August 24, 2015

US Department of Transportation Docket management System 1200 New Jersey Ave., SE Washington, DC 20590

RE: Exemption request under Section 333 of the FAA Rreform Act and Part 11 of the Federal Aviation Regulations.

Dear Sir or Madam:

Pursuant to Section 333 of the FAA modernization and Reform Act of 2 012 (the "Reform Act") and 14 C.F.R. part 11, Diebold Resources, LLC (the "Ope rator") of the DJI products including the Phantom 2 (Standard and Vision Plus V+), Phantom 3 (Standard, Advanced and Professional), and Inspire 1 small Unmanned Aircraft Systems ("sUAS") seeks and exemption fro the Federa l Aviation Regulations ("FARs") listed below and discussed in Appendix A. User manu als for the DJI Phantom 2 (Standard and Vision Plus V+), DJI Phantom 3 (Standard, Advanced and Professional), and DJI inspir e 1 sUAS are attached in Appendices C through E. Attached as Appendix B is a summary of this request.

The requested exemption would permit Diebold Res ources, LLC commercial ope ration of company owned sUAS: DJI Phantom 2 (Standard and Vision Plus V+), DJI Phantom 3 (Standard, Ad vanced and Professional), and DJI inspire 1 which weigh 2.7 lbs, 2.8 lbs, and 6.5 lbs respectively. O nboard cameras are used to perform aerial video and photography services. the sUAS's camera s produce high quality images and video that is then

edited and sorted and combined w ith images and video taken from land based photography equipment. Applications can include commercial and residential real estate, aerial survey, mapping, 3D modeling, general aerial photography, and f light training.

Operations under the exemption will be sugject to strict operati ng requirements and conditions to ensure at least an equivelant level of safety to currently authorized operations using manned airc raft and under conditions as may be modified by the FAA as required by Section 333.

As described more fully below, the requested exem ption would authorize Die bold Resources to perform commercial operations of aerial video and photography usin g it's company owned sUAS that are small in size and powered electrically by battery. The sUAS will be operated under controll ed conditions at low altitude in airspace that is limited in scope, as described more fully herein; it will ha ve automated control features, as described below. the sUAS is designed to be operated by one person but flight operat ions generally involve two people: an operator and an observer. The operator is responsible for fl ying the sUAS, monitoring it's status and flight dynamics while maintaining visual line of sight (vLOS), and keeping the f light within the specified factory limitations (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 w ith other aircraft and hazards . Finally, the airspace in which the sUAS will operate will be disclosed to and approved, as needed, by the FAA in advance.

Page 1 of 14The sUAS that will be operated by Diebold Resources 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 it's operation, Diebold Resources' operation of DJI Phanto m 2 (Standard and Vision Plus V+), DJI Phantom 3 (Standard, Advanced and Professional), and DJI inspire 1 sUAS meets the conditions of FMRA Section 333 and therefore, will not require an airwor thiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, Diebold Resources re quests relief from Sections 91.405( a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections se t forth requirements for maintenance th at only apply to aircraft with an

airworthiness certificate.

Diebold Resources submits that the requested relief is proper since and equivalent level of safety will be ensured. Diebold Resources will use experienced personne l or technicians to perfor m maintenance, alterations, or preventive maintenance on the sUAS using the methods, techniques, and practices pr escribed in the operating documents (i.e., of DJI Phantom 2 (Standard and Visi on Plus V+), DJI Phantom 3 (Standard, Advanced and Professional), and DJI inspire 1 user manuals). Furthe rmore, Diebold Resources wi ll document and maintan all maintenance records for the of DJI Phantom 2 (Standa rd and Vision Plus V+), DJI Phantom 3 (Standard, Advanced and Professional), and DJI inspire 1 sUAS.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privil eges and limitations:

Pilot in command , is requested by Diebold Resources to the ex tent necessary to allow a Pilot in Command (PIC) holding a sport pilot or higher cer tificate, as well as an airman medical certificate or valid driver's license. The PIC must also be able to safely operate the of DJI Phantom 2 (Standa rd and Vision Plus V+), DJI Phantom 3 (Standard, Advanced and Professional), and DJI inspir e 1 sUAS in a manner consis tent with this exemption, including evasive and emergency maneuve rs and maintaing appropriate distan ces from people, vessels, vehicles

and structures.

