Page 1 of 13

May 29

, 2015

U

. S

. Depar t men t o f Transpor t a t ion

Docke t Managemen t Sys t em

1200 New Jersey Ave

., SE Washing t on

, DC 20590

Re : Exemp t ion Reques t under Sec t ion 333 o f t he FAA Re f orm Ac t and Par t 11 o f t he F ederal

Avia t ion R egula t ions

Dear Sir or Madam :

Pursuan t t o Sec t i on 3 3 3 o f t he FAA Moderniza t ion and Re f orm Ac t o f 2012 ( t he “Re f orm A c t ”) and 14

C

. F

. R

. Par t 11

, PKD P hotography t he opera t or o f t he DJI products including the Phantom 2,

Phantom 3, and In spire 1 small U nmanned Aircra ft Sys t ems (“sUAS”) seeks an exemp t ion f rom t he

Federal Avia t ion Regula t ions (“FARs”) lis t ed below and discussed in Append i x A

. User manuals for

t he DJI Phant om 2, DJI Phantom3, and DJI In spi re 1 sUAS are attached in Appendices C through

E

. A tt ached as Ap p endix B i s a summary o f t his reques t.

The reques t ed exemp t ion would permi t P KD Photo graphy commercial opera t ion o f company owned

sUAS : DJI Phantom 2, DJI Phantom3, and DJI Inspire 1 which weighs 2.7 lbs.

, 2.8 lbs. , and 6.5

lbs. , respectively. O n board camera s are used t o per f orm aerial video and photography services

. The sUAS’s cameras produce high quality images and video that is then edi ted and sorted and

combined with images and video taken from land based photography equipment. Applications can

include commercial and residential real estate, aerial survey, mapping, 3D modeling, and general aerial

photography.

Opera t ions under t he exemp t ion will be subjec t t o s t ric t opera t ing requireme n t s and condi t ions t o

ensure a t leas t an equivalen t level o f sa f e t y t o curren t ly au t horized opera t i o ns us i ng ma n ned aircra ft

and under condi t ions as may be modi f ied by t he FAA as required by Sec t ion 333

.

As described more fully below, the requested exemption would authorize PKD Photo graphy to perfor med

commercial operations of aerial video and photography using its company owned sUAS that are small in

size and powered electrically by battery. The sUAS will be operated under controlled conditions at low

altitude in airspace that is limited i n scope, as described more fully herein; it will have automated control

features, as described below. The sUAS is designed to be operated by one person but flight operations

generally involve two people: an operator and an observer. The operator is respons ible for flying the

sUAS, monitoring its status and flight dynamics while maintaining visual line of sight, and keeping the

flight within the specified factory limits (in terms of wind, flight range, battery life, etc. ) to ensure safe

operation of the sUAS itself. The observer is responsible for monitoring the airspace for other aircraft and

hazards and instructing the operator before and during flight as necessary to ensure safe separation/de

confliction with these aircraft and hazards. Fi n ally

, t he airspace in w h ich t he sUAS will opera t e will be

disclosed t o and approved

, as n eeded

, by t he FAA in advance

.

The sUAS that will be operated by PKD Photo graphy 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

.

In consideration of the speed, weight, size, and limited operating area associated with the unmanned

aircraft and its operation, PKD Photography’s operation of DJI Phantom 2 , DJI Phantom 3, and DJIPage 2 of 13

Inspire 1 s UAS 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, PKD Photography 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.

PKD Ph otography submits that the requested relief is proper since an equivalent level of safety will be

ensured. PKD Photography will use experienced personnel or technicians to perform maintenance,

alterations, or preventive maintenance on the s UAS using the me thods, techniques, and practices

prescribed in the operating documents (i.e., DJI Phantom 2 , DJI Phantom 3, and DJI Inspire 1 user

m anual s ). Furthermore, PKD Photography will document and maintain all maintenance records for the

DJI Phantom 2 , DJI Phantom 3, and DJI Inspire 1 s UAS.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and

limitations: Pilot in command , is requested by PKD Photography to the extent necessary to allow a Pilot in

Command (PIC) holdi ng a sport pilot or higher level certificate, as well as an airman medical certificate or

valid driver’s license. PIC must also be able to safely operate the DJI Phantom 2 , DJI Phantom 3, and

DJI Inspire 1 s UAS in a manner consistent with this exemption, including evasive and emergency

maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

PKD Photography requests relief from Section 45.23(b), entitled Marking of the Air craft , as t he DJI

Phantom 2, DJI Phantom 3, or DJI Inspire 1 have no en t rances t o t he cabin

, c o ckpi t, or pilo t s t a t ion

on which t h e mark i ngs c a n be placed

. Given t he size o f t he sUA S

, t wo

- inch le tt er i ng w ill be

impossible

. O f ficial marking sys t ems f or small s U AS have no t ye t been es t ablish e d f or opera t ions

inside t he NA S

. PKD Photo graphy proposes to mark the top of the vehicle with the registration number

with marking as large as practicable.

