UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Realtime Aerial

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1)

& (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF DJI

PHANTOM 3 PROFESSIONAL AND DJI INSP IRE 1 UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112

- 95)

Submitted on June 15 , 2015

Realtime Aerial

841 Brunellos Avenue

Las Vegas, Nevada 89123

702

- 353

- 5742FAA Petition for Exemption Realtime Aerial

— June 15 , 2015

Page 2 TABLE OF CONTENTS

Page

GLOSSARY OF ABBREVIATIONS 3

SUMMARY 4

INTRODUCTION AND INTERESTS OF PETITIONER 4

BACKGROUND 4

BASIS FOR PE TITION 5

NAME AND ADDRESS OF PETITIONER 6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH REALTIME AER IAL SEEKS E XEMPTION 6

THE EXTENT OF RELIEF REALTIME AERIAL SEEKS AND THE REASON

REALTIME AERIAL SEEKS THE RELIEF 9

THE REASONS WHY GRANTING REALTIME AERIAL REQUEST WOULD BE

IN THE PUBLIC INTEREST 11

THE REASONS WHY GRANTING THE EXEMPTION W OULD NOT ADVERSELY

AFFECT SAFETY 13

CONCLUSION 2 2

APPENDIX A

— DJI PHANTOM 3 PROFESSIONAL SPECIFICATIONS SHEET

APPENDIX B

— DJI INSPIRE TECHNICAL SPECIFICATIONS SHEET

APPENDIX C

— DJI PHANTOM 3 PROFESSIONAL MANUAL

APPENDIX D

— DJI INSPIRE 1 MANUAL

APPENDIX E

— REALTIME AERIAL MONTHLY MAINTENANCE LOGFAA Petition for Exemption Realtime Aerial

— June 15 , 2015

Page 3 GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

Section 333 FAA Modernizat ion and Reform Act of 2012 (FMRA)

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and LandingFAA Petition for Exemption Realtime Aerial

— June 15 , 2015

Page 4 SUMMARY

Realtime Aerial seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Ryan C. Jones, CEO/Co

- Owner and/or Jason E. Hoffman, COO/Co

- owner to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography of to be used in real estate, environmental / engineering projects, special events such as weddings and parties , sporting events, construction inspection purposes, educational outreach, and Hollywood

- style videography purposes over certain area s of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Realtime Aerial is a partnership formed by Ryan C. Jones and Jason E. Hoffman, both of Las Vegas, Nevada. Ryan (aged 3 6 years) has over 12 years of practical experience as an environment al geologist, with a focus on asbestos consultation. Jason (aged 38 years) has over 15 year of practical experience as an environmental geologist, with a focus on health and safety

. We both have long

- standing interests in professional photography and vid eography, and have spent a good portion of our lives engaged in technology and using technology as a tool to help us better understand the world around us.

The objective is to use our small business, Realtime Aerial, to provide aerial photography and
video graphy services fo r a variety of commercial and public uses, specifically targeting:

• Real estate assessments and photography/videography

.

• Environmental remediation/reclamation projects

.

• Engineering project evaluations (e.g., before/during/after inspe ctions).

• Special events (e.g., weddings, private parties, golf tournaments, charity events)

• Construction projects.

• Educational outreach in Southern Nevada (working with local school robotic programs and community outreach to educate and promote UAS applications)

• Professional (Hollywood) style productions for producers and other high

- end entertainment projects.

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 3 Professional , DJI Inspire 1 UASs

Realtime Aerial seeks an exemption to operate DJI syste ms for compensation or hire within the NAS. The
DJI Phantom 3 Professional and DJI Inspire 1 are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The DJI
Phan tom 3 Professional has a maximum gross weight of approximately 2 pounds 11 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 DJI Inspire 1 has a maximum gross weight of 6 p ounds 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 DJI Phantom 3 Professional and DJI Inspire 1UAs are equipped with four main rotors; driven by Lithium Polymer battery powered electric motors.FAA Petition for Exemption Realtime Aerial