Diebold Resources requests relief from Section 45.23(b), entitled Marking of the Aircraft , as the DJI Phantom 2 (Standard and Vision Plus V+), DJI Phantom 3 (Standar d, Advanced and Professional) , and DJI inspire 1 have no entrances to the cabin, cockpit, or pilot station on which the markings can be placed. Given the size of the sUAS, two-inch lettering will be impossible. Official marking systems for small sUAS have not yet been established for operations inside the NAS. Diebold Resources propos es to mark the top of the vehicle with the registration number with marking as large as practicable.

Diebold Resources seeks relief from Section 91.119, entitled Minimum Safe Altitudes . As set forth herein, the sUAS will never operate at higher th an 500 feet AGL. It will, however, be operated to avoid congested or populated areas that are depicted in yellow on VFR sectional charts. B ecause aerial survey, mapping and inspection work general aerial photography must be accomplishe d at relatively low altitudes and at altitudes less than 500 feet AGL, an exemption fr om Section 91.119(c) is needed.

Diebold Resources asks for relief from Section 91.7(a), entitled Civil aircraft airworthiness , because the DJI Phantom 2 (Standard and Vision Plus V+), DJI Phantom 3 (Standard, Advanced a nd Professional), and DJI inspire 1 sUAS do not require an airw orthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As

such, Diebold Resources submits that it will ensure that the DJI Phantom 2 (Standard and Vision Plus V+), DJI

Page 2 of 14Phantom 3 (Standard, Advanced and Professional), and DJ I inspire 1 sUAS are in an airworthy condition, prior to every flight, by determining that the sUAS are in compliance with the operating documents (i.e. DJI Phantom 2 (Standard and Vision Plus V+), DJI Phantom 3 (Standard , Advanced and Professional), and DJI inspire 1 user manuals), and that the aircraft ar e in a condition for safe flight.

Diebold Resources also seeks an exemption fr om the requirements of Section 91.121, entitled Altimeter

Settings , as the DJI Phantom 2 (Standard and Vision Plus V+), DJI Phantom 3 (Standard, Advanced and Professional), and DJI inspire 1 sUAS will not have a t ypical barometric altimeter onboard. However, altitude information of the DJI Phantom 2 (Standard and Visi on Plus V+), DJI Phantom 3 (Standard, Advanced and Professional), and DJI inspire 1 sUAS will be provide d 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 Diebold Resources' operation of DJI Phantom 2 (Standard and Vision Plus V+), DJI Phantom 3 (Standard, Advanced a nd Professional), and DJI inspire 1 sUAS within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to

Section 91.121.

Additionally, Diebold Resources seek s an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions Diebold Resources submits that safety will not be affected by operation of the DJI Phantom 2 (Standard and Vision Plus V+), DJI Phantom 3 (Standard, Advanced and Professional), and DJI inspire 1 sUAS during daylight hours in visual meteorolog ical conditions (VMC) under visual flight rules (VFR), with enoug h battery power to fly for a total du ration of approximately 13.5 minutes to the first point of intended landing and, assuming normal cr uising speed, to fly after th at for at least 4.5 minutes.

Name and address of the Petitioner:

Diebold Resources

Attn: Darin Diebold

4604 Games Trail

Minnetrista, MN 55375 612.208.3766 (c) darin.diebold@gmail.com

The Specific Sections Of 14 C.F.R. From Wh ich Diebold Resources Seeks Exemption.

14 C.F.R. 45.23(b); 14 C.F.R. 61.113(a) & (b); 14 C.F.R. 91.7(a);

14 C.F.R. 91.119;

14 C.F.R. 91.121; 14 C.F.R. 91.151(a); 14 C.F.R. 91.405(a); 14C.F.R. 91.407(a)(1); 14 C.F.R. 91.409(a)(2); 14 C.F.R. 91.417(a).

Page 3 of 14Appendix A discusses each ru le listed above and explains why exempti ons pursuant to the proposal set forth in this letter are appropriate, provide an equivalent level of safet y, and are in the public interest.

Mandatory Operating Conditions:

Grant of the exemption to Diebold Resources will be subject to the following mandatory conditions, which are based upon operating conditions set forth for operation of sUAS by public entitie s pursuant to Certificates of

Authorization, with add itional restrictions:

1. Operations authorized by this grant of exemption w ill be limited to the following aircraft described in the operating documents, rotorcraft sUAS weighing less than 55 pounds maximum gross weight: DJI Phantom 2 (Standard and Vision Plus V+), DJI Phantom 3 (Standa rd, Advanced and Professi onal), and DJI inspire 1.