PKD Photography seeks relief from Section 91.119, entitled M i n i m u m Safe A l t

i tud e s . As se t f or t h

herein

, t he sUAS will never opera t e a t higher t han 5 00 f ee t AGL

. It will

, however

, be opera t ed t o

avoid conges t ed or popula t e d are a s t ha t are depic t ed in yellow on VFR sec t i o nal c h ar t s

. Because

aerial survey

, mapping and inspec t ion work general aerial photography mus t be accomplis h ed a t

rela t ively low al t i t udes and a t al t i t udes less t han 500 f ee t AGL

, an exemp t ion f r o m Sec t ion 91

. 119(c) is

needed

.

PKD Photography asks for relief from Section 91.7(a), entitled Civil aircraft airworthiness , because the

DJI Phantom 2 , DJI Phantom 3, and DJI Inspire 1 s UAS do not require an airworthiness certificate in

accordance with 14 C.F.R. Part 21, Subpart H. As such, PKD Photography submits that it will ensure that

the DJI Phantom 2 , DJI Phantom 3, and DJI Inspire 1 s UAS are in an airworthy condition, prior to every

flight, by determining that the s UAS are in compliance with the operating documents (i.e

. DJI Phantom 2

, DJI Phantom 3, and DJI Inspire 1 user m anual s ), and that the aircraft are in a condition for safe flight.

PKD Photography also seeks an exemption from the requirements of Section 91.121, entitled Altimeter

Settings , as the DJI Phantom 2 , DJI Phantom 3, and DJI Inspire 1 s UA S will not have a typical barometric

altimeter onboard. However, altitude information of the DJI Phantom 2 , DJI Phantom 3, and DJI Inspire 1

s UA S will be provided to the PIC via Global Positioning System (GPS) equipment and radio

communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the

flight path. This altitude information, combined with PKD Photography’s operation of the DJI Phantom 2

, DJI Phantom 3, and DJI Inspire 1 s UAS within visual line of sight, at or below 500 feet AGL, will e nsure a

level of safety equivalent to Section 91.121.

Additionally, PKD Photography seeks an exemption from the requirements of Section 91.151(b), entitled

Fuel requirements for flight in VFR conditions

. PKD Photography submits that safety will not be af fectedPage 3 of 13

by operation of the DJI Phantom 2 , DJI Phantom 3, and DJI Inspire 1 s UA S during daylight hours in

visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly

for a total duration of approximately 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.

Name and address of the Petitioner

P KD Photography

Attn: Patryk Drozd

Ph: 617

- 620

- 4159

Email: patrykdrozd@icloud.com

Address: 1 1 Orchard Street, Apt. 5

Newton, MA 02458

The Specific Sections Of 14 C.F.R. From Which PKD Photography Seeks Exemption.

14 C

. F

. R

. 45

. 23( b ) ;

14 C

. F

. R

. 61

. 11 3 (a) & (b) ;

14 C

. F

. R

. 91

. 7(a ) ;

14 C

. F

. R

. 91

. 11 9 ;

14 C

. F

. R

. 91 .121;

14 C

. F

. R

. 91

. 15 1 (a) ;

14 C

. F

. R

. 91

. 40 5 (a) ;

14C

. F

. R

. 91

. 40 7 (a)(1) ;

14 C

. F

. R

. 91

. 40 9 (a)(2) ;

14 C

. F

. R

. 91

. 41 7 (a)

.

Appendix A discusses each rule lis t ed above and explains why exemp t io n s purs u an t t o t he proposal

se t f or t h in t his le t t er are appr o pria t e

, prov i de an e q uivalen t level o f sa f e t y

, a nd are in t he public

in t eres t

.