— June 15 , 2015

Page 5 The DJI Phantom 3 Professional and DJI Inspire 1 UAs that will be operated by Realtime Aerial 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, Realtime Aerial , pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform A ct of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereby petitions the Administrator to commercially operate the DJI
Phantom 3 Professional and/or DJI Inspire 1 UASs in the National Airspace System (NAS), and for an

exemp tion from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, Realtime Aerial operation of DJI Phantom 3 Professional and DJI Inspire 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, Realtime Aerial 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 only apply to aircraft with an airworthiness certificate. Realt ime
Aerial submits that the requested relief is proper since an equivalent level of safety will be ensured.
Realtime Aerial will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the m ethods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Professional and DJI Inspire 1
Instructio n Manual). Furthermore, Realtime Aerial will document and maintain all maintenance recor ds
fo r the DJI Phantom 3 Professional and DJI Inspire 1 UASs.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and
lim itations: Pilot in c ommand , is requested by Realtime Aerial to the extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an airman medical certificate, and who has demonstrated, by meeting minimum flighthour and currency requirements, that the PIC is able to safely o perate the DJI Phantom 3 Professional and DJI Inspire 1 UASs in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

Realtime Aerial seeks relief from Section 91.7( a), entitled Civil aircraft airworthiness , because the DJI
Phantom 3 Professional and DJI Inspire 1 UASs do not require an airworthiness certificate in accordance
with 14 C.F.R. Part 21, Subpart H. As such, Realtime Aerial submits that t he y will ensur e tha t the DJI
Phantom 3 Professional and DJI Inspire 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 Maintenan ce Log, and DJI Phantom 3 Professional and D JI Inspire 1 Instruction Manual), and that the aircraft are in a condition for safe flight.

Realtime Aerial also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , as the DJI Phantom 3 Professional and DJI Inspire 1 UAs will not have a typical barometric altimeter onboard. However, altitude informa tion of the DJI Phantom 3 Professional and DJI Inspire 1UAs will be provided to the PIC via Global Positioning System (GPS) equipment and radioFAA Petition for Exemption Realtime Aerial

— June 15 , 2015

Page 6 communicat ions telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude inf ormation, combined with Realtime Aerial’ s operation of the DJI Phantom
3 Professional and DJI Inspire 1 UASs within visual line of s ight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, Realtime Aerial seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions

. Realtime Aeria l submits that safety will not be affected by operation of the DJI Phantom 3 Professional and DJI Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a
total du ration of approximately 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

In accordance with 14 C.F.R. § 11.81, Realtime Aerial provides the following i nformation in support of its petition for exemption:

A. Name And Address Of The Petitioner.

The name and address of the Petitioner and point of contact is:

Realtime Aerial

Ryan C. Jones, CEO/Co

- owner; Jason E. Hoffman, COO/Co

- owner

841 Brunellos Avenue

Las Vegas, Nevada 89123

702

- 353

- 5742

Email: rjones@realtimeaerial.com / jhoffman@realtimeaerial.com

B. The Specific Sections Of 14 C.F.R. From Which Realtime Aerial Seeks Exemption.

1. Realtime Aerial Seeks Exemption From The Requirements Of Section 61.113(a) And (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command

, subsections (a) and (b) prescribe the following, in relevant part:

(a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PIC of an aircraft.

(b) A privat e pilot may, for compensation or hire, act as PIC of an aircraft in connection wit h any business or employment if:

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire.

2. Realtime Aerial Seeks Exemption From The Requirements Of Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness , subsection (a), states the following:FAA Petition for Exemption Realtime Aerial

— June 15 , 2015

Page 7 (a) No person may operate a civil aircraft unless it is in an airworthy condit ion.

3. Realtime Aerial Seeks Exemption From 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 fligh t level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating:

(1) Below 18,000 feet MSL, to:

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

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

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

4. Realtime Aerial Seeks Exemption From The Requirements Of Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions , subsection (b), states th e 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 afte r that for at least 20 minutes.

5. Realtime Aerial Seeks Exemption From The Requirement Of Section 91.405(a).

Section 91.405, entitled Maintenance required , subsection (a), states the following: Each o wner 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. Realtime Aerial Seeks Exempti on From 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,

re building, or alteration unless:

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

7. Realtime Aerial Seeks Exemption From The Requirements Of Sections 91.409(a)(1) A nd 91.409(a)(2).

Section 91.409, entitled Inspections , subsection (a), states the following:FAA Petition for Exemption Realtime Aerial

— June 15 , 2015

Page 8 (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 1 2 calendar months, it has had:

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

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

8. Realtime Aerial Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b).

Section 91.417, entitled Maintenance records , subsections (a) and (b), state the following:

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

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

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

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

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

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

(2) Records containing the following information:

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

(ii) The current status of life

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

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

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

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

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

(b) The owner or operator shal l retain the following records for the periods prescribed:

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

(2) The records spe cified in paragraph (a)(2) of this section shall be retained and transferred with the
aircraft at the time the aircraft is sold.FAA Petition for Exemption Realtime Aerial

— June 15 , 2015

Page 9 (3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be
retained until the def ects are repaired and the aircraft is approved for return to service.

