance with its operating documents and as stated in the conditions and limitations here in. Additionally , the FAA has previously granted relief from Section 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).15

**4. Reasons Why An Exemption From The Requirements Of Section 91.121**  **Would Not Adversely Affect Safety.** The equivalent level of safet y established b y Section 91.121 will be main tained because the altitude informat ion of the DJ I Phantom 3 and DJ I Inspire 1 UAs will be provided to the PI C 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 informat ion, combined with operat ion of the DJ I Phantom 3 and DJI Inspire 1 UAs within visual line of sight, at or below 500 feet AGL, will ensure a level of safet y equivalent to Section 91.121. The altitude information will be generated b y GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically establish ed by

the UASs at ground le

. **5. Reasons Why An Exemption From The Requirements Of Section 91.151(b)**  **Would Not Adve rsely Affect Safety.**  A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJ I Phantom 3 and DJII nspire 1 UASs; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operati ons. Accordingl y, R. C. Tripp will ensure that it will safel y operate the batte ry powered DJ I Phantom 3 and DJII nspire 1 UAs during day light hours in VFR conditions, with enoug h 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 fl y after that for at least 4.5 minutes. Here, as in Exemption No. 11109, the technical specificati ons of the DJ I Phantom 3 and DJ I Inspire 1 UASs; 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. Section 91.151(b). Furthermore, safety will be ensu red as the DJIPhantom 3 and DJ I Inspire 1 UASs provide audible and visual warnings to the PI C 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% remain ing battery

power. At the criticall y low batter y level, the DJ I Phantom 3 and DJ I Inspire 1 UASs will descend and land automaticall y.

**6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a),**  **91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417 (a) & (b) Would Not Adversely Affect**  **Safety.** In seeking this exemption , Isubmit that the equivalent level of safet y with regard to the regulatory

maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a )(2), and 91.417(a) & (b) w ill be met because We will use trained technicians to p erform maintenance or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating doc uments (i.e., the Aerial16

Operations Manua l, Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJ I Ins pire 1 Instruction Manual.

**F. A Summary That Can Be Published In The Federal Register, stating:**  **The Rules From Which R. C. Tripp Inc. Seeks Exemption:**  R. C. Tripp seeks exemption from the requirements of 14 C.F.R Sections 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 O f The Nature Of The Exemption R. C. Tripp**  **Seeks:** This exem ption will pe rmit R. C. Tripp to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States. In accordance with the Federal Aviation Regulations and the FAA Modernization an d Reform Act of 2012, Section 333, R. C. Tripp respectfull y request that the Administrator grant this petition for an exemption from the requirements of 14 C.F.R Sections 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).

**Dated: June 10, 2015 Respectfully submitted,** 

_______________________ **Regnal Tripp, Owner R. C. Tripp**  **143 Marion Oaks Drive Ocala, Fl 34473**  **(352) 817**
**- 4857**  **langerppirt@aol.com**17 APPENDIX

– A **DJI PHANTOM 3**  **TECHNICAL SPECIFICATIONS**

1.1 DJIPhantom 3 1.1.1 Aircraft 1.1.1.1 Supported Battery

– DJ I 5200mAH LiPo Battery 1.1.1.2 Weight (Battery

& Propellers Included)

– 2lbs 11.810oz (1242g) 1.1.1.3 Hover Accuracy

(Ready to Fl y)

– Vertical: .8m; Horizontal: 2.5m 1.1.1.4 Max Yaw Angular Velocit y - 200 /s 1.1.1.5 Max Tilt Angel

- 35 1.1.1.6 Max Ascent Speed

– 6m/s 1.1.1.7 Max Descent Speed

– 2m/s 1.1.1.8 Max Flight Speed

– 15m/s (NOT RECOMMENDED) 1.1.2 Gimbal 1.1.2.1 Working Current

– Static: 750mA; Dy namic: 900mA 1.1.2.2 Control Accuracy

- ±0.03 1.1.2.3 Controllable Range

– Pitch:

- 90

- 0 1.1.2.4 Maximum Angular Speed

– Pitch: 90 /s 1.1.3 Camera 1.1.3.1 Operating Temperature Range

- 32 F

- 104 F (0 C

- 40 C) 1.1.3.2 Sensor Size

– 1/2.3” 1.1.3.3 Effective Pixels

– 14M 1.1.3.4 Resolution

– 4384x3288 1.1.3.5 HD Video Recording

– 1080p30 & 720p 1.1.3.6 Recording Field of View

- 1 10 /85 1.1.4 Transmitter 1.1.4.1 Operating Frequency

– 5.728GHz

– 5.85GHz 1.1.4.2 Communication Distance (unobstructed)

– FCC Compliance: 800m18 1.1.4.3 Receiver Sensitivity (1%PER)

- - 93dBm 1.1.4.4 Transmitter Power

– FCC Compliance: 100mW 1.1.4.5 Working Voltage

– 120mA@3.7V 1.1.5 Range Extender 1.1.5.1 Operating Frequency

– 2412

- 2462MHz 1.1.5.2 Communication Distance (unobstructed)

– 500

- 700m 1. 1.5.3 Transmitter Power

– 20dB

APPENDIX

– B **DJI INSPIRE 1 TECHNICAL SPECIFICATIONS**

2.2 DJII nspire 1 2.2.1 Aircraft 2.2.1.1 Model

– T600 2.2.1.2 Weight (Battery

Included)

– 6lbs 7.5291oz (2935g) 2.2.1.3 Hovering Accuracy (GPS Mode)

– Vertical: 0.5m; Horizontal: 2.5m 2.2.1.4 Max Angular V elocity

– Pitch: 3000/s; Yaw: 1500/s 2.2.1.5 Max Tilt Angle

- 350 2.2.1.6 Max Ascent Speed

– 5m/s 2.2.1.7 Max Descent Speed

– 4m/s 2.2.1.8 Max Speed

– 22m/s (ATTI mode, no wind

– NOT RECOMMENDED) 2.2.1.9 Max Flight Altitude

– 4500m 2.2.1.10 Max Wind Resistance

– 10m/s 2.2.1.11 Max Flight Time

– Approximately 18 minutes 2.2.1.12 Motor Model

– DJI3510 2.2.1.13 Propeller Model

– DJI1345 2.2.1.14 Operating Temperature Range

– 140F to 1040F (

- 100C to 400C) 2.2.1.15 Dimensions

– 17 1 ⁄4” x 17 3⁄4” x 12” 2.2.2 Gimbal 2.2.2.1 Model

– ZENMUSE X3 2.2.2.2 Output Power (with camera)

– Static: 9W; In Motion: 11W 2.2.2.3 Operating Current

– Static: 750mA; I n Motion: 900mA 2.2.2.4 Angular Vibration Range

- ±0.03 0 2.2.2.5 Mounting

– Detachable 2.2.2.6 Controllable Range

– Pitch:

- 900 to +300; Pan: ±3200 2.2.2.7 Mechanical Range

– Pitch:

- 1250 to 450; Pan: ±3300 2.2.2.8 Max Controllable Speed

– Pitch: 1200/s; Pan: 1800/s 2.2.3 Camera19 2.2.3.1 Name

– X3 2.2. 3.2 Model

– FC350 2.2.3.3 Total Pixels

– 12.76M 2.2.3.4 Effective Pixels

– 12.4M 2.2.3.5 I mage Max Size

– 4000x3000 2.2.3.6 I SO Range

– 100

- 3200 2.2.3.7 Field of View

- 940 2.2.3.8 CMOS

– Sony

EXMOR 1/2.3” 2.2.3.9 HD Video Recording

– UHD(4K): 40 96x2160p24/25, 3840x2160p24/25/30; FHD: 1920x1080p24/25/30/48/50/60;