Mandatory Operat i ng Con d i t i ons

Gran t o f t he exemp t ion t o PKD Photo graphy will be subjec t t o t he f ollowing mand a t ory condi t ions

, which are based upon opera t ing condi t ions se t f or t h f or opera t ion o f sUAS by publ i c en t i t ies

pursuan t t o Cer t i f ica t es o f A u t horiza t ion

, wi t h ad d i t ional res t ric t ions :

1. Operations authorized by this grant of exemption will be limited to the following aircraft described in

the operating documents, rotorcraft s UAS weighing less than 55 pounds maximum gross weight: DJI

Phantom 2 , DJI Phantom 3, and DJI Inspire

2. s UAS operations under this exemption will be limited to conducting operations for the purpose of

aerial video a nd photography

3. The s UA S may not be flown at a n indicated airspeed not exceeding 85 knots

4. The s UA 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 repo rted to ATC must be in feet AGL

5. The s UA S 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 ot her than corrective lensesPage 4 of 13

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of

sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as

lon g as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate

verbally at all times

7. This exemption and all documents needed to operate the sUAS and conduct its operations in

accordance with the conditions and limitations stated in this grant of exemption, are hereinafter

referred to as the operating documents. The operating documents must be accessible during s UAS

operations and made available to the Administrator upon request. If a discrepancy exists between the

conditions and limitations in this exemption and the procedures outlined in the operating documents,

the conditions and limitations herein take precedence and must be followed. Otherwise, the operator

must follow the procedures as outlined in its operating documents. The operator may update or revise

its operating documents. It is the operator’s responsibility to track such revisions and present updated

and revised documents to the Administrator or any law enforcement official upon request. The

operator must also present updated and revised documents if it petitions for extension or amendment

to this grant of exemption. If the operator determines that any update or revision would affect the

basis upon which the FAA granted this exemption, then the operator must petition fo r an 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

8. The operator is responsible for maintaining and inspecting the s UAS to ensur e that it is in a condition

for safe operation

9. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the s UAS is in a

condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g.,

inope rable components, items, or equipment. If the inspection reveals a condition that affects the safe

operation of the s UAS, the aircraft is prohibited from operating until the necessary maintenance has

been performed and the s UAS is found to be in a conditio n for safe flight

10. The operator must follow the s UAS manufacturer’s aircraft/component, maintenance, overhaul,

replacement, inspecti on, and life limit requirements

11. Each s UAS operated under this exemption must comply with all manufacturer Safety Bulletins

12. The authorized person must make an entry in the aircraft record of the corrective action taken against

discrepancies discovered between inspections

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private,

recreatio nal, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate

or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a

possession, or the Federal Government. The PIC must a lso meet the flight review requirements

specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate

14. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification

criteria and demonstrates the ability to safely operate the s UAS in a manner consistent with how the

s UAS will be operated under the exemption, including evasive and emergency maneuvers and

maintaining appropriate distances from persons, vessels, vehicles and structure s. PIC qualification

flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b)

15. s 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 office closest to proposed area of operations. Flights under

special visual flight rules (SVFR) are n ot authorizedPage 5 of 13

16. The UA may not operate within 5 nautical miles of an airpor t reference point as denoted on a current

FAA

- published aeronautical chart unless a letter of agreement with that airport’s management is

obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s

COA. The letter of a greement with the airport management must be made available to the

Administrator upon request

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a

cloud or when visibility is less than 3 statute miles from the PI C

18. If the UA loses communications or loses its GPS signal, it must return to a predetermined location

within the planned operating area and land or be recovered in accordance with th e operating

documents

19. The PIC must abort the flight in the event of unpre dicted obstacles or emergencies in accordan ce with

the operating documents

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather

conditions) there is enough available power for the UA to conduct the intended operation and to

operate after that for at least 5 minutes or with the reserve power recommended by the manufacturer

if greater

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be

conducted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or

amended COA if it intends to conduct operations that cannot be conducted under the terms of the

original COA

22. All aircraft operated in accordance with the exemption must be identified by serial numbe r, registered

in accordance with 14 C.F.R. part 47, and have identification (N

- Number) markings in accordance

with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable

23. Documents used by the operator to ensure the safe operation and flig ht of the s UAS and any

documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground

Control Station of the s UAS any time the aircraft is operating. These documents must be made

available to the Administrator or any law enfo rcement official upon request

24. The s UA must remain clear and yield the right of way to all manned aviation operati ons and activities

at all times

25. The s UAS may not be operated by the PIC fr om any moving device or vehicle

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 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 operat or must ensure that nonparticipating

persons remain under such protection. If a situation arises where nonparticipating persons

leave such protection and are within 500 feet of the UA, flight operations must cease

immediately in a manner ensuring the safet y of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission for

operating closer to those objects and the PIC has made a safety assessment of the risk of

operating closer to those objects and determ ined that it does not present an undue hazard.