C. The Extent Of Relief Realtime Aerial Seeks And The Reason Realtime Aerial Seeks The Relief.

1. Extent Of Relief Realtime Aerial Seeks And The Reason Realtime Aerial Seeks Relief From Section 61.113(a) And (b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations:

Pilot in command , is requested to the extent necessary to allow a PIC holding a private pilot or higher level certificate, as well as a curr ent and valid airman medical certificate, and who has met certain flight

hour and currency requirements, to conduct the proposed UAS flight operations for compensation or
hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers o r property for compensation or hire.

As set forth more fully below, Realtime Aerial submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the DJI Phantom 3 Professional UAS or DJI Inspire
1 UAS unless that PIC has met certain flight

- hour and currency requirements, demonstrating that the PIC is able to safely operate either the DJI Phantom 3 Professional or DJI Inspire 1 UAS in a manner consistent with the operations specifications as described in this exempt ion, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and

structures.

Further, Realtime Aerial submits that all flights of the DJI Phantom 3 Professional and DJI Inspire 1 UASs, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to Realtime Aerial’s business; and (2) will not carry passengers or property for compensation or hire.

2. Extent Of Relief Realtime Aerial Seeks And The Reason Realtime Aer ial 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 Realtime Aerial to determine that the DJI Phantom 3 Professional and DJI Inspire 1 UASs are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., the Realtime Aerial Aerial Operations Manual, Monthly Maintenance Log, and DJI
Phantom 3 Professional and DJI Inspire 1 Instruction Manual).

Realt ime Aerial seeks the requested relief because the DJI Phantom 3 Professional and DJI Inspire 1 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Realtime Aerial will ensure that the DJI Phantom 3 P rofessional and DJI Inspire 1 UASs are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Professional and DJI Inspire 1 Instruction Manual) prior to every flight, and further, de termine that the aircraft are in condition for safe flight, as stated in the conditions
and limitations below.FAA Petition for Exemption Realtime Aerial

— June 15 , 2015

Page 10 3. Extent Of Relief Realtime Aerial Seeks And The Reason Realtime Aerial Seeks Relief From Section
91.121.

Relief from Section 91.121, entitled A ltimeter settings, may be required to allow flight operations of the
DJI Phantom 3 Professional and DJI Inspire 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 PIC at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL),
Realtime Aerial seeks the requ ested relief because the DJI Phantom 3 Professional and DJI Inspire 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 propose d operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply with the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level of safety will be maintained since the DJI Phantom 3 Profes sional and DJI Inspire 1 UAs are equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the PIC with altitude information of the UA on the heads

- up display of the GCS.

4. Extent Of Relief Realtime Aerial Seeks And The Reason Realtime Aerial 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 battery powered DJI Phantom 3 Professional and DJI Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to the first poi nt of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. Realtime Aerial seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered DJI
Phan tom 3 Professional and DJI Inspire 1 UAs will severely constrain the practicality of any aerial video or still pho to flight operations that Realtime Aerial proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical spec ificat ions of the DJI Phantom 3 Professional and DJI Inspire 1 UASs, the DJI Phantom 3 Professional and DJI Inspire 1 operating documents,and Realtime
Aerial proposed operating limitations, ensure that Realtime Aerial will safely operate the battery

powere d DJI Phantom 3 Professional and DJI Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total duration of 13.5 minutes to the first point of intended landin g and, assuming normal cruising speed, to fly after that
for at least 4.5 minutes.

5. Extent Of Relief Realtime Aerial Seeks And The Reason Realtime Aerial Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b).

Sinc e Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, Realtime Aerial requests relief from these Sections because the DJI
Phantom 3 Professional and DJI Inspire 1 UASs do not require airworthiness certificates. As set forth more fully below, the DJI Phantom 3 Professional and DJI Inspire 1 UASs meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, Realtime Aerial will useFAA Petition for Exemption Realtime Aerial

— June 15 , 2015

Page 11 trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the Realtime
Aerial Aerial Operations Man ual, Monthly Maintenance Log, and DJI Phantom 3 Professional and DJI Inspire 1 Instruction Manual). Furthermore, Realtime Aerial will document and maintain all
maintenance records for the DJI Phantom 3 Professional and DJI Inspire 1 UASs.