2. sUAS operations under this exempti on will be limited to conducting oper ations for the purpose of aerial video and photography.

3. The sUAS may not be flown at an i ndicated airspeed not exceeding 85 knots

4. The sUAS 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 sUAS 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.

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 long as the PIC always maintains VLOS capability. The VO and PIC mu st be able to communicat e 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 accessibl e during sUAS operations and made available to the Administrator upon request. If a discre pancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the c onditions and limitations here in take precedence and must be followed. Otherwise, the operator must follo w 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 re vised documents if it petitions for extension or amendment to this grant of exempti on. If the operator determin es that any update or re vision would affect the basis upon which the FAA granted this exemption, then the operator must petition for 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 mainta ining and inspecting the sUAS to ensure that it is in a condition for safe operation.

Page 4 of 149. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the sUAS is in a condition for safe flight. The pre-flight inspection must account for all potential discrepancies, e.g., inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the sUAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the sUAS is found to be in a condition for safe flight.

10. The operator must follow the sUAS manufacturer ’s aircraft/component, maintenance, overhaul, replacement, inspection, a nd life limit requirements.

11. Each sUAS operated under this exemption must co mply with all manufacturer Safety Bulletins.

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

13. Under this grant of exemption, a PIC must hold either an air line transport, commercial, private, recreational, 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 Ric o, a territory, a posse ssion, or the Federal Government. The PIC must also 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 unle ss the PIC meets the operato r’s qualification criteria and demonstrates the ability to safely operate the s UAS in a manner consistent with how the sUAS will be operated under the exemption, incl uding evasive and emergency maneuv ers and maintaining appropriate distances from persons, vessels, vehicl es and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b).

15. sUAS 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 f light at night is required, a special request will be made at the FAA office closest to propos ed area of operations. Flights under special visual flight rules (SVFR)

are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point as denoted on a current FAApublished aeronautical chart unless a le tter of agreement with that airpor t’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 Ad ministrator upon request.

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

18. If the UA loses communications or lo ses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovere d in accordance with the operating documents.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents.

Page 5 of 1420. The PIC is prohibited from beginning a flight unle ss (considering wind and forecast weather conditions) there is enough available power for the UA to conduct th e intended operation and to op erate after that for at least 5 minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Cer tificate of Waiver or Authoriza tion (COA). All operations shall be

conducted in accordance with an ATO-issued COA. Th e exemption holder may apply for a new or amended COA if it intends to conduct operatio ns that cannot be conducted under th e terms of the original COA.

22. 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 (N- Number) mark ings 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 flight of the sUAS 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 sUAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

24. The sUA must remain clear and yield the right of wa y to all manned aviation opera tions and activities at all

times.

25. The sUAS may not be operated by the PIC from any moving devi ce or vehicle.

26. All Flight operations must be conducted at leas t 500 feet from all nonpartic ipating persons, vessels,

vehicles, and stru ctures unless:

a. Barriers or structures are presen t that sufficiently prot ect nonparticipating persons from the UA and/or debris in the event of an accident. The operator mu st ensure that nonparticipating persons remain under such protection. If a situation aris es where nonparticipating persons leav e such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has gr anted permission for operating closer to those objects and the PIC has made a safety assessmen t of the risk of operati ng closer to those objects

and determined that it does not present an undue hazard.

*The PIC, VO, operator trainees or essential persons are not considered.

27. All operations shall be conducted ove r private or controlled-access prope rty with permission from the land

owner/controller or author ized 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 late ral or vertical boundaries of the operational area as defined by the app licable COA must be reported to th e FAA's UAS Integration Office (AFS80) within 24 hours. Accidents must be reporte d to the National Transportation Safety Board

Page 6 of 14As set forth herein, Diebold Resource s seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), whic h will permit safe operation of the DJI Phantom 2 (Standard and Vision Plus V+), DJI Phantom 3 (Standar d, Advanced and Professional) , and DJI inspire 1 sUAS commercially, without an airworthin ess 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 Moderniz ation and Reform Act of 2012, while also advancing the interests of the public, by allowing Diebold Resources to safely, efficiently, and economically operate the DJI Phantom 2 (Standard and Vision Plus V+), DJI Ph antom 3 (Standard, Advanced and Professional), and DJI inspire 1 sUAS commercially within the NAS.

Respectfully submitted,

/e/ Darin Diebold

Darin Diebold

Diebold Resources, LLC

4604 Games Trail

Minnetrista, MN 55