The PIC, VO, operator trainees or essential persons are not consideredPage 6 of 13

27. All operations shall be conducted over private or controlled

- access property with permission from the

land owner/controller or authorize d representative. Permission from land owner/controller or

authorized representative will be obtained for each flight to be conducted

28. 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 reported to the National Transportation Safety

Board

As set forth herein, PKD Photography 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 2, DJI Phantom3, and DJI Inspire 1 sUAS commer cially, without an airworthiness

certificate, for the limited purpose of conducting aerial video and photography over certain areas of the

United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional

mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the

public, by allowing PKD Photography to safely, efficiently, and economically operate the DJI Phantom 2

, DJI Phantom 3, and DJI Inspire 1 s UAS commercially within the NAS.

Very t ruly yours

,

Patryk Drozd

PKD Photography

____________________ Patryk Drozd

11 Orchard Street, Apt. 5

Newton, MA 02458

Tel: 617

- 6 20

- 4159

Appendices :

A

– Exemption Request and Equivalent Level of Safety Showing Under Applicable Rules Subject to

Exemption

B

– Summary of PKD Photography Section 333 Exemption Request

C

– DJI Phantom 2 Manufactur er ’s User Manual

D

– DJI Phantom 3 Manufact u r er ’s Use r Manual

E

– DJI Inspire 1 Manufact u r er ’s User ManualPage 7 of 13

APPEND I X A

EXEMP T I ON R E QUEST AND E QU I VAL E NT L EVEL OF SAFETY SHO W I NGS UNDER

APPL I CAB L E RU L ES S UBJECT TO E XEMPT I ON

PKD Photo graphy reques t s an exemp t ion f rom t he f ollowing regula t ions as well as any addi t ional

regula t ions t ha t may t echnically apply t o t he opera t ion o f its sUAS :

14 C

. F

. R

. § 45

. 23: Ma r k i ng of the A i rcraft

Regula t ion 45

. 23 provides :

(a) E ach opera t or o f an aircra ft mus t displ a y on t ha t aircra ft marks consis t ing o f t h e

Roman capi t al le tt er “N” (deno t ing Uni t ed S t a t es regis t ra t ion) f ollowed by t he regis t ra t ion

number o f t he aircra ft. E ach su f f ix le tt er used in t he marks displayed mus t also be a

Roman capi t al le tt er

. (b) W hen marks i nclude only t he Roman capi t al le tt er “N” and t he regis t ra t ion number is

displayed on limi t ed

, res t ric t ed or ligh t

- spor t ca t egory aircra ft or experimen t al or

provisionally cer t i f ica t ed aircra f t, t he opera t or mus t also disp l ay on t ha t aircra ft near

each e n t rance t o t he cabin

, cockpi t, or pi l o t s t a t ion

, in le t t ers no t less t han 2 inches nor

more t han 6 inches high

, t he words “limi t ed

, ” “res t ric t ed

, ” “ligh t

- spor t, ” “experimen t al

, ” or

“provisional

, ” as applicable

.

The D JI Phantom 2, DJI Phantom 3, or DJI In spire 1 ha ve no en t rance s t o t he cabin

, c o ckpi t, or pilo t

s t a t ion on which t h e mark i ngs c a n be placed

. Given t he size o f t he sUA S

, t wo

- inch le tt er i ng w ill be

impossible

. O f ficial marking sys t ems f or small U AS have no t ye t been es t ablish e d f or opera t ions

inside t he NA S

. PKD Photo graphy proposes to mark the top of the vehicle with the registration number

with marking as large as practicable

.

14 C

. F

. R

. § 61

. 113(a) & (b) : Pr i vate P i l ot P r i v il eges and L i m i tat i o ns; P i l ot i n

Command

.

Sec t ion 61

. 113(a) & (b) limi t priv a t e pilo t s t o non

- commercial opera t ions

. Unlike a conven t ional aircra ft

t ha t carries a pilo t, passengers

, and cargo

, t he DJI Pha ntom 2, DJI Phantom 3, and DJI In spire One

are in t his case remo t ely con t rolled wi t h no passengers or p roper t y o f o t hers on board

. Sec t ion

61

. 133(a) requires an individual wi t h a commercial pilo t ’s license t o be pilo t in command o f an

aircra ft f or compensa t ion or hire

. PKD Photography r espec t f ully proposes t ha t opera t or

requiremen t s sho u ld t ake in t o accoun t t he charac t eris t ics o f t he par t icular sUAS

.