D. The Reasons W hy Granting Realtime Aerial Request Would Be In The Public Interest; That Is, How It
Would Benefit The Public As A Whole.

Granting the present Petition will further the public interest by allowing Realtime Aerial to safely, efficiently, and economically pe rform aerial video and photography of real estate, environmental / engineering projects

, social events, construction projects, sporting events, educational events, and Hollywood

- style projects over certain areas of the United States.

Additionally, use of t he DJI Phantom 3 Professional and DJI Inspire 1 UASs will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of
Realtime Aerial ’s proposed operation of the DJI Phantom 3 Professional and DJI Inspire 1 UASs will be realized without implicating any privacy issues.

1. The Public Will Benefit From Decreased Congestion Of The NAS.

The DJI Phantom 3 Professional and DJI Inspire 1 UAs are battery powered and serve as a safe, efficient,
and econo mical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing
the use of a DJI Phantom 3 Professional or DJI Inspire 1 UAS wo uld reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The DJI Phantom 3 Professional and DJI Inspire 1 UAs do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography m issions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 3 Profe ssional and DJI Inspire 1 UASs.

Conducting aerial acquisitions with the DJI Phantom 3 Professional and DJI Inspire 1 UASs, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated d uring traditional aerial video and still photography flight operations. By using battery power and electric motors, the DJI Phantom 3 Professional and DJI Inspire 1 UASs produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically utilized for aerial video and photography, while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The DJI Phantom 3 Professional and DJI Inspire 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.FAA Petition for Exemption Realtime Aerial

— June 15 , 2015

Page 12 By using the DJI Phantom 3 Professional and DJI Inspi re 1 UASs to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated.
Aside from the lack of flight crew members located onboard the aircraft, the DJI Phantom 3 Professional and DJI Inspire 1 UAs (weighing approximately 2 pounds 11 ounces and 6 pounds 7.5 ounces respectively, at their maximum gross weights with lengths of 16 inche s and 17.3 inches respectively, widths of 16 inches and 17.7 inches respectively, and with no fuel on board), has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typical ly conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography O perations With The DJI Phantom 3 Professional and DJI Inspire 1 UASs Will Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 3 Professional and DJI Inspire 1 UASs are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, oper ation
of the DJI Phantom 3 Professional and DJI Inspire 1 UASs will allow United States based companies, like
Realtime Aerial , to remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery powered DJI Phantom 3 Profession al and DJI 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 cost of

a traditional manned aircraft.

By operating the DJI Phantom 3 Professional and DJI Inspire 1 UASs, companies such as Realtime Aerial

, can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately contribute to growth of the U.S. e conomy. Improved financial performance of U.S. companies, through commercial use of the DJI Phantom 3 Professional and DJI Inspire 1 UASs, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and al lows companies to invest in research and development in order to remain competitive both in the United States and abroad.

4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for decades,
Realt ime Aerial ’s proposed operation of the DJI Phantom 3 Professional and DJI Inspire 1 UASs will not implicate any privacy issues. Specifically, the DJI Phantom 3 Professional and DJI Inspire 1 UASs will be operated only in compliance with operating documents (i.e., the Realtime Aerial Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Professional and DJI Inspire 1 Instruction Manual) which requires property owner involvement as well as local law enforcement notification, and
in accordance w ith the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.FAA Petition for Exemption Realtime Aerial

— June 15 , 2015

Page 13 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 Provided By

The Rule From Which Realtime Aerial Seeks Exemption.

1. Reasons Why The DJI Phantom 3 Professional and DJI Inspire 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 and its operation, Realtime Aerial ’s operation of the DJI Phantom 3 Professional and DJI Inspire 1 UASs 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 airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users of th e NAS or the public, or otherwise pose a threat to national security. 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 enact ment 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 rule making required by section 332 of this Act or the guidance requ ired 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, we ight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not
create a hazard to users of the national airspace system or the public or pose a threat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1). (c) Re quirements for Safe O peration. 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, Realtime Aerial submits that the DJI Phantom 3 Professional and DJI Inspire 1 UASs can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the
characteristics of the DJI Phantom 3 Prof essional and DJI Inspire 1 UASs; (b) the pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The DJI Phantom 3 Professional and DJI Inspire 1 UASs Demonstrate Its Safe
Characteristics.

The DJI Phantom 3 Professional and DJI Inspire 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 Specifications Of The DJI Phantom 3 Professional and DJI Inspire 1 UASs.FAA Petition for Exemption Realtime Aerial

— June 15 , 2015

Page 14 The technical specifications of the DJI Phantom 3 Professional and DJI Inspire 1 UASs are set forth by the
DJI Phantom 3 Professional and DJI Inspire 1 Specifications and Data Sheet, attached hereto as Appendix
A and B.

ii. The DJI Phantom 3 Professional and DJI Inspire 1 UASs Autonomous Flight And Navigation Modes
Enable The UASs To Remain Within A Defined Operational Area.

The DJI Phantom 3 Professional and DJI Inspire 1 UASs may be operated in both manual and fully

au tonomous flight modes. A complete description of the flight and navigational modes of the DJI
Phantom 3 Professional and DJI Inspire 1 UASs is provided at pages 25

- 35 of the DJI Phantom 3 Professional and pages 12

- 16 and 45

- 50 of the DJI Inspire 1 User Man uals, attached hereto as Appendix
C and D.

iii. The DJI Phantom 3 Professional 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 Control Link is lost, the DJI Ph antom 3 Professional and DJI Inspire 1 UAs will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 3 Professional and DJI Inspire 1 UAs do not reacquire control link data from the GCS, the UAs will assume that the Con trol Link is lost and the UAs will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown. A complete description of the Failsafe Functions of the DJI Phantom 3
Professional UAS are set forth at pages 27 through 29 and for the DJI Inspire 1 at pages 13 through 15 of
the DJI Phantom 3 Professional and DJI Inspire 1 User Manuals, attached hereto as Appendix C and D.

iv. The DJI Phantom 3 Professional and DJI Inspire 1 GCS And Its Operat ion.

A complete description of the operation and specifications of the DJI Phantom 3 Professional and DJI Inspire 1 GCS and flight control software is provided at pages 32 through 43 of the DJI Phantom 3
Professional User Manual and pages 40 through 47 of the DJI Inspire 1 User Manual. DJI Phantom 3 Professional and DJI Inspire 1 User Manuals are attached hereto as Appendix s C and D.

b. Flight Operations Of DJI Phantom 3 Professional and DJI Inspire 1 UASs Are Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer.

Realtime Aerial will only utilize certificated pilots who possess a current and valid airman medical certificate to act as a pilot in command (PIC) of the DJI Phantom 3 Professional and DJI Inspire 1 UASs.
Additiona lly, a safety observer will assist all pilots during flight time.

c. Flights Of DJI Phantom 3 Professional and DJI Inspire 1 UASs Will Be Conducted

Pursuant To Specific Operating Limitations.

In seeking this exemption, Realtime Aerial proposes to commercia lly operate DJI Phantom 3 Professional and DJI Inspire 1 UASs for the special purpose of conducting aerial video and photography over certain areas of United States, pursuant to the following specific operating limitations:

1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: DJI
Phantom 3 Professional and DJI Inspire 1 Unmanned Aircraft Systems. Proposed operatio ns of any other aircraft will require a new petition or a petition to amend this grant.FAA Petition for Exemption Realtime Aerial

— June 15 , 2015

Page 15 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 indic ated airspeed exceeding 20 knots.

4. The UAS must be operated at an altitude of no more than 500 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved by ATC. All altitudes reported to ATC must be in feet AGL.

5. The UAS must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on
the PIC’s FAA

- issued airman medical certificate.

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

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the SO can perform the functions prescribed in the operating documents.

8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air
traffic and other ground based obstacles/obstructions and is not permitted to operate the camera or
other instruments.

9. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon requ est. If a discrepancy exists between the conditions and limitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption take precedence and
must be f ollowed. Otherwise, the operator must follow the procedures as outlined in its operating
documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised docum ents to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. If the operator determines that any update or revision would affect the basis upon wh ich the FAA granted the exemption, then the operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS

- 80) may be
contacted if questions arise regarding updates or revisions to the operating documents.

10. Prior t o each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All
maintenance and alterations must be properly documented in the aircraft records.

11. Any UAS that has und ergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the air craft records.FAA Petition for Exemption Realtime Aerial

— June 15 , 2015

Page 16 12. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents.