PKD Photography respec t f ully proposes to allow a Pilot in Command (PIC) holding a sport, recreational,

private pilot or higher level certificate, as well as an airman medical certificate or valid driver’s license to

operate the sUAS. And that the PIC is able to safely operate the DJI Phantom 2 , DJI Phantom 3, and DJI

Inspire 1 s UAS in a manner consistent with this exemption, including evasive and emergency maneuvers

and maintaining appropriate distances from people, vessels, vehicles and structure s.

14 C

. F

. R

. § 91

. 7(a): C i v il a i rcraft a i r w orth i ness

.

This regula t ion requires t ha t no person may opera t e a civil aircra f t unless i t is in airwor t hy condi t ion

. Due to the fact that the DJI Phantom 2, DJI Phantom 3, and DJI Inspire 1 s UAS do not require an

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, PKD Photography

submits that it will ensure that the DJI Phantom 2, DJI Phantom 3, and DJI Inspire 1 sUAS are in anPage 8 of 13

airworthy condition, prior to every flight, by determining that the UASs are in compliance with the

operating documents (i.e., DJI Phantom 2, DJI Phantom 3 , and DJI Inspire 1 user m anual s ), and that the

aircraft are in a condition for safe flight.

14 CFR § 91

. 119: M i n i m u m Safe A l t i tud e s

Sec t ion 91

. 119 es t abl i shes s a f e al t i t udes f or opera t i on o f civil aircra ft. Speci f ically

, 91

. 119(c) limi t s

aircra ft f lying over areas o t her t han conges t ed areas t o an al t i t ude o f 500 f ee t a bove t he sur f ace

,

excep t over open wa t er or sparsely popula t ed areas

. I n t hose cases

, t he aircra ft may no t be opera t ed

closer t han 500 f ee t t o any person

, vessel

, v e hicle

, or s t ruc t ure

.

As se t f or t h herein

, t he sUAS will never opera t e a t higher t han 5 00 f ee t AGL

. It will

, however

, be

opera t ed t o avoid conges t ed or popula t e d are a s t ha t are depic t ed in yellow on VFR sec t i o nal c h ar t s

. Because aerial survey

, mapping and inspec t ion work mus t be accomplis h ed a t rela t ively low al t i t udes

and a t al t i t udes less t han 500 f ee t AGL

, an exemp t ion f r o m Sec t ion 91

. 119(c) is needed

.

The equivalen t level o f sa f e t y wi l l be achi e ved g iven t he size

, weigh t, speed

, and ma t erial wi t h which

t he DJI Phantom 2, DJI Phantom 3, and DJI Inspire 1 are buil t. Als o

, no f ligh t will be t aken wi t hou t t he

permission o f t he land owner or t hose who c o n t rol t he land

. Because o f t he a dvance no t ice t o t he

landowner

, all a f f ec t ed individuals will be aware o f t he f ligh t s

. Compar e d t o aerial survey

opera t ions conduc t ed wi t h aircra f t or ro t orcra ft weighing f ar more t han 6 lbs

. and carrying

f lammable f uel

, any risk assoc i a t ed wi t h t hese opera t ions will be f ar less t han t hose curren t ly allowed

wi t h conve n t ional aircra ft opera t i n g a t or be l ow 5 00 f ee t AGL

. I ndeed

, t he low

- al t i t ude opera t i ons o f

t he sUAS will main t ain separa t ion be t ween t hese sUAS opera t ions and t he o p era t ions o f

conven t ional aircra ft t ha t m u s t comply wi t h S ec t ion 91

. 1 19

.

14 CFR § 91 .121 : Altimeter Settings

Section 91.121 requires that each person operating an aircraft shall maintain cruising altitude or flight

level by reference to an altimeter that is appropriately set to the specified source..

T he DJI Phantom 2, DJI Phantom 3, and DJI Inspire 1 sUAS will not have a typical barometric altimeter

onboard. However, altitude information of the DJI Phantom 2, DJI Phantom 3, and DJI Inspire 1 sUAS will

be provided to the PIC via Global Positioning System (GPS) equipment and radio communications

telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This

altitude information, combined with PKD Photograp hy’s operation of the DJI Phantom 2 , DJI Phantom 3,

and DJI Inspire 1 s UAS within visual line of sight, at or below 500 feet AGL, will ensure a level of safety

equivalent to Section 91.121.