13. The operator must follow the UAS manufa cturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements.

14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenanc e, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature of the authorized person returning the UAS
to service

. 15. Each UASs operated under this exemption must comply with all manufacturer Safety Bulletins.

16. The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections.

17. T he PIC must possess at least a private pilot certificate and at least a current third

- class medical
certificate.

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to s afely operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hou rs must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator’s PICs are permitted under the terms of the exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 C. F.R. § 91.119.

19. 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 FAA off ice closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized.

20. The UA may not operate within 5 nautical miles of an airport reference point as denoted on a

current FAA

- published aeronautical chart unles s a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s
COA. The letter of agreement with the airport management must be made available to the

A dministrator upon request.

21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

22. If the UA loses communications or loses its GPS signal, it must retur n to a predetermined location within the planned operating area and land or be recovered in accordance with the operating
d ocuments.FAA Petition for Exemption Realtime Aerial

— June 15 , 2015

Page 17 23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating doc uments.

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

25. T he operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requir ements.

26. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (NNumber) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings mu st be as large as practicable.

27. Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirement s.

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 any time the UAS is operating. These documents must be made available to the Administrator or any law enforcement offic ial upon request.

29. The UAS must remain clear and yield the right of way to all manned aviation operations and
activities at all times.

30. The UAS may not be operated by the PIC from any moving device or vehicle.

31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection
and are within 500 feet of the UA, fligh t operations must cease immediately and/or;

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

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

32. All operations shall be conducted over private or controlled

- access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted.FAA Petition for Exemption Realtime Aerial

— June 15 , 2015

Page 18 33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents must be r eported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety.

Realtime Aerial subm its that the equivalent level of safety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI Phantom 3 Professional and DJI Inspire 1 UASs unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements,
that the PIC is able to safely operate the DJI Phantom 3 Professional or DJI Inspire 1 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from peopl e, vessels, vehicles and structures.

Considering Realtime Aerial ’s proposed area of operations, and the operating limitations set forth

above; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirement s (See Exemption No. 11062); and the airmanship skills necessary to safely operate the
DJI Phantom 3 Professional or DJI Inspire 1 UAS, Realtime Aerial submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for Realtime Aerial ’s specific proposed flight operations.

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

Realtime Aerial will not allow any PIC to operate the DJI Phantom 3 Professional or DJI I nspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight

- hour requirements or the DJI Phantom 3 Professional or DJI Inspire 1 UAS training and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 Professional or D JI Inspire 1 UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Specifically, the PIC must have accumulated and logged, in a manner
consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of
5 hours of those hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In addition to the hour requirements, the PIC must accomplish 3
takeoffs and landings in the preceding 90 days (for currency purposes).

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations wi ll ensure an equivalent level of safety during Realtime
Aerial ’s proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as fo llows:

In Exemption No. 11062, the FAA required that prior to conducting operations f or the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi

- rotor UAS. Prior to operations under Exemption No. 11062, theFAA Petition for Exemption Realtime Aerial

— June 15 , 2015

Page 19 PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same
mak e and model of UAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi

- rotor tim e and the 10 hours may be included in the
total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the fl ight

- hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the petitioner’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience

- building flights can also be conducted under the grant of exemption to accomplish the required flight time. During training, proficiency, and exper ience

- building flights the PIC is required to operate the UA with appropriate
distances in accordance with 14 C.F.R 91.119.

Exemption No. 11138 at page 15. Accordingly, Realtime Aerial will ensure safe operations by not allowing any PIC to operate the DJI Phantom 3 Professional or DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely
operate the DJI Phantom 3 Professional or DJI Inspire 1 UAS in a manner consistent with t he exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety.

The equival ent level of safety established by Section 91.7(a) will be maintained because prior to every flight, Realtime Aerial will ensure that the DJI Phantom 3 Professional or DJI Inspire 1 UAS is in an airworthy condition based upon the UAS’s compliance with its operating documents and as stated in the
conditions and limitations herein.

Additionally, the FAA has previously granted relief from 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).

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect
Safet y.

The equivalent level of safety established by Section 91.121 will be maintained because the altitude
information of the DJI Phantom 3 Professional and DJI Inspire 1 UAS will be provided to the PIC via GPS equipment and a radio communications telemetry d ata link, which downlinks from the UA to the GCS for active monitoring of the flight path and altitude. This altitude information, combined with Realtime
Aerial ’s operation of the DJI Phantom 3 Professional and DJI Inspire 1 UAS within visual line of sight , at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically esta blished by the UASs at ground level.FAA Petition for Exemption Realtime Aerial

— June 15 , 2015

Page 20 The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 110 80, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely Affect Safety.

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 spe cifications of the DJI Phantom 3 Professional and DJI Inspire 1 UASs; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, Realtime Aerial will ensure that it will safely operate the battery powered DJI
Phantom 3 Professional and DJI Inspire 1 UAs during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 13.5 min utes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

Here, as in Exemption No. 11109, the technical spe cifications of the DJI Phantom 3 Professional and DJI Inspire 1 UASs; the limitat ions 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 ensured as the DJI Phantom 3 Professional and DJI Inspire 1 UASs provide audible and visual warnings to the PIC at the GCS when the UAS experiences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery power. At the critica lly low battery level, the DJI Phantom 3 Professional and DJI Inspire 1 UASs will descend and land automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

6. Reasons Why An Exemption From The Requirements Of 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 exem ption, Realtime Aerial submits that the equivalent level of safety with regard to the regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because Realtim e Aerial will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., the Realtime Aerial Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Professional and DJI Inspire 1 Instruction Manual).

Furthermore, Realtime Aerial will document and maintain all maintenance records for the DJI Phantom
3 Professional and DJI Inspire 1 UASs. Since the DJI Phantom 3 Profe ssional and DJI Inspire 1 UASs will be inspected as prescribed by the operating documents, Realtime Aerial will maintain the equivalent levelFAA Petition for Exemption Realtime Aerial

— June 15 , 2015

Page 21 of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI Phantom 3
Professio nal and DJI Inspire 1 User Manuals are attached hereto as Appendix C and D; a copy of the DJI
Phantom 3 Professional and DJI Inspire 1 UAS Maintenance LOG is attached hereto as Appendix E.

Likewise, the exemption sought will not adversel y affect safety bec ause Realtime Aerial will use trained technicians to perform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed by the operating documents.

Furthermore, the exemption sought would maintain an equivalent level of safety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI Phantom 3 Professional and DJI Inspire 1 UASs will be performed by trained technicians. Maintenance will be documented and
maintained utilizing the monthly maintenance log. Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS
are considered.

In consideration of Realtime Aerial ’s proposed operating limitations, the operating documents, and the technical aspects of the DJI Phantom 3 Professional and DJI Inspire 1 UASs, Realtime Aerial submits that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted relief specific to UAS in circumstances similar , in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159,11160, 11161).

7. The FAA May Prescribe Any Other Condit ions For Safe Operation.

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Realtime Aerial requests that the FAA prescribe special conditions for the intended operation of the DJI Phantom 3 Professional and DJI Inspire 1 UASs, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that
established b y 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAS for the limited purpose of cond ucting aerial video and photography over certain areas of the UnitedStates for compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a thre at to national security; and further, provides the authority for such UAS to operate
without airworthiness certification in accordance with any requirements that must be established for
the safe operation of the UAS in the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation
of the DJI Phantom 3 Professional and DJI Inspire 1 UASs, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special Conditions, states the following:

If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an a ircraft, aircraft engine, or propeller because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions andFAA Petition for Exemption Realtime Aerial

— June 15 , 2015

Page 22 amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent to that established in the regulations. See 14 C.F.R. § 21.16.

Therefore, in acco rdance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions intended operation of the DJI Phantom 3 Professional and DJI Inspire 1 UASs, which contain such safety standards that the Administrator finds necessary to establis h a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a) (2), and 91.417(a) & (b).

• A Summary That Can Be Published In The Federal Register, stating: The Rules From Which Realtime
Aerial Seeks Exemption:

Realtime Aerial seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a) (2), a nd 91.417(a) & (b).

A Brief Description Of The Nature Of The Exemption Realtime Aerial Seeks:

This exemption will permit Realtime Aerial to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography ov er certain areas of the United States.

• Any Additional Information, Views, Or Arguments Available To Support Realtime Aerial

. This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. As such, Realtime Aerial ’s request for exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above.

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification.

As disc ussed in detail above, Realtime Aerial will operate the DJI Phantom 3 Professional and DJI Inspire 1 UASs safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.