14 C

. F

. R

. § 91

. 151(a): F ue l Re q u i rements for F li ght i n V FR C o nd i t i o n s

This regula t ion prohibi t s an individual f rom beginning “a f ligh t in an airplane under VFR cond i t ions

unless (considering wind and f orecas t wea t her condi t ions) t here is enough f uel t o f ly t o t he f irs t poin t o f

in t ended landing and

, assuming normal cruising speed

– (1) During t he day

, t o f ly a ft er t ha t f or a t leas t

30 minu t es ; or (2) A t nigh t, t o f ly a ft er t ha t f o r a t leas t 45 minu t es

. ”

PKD Photography submits that safety will not be affected by operation of the DJI Phantom 2 , DJI

Phantom 3, and DJI Inspire 1 s UA S during daylight hours in visual meteorological conditions (VMC)

under visual flight rules (VFR), with enough battery power to fly for a total duration of approximately 13.5Page 9 of 13

minutes to the first point of intended landing and, assumin g normal cruising speed, to fly after that for at

least 4.5 minutes.

The FAA has gran t ed similar exemp t ions t o o t hers

, including Ex e mp t ions 2689F

, 5745

, 10673 and

10808

.

14 C

. F

. R

. § 91

. 405(a); 407( a )(1); 409(a)(2); 417(a): Ma i nt e nance I nspect i o n s

Sec t ion 91

. 405(a) requires t h a t an aircra ft opera t or or owner “shall have t ha t aircra f t inspec t ed as

prescribed in subpar t E o f t his par t and shall be t w een r e quired inspec t ions

, excep t as provided in

paragraph (c) o f t his sec t ion

, have discrepancies repaired as prescribed in par t 43 o f t his chap t er

... ”

Sec t ion 91

. 407 similarly makes re f ere n ce t o requiremen t s in Par t 43 ; Sec t ion 91

. 409(a)(2) requires an

annual inspec t ion f or t he issuance o f an air wor t h i ness cer t i f ica t e

. S e c t ion 91

. 417(a) requires t he

owner or o p era t or t o keep records showing cer t ain main t enance work t ha t has been accomplished by

cer t i f ica t ed mechanics

, und e r P ar t 43

, or licensed pilo t s and records o f approval o f t he a i rcra ft f or

re t urn t o service

.

PKD Photography requests relief from these sections as they set forth requirements for maintenance that

only apply to aircraft with an airworthiness certificate.

PKD Photography submits that the request is proper since an equivalent level of safety will be ensured.

PKD Photo will use experienced personnel or technicians to perform maintenance, alterations, or

preventive maintenance on the s UAS using the methods, techniques, and practices prescribed in the

operating documents (i.e., DJI Phantom 2 , DJI Ph antom 3, and DJI Inspire 1 user m anual s ). Furthermore,

PKD Photography will document and maintain all maintenance records for the DJI Phantom 2, DJI

Phantom 3, and DJI Inspire 1 s UAS.Page 10 of 13

APPEND I X B

SUMMARY O F PKD PHOTOGRAPHY S ECT I ON 333 E XEMPT I ON RE Q UEST

PKD Photo graphy hereby provides pursuan t t o Par t 11 a summary o f i t s ex e mp t ion

applica t ion t o allow commercial opera t ion o f t he DJI Pha ntom 2, DJI Phantom 3, and DJI In spire 1

small unma n ned sys t em in aerial video and photography applications

. An exemp t ion is reques t ed

f rom t he f ollow i ng regula t ions :

14 C

. F

. R

. 45

. 23( b ) ;

14 C

. F

. R

. 61

. 11 3 (a) & (b) ;

14 C

. F

. R

. 91

. 7(a ) ;

14 C

. F

. R

. 91

. 11 9 ;

14 C

. F

. R

. 91. 121;

14 C

. F

. R

. 91

. 15 1 (a) ;

14 C

. F

. R

. 91

. 40 5 (a) ;

14 C

. F

. R

. 91

. 40 7 (a)(1) ;

14 C

. F

. R

. 91

. 40 9 (a)(2) ;

14 C

. F

. R

. 91

. 41 7 (a)

.Page 11 of 13

APPEND I X C



### DJI PHANTOM 2 MANUFACTURER’S USER MANUALPage 12 of 13

APPEND I X D



### DJI PHANTOM 3 MANUFACTURER’S USER MANUALPage 13 of 13

APPEND I X E



### DJI INSPIRE 1 MANUFACTURER’S USER MANUAL