CONCLUSION

As set fo rth herein, Realtime Aerial seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI
Phantom 3 Professional and DJI Inspire 1 UASs commercially, wit hout an airworthiness certificate, for the limited purpose of conducting aerial video and photography over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing
Realtime Aerial to safely, efficiently, and economically operate the DJI Phantom 3 Professional and DJI Inspire 1 UASs commercially within the NAS.

WHEREFOR E , in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, Realtime Aerial respectfully requests that the Administrator grant thisFAA Petition for Exemption Realtime Aerial

— June 15 , 2015

Page 23 Petition for an exemption from the requirements of 14 C.F.R Sectio ns 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a) (2), and 91.417(a) & (b), and permit Leading Edge to operate the DJI Phantom 3 Professional and DJI Inspire 1 UASs commercially for the purpose of conducting aerial video and photography over certain areas of the United States.

Dated: June 8 , 2015

Respectfully submitted,

Realtime Aerial

— Ryan C. Jones, CEO/Co

- owner

_ __ ______________________ Realtime Aerial

— Jason E. Hoffman, COO/Co

- owner

_________________________ Realt ime Aerial

841 Brunellos Avenue

Las Vegas, Nevada 89123

702

- 353

- 5742APP PENDIX

– A

DJI PHANTOM 3 Professional TECHNICAL SPECIFICATIONS

Realtime Aerial only utilizes safe and reliable UASs. DJI is an industry leader in small UAS production. DJI 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

p redetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJI software provides real

- time al titude and location information to the PIC via the linked monitor (smart phone/tablet devices)

.

1.1 DJI Phantom 3 Professional

1.1.1 Aircraft

1.1.1.1 Supported Battery

– DJI 5200mAH LiPo Battery

1.1.1.2 Weight (Battery & Propellers Included)

– 2lbs 11.810o z (1242g)

1.1.1.3 Hover Accuracy (Ready to Fly)

– Vertical: .8m; Horizontal: 2.5m

1.1.1.4 Max Yaw Angular Velocity

- 2000/s

1.1.1.5 Max Tilt Angel

- 350

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; Dynamic: 900mA

1.1.2.2 Control Accuracy

- ±0.030

1.1.2.3 Controllable Range

– Pitch:

- 900

- 00

1.1.2.4 Maximum Angular Speed

– Pitch: 900/s

1.1.3 Camera

1.1.3.1 Operating Temperature Range

- 320F

- 1040F (00C

- 400C)

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

– 1080p & 720p

1 .1.3.6 Recording Field of View

- 1100/8501.1.4 Transmitter

1.1.4.1 Operating Frequency

– 5.72 8GHz

– 5.85GHz

1.1.4.2 Communication Distance (unobstructed)

– FCC Compliance: 800m

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

– 20dBm

1.1.5.4 Power Consumption

– 2WAPPENDIX

– B

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

Realtime Aerial only utilizes safe and reliable UASs. DJI is an industry leader in small UAS production. DJI 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, DJI software provides real

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

. 2.2 DJI Inspire 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 Velocity

– 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 Ti me
– Approximately 18 minutes

2.2.1.12 Motor Model

– DJI 3510

2.2.1.13 Propeller Model

– DJI 1345

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; In Motion: 900mA

2.2.2.4 Angular Vibration Range

- ±0.0302.2.2.5 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 Camera

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 Image Max Size

– 400 0x3000

2.2.3.6 ISO 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): 4096x2160p24/25, 3840x2160p24/25/30; FHD: 1920x1080p24/25/30/48/50/60; HD: 1280x720p24/25/30/48/50/60

2.2.3.10 Operating Temperature Range

- 320F

- 1040F (00C

- 400C)

2.2.4 Transmitter

2.2.4.1 Name

– C1

2.2.4.2 Operating Frequency

– 5.728

- 5.850GHz; 2.400

- 2.483GHz

2.2.4.3 Communicating Distance (unobstructed)

– 2000m

2.2.4.4 Output Power

– 9W

2.2.4.5 Operating Temperature Ran ge

- 140F to 1040F (

- 100C to 400C)

2.2.4.6 Battery

– 600mAh LiPo 2SAPPENDIX

– C

DJI INSPIRE 3 PROFESSIONAL USER MANUALAPPENDIX

– D

DJI INSPIRE 1 USER MANUALAPPENDIX

– E

REALTIME AERIAL MONTHLY MAINTENANCE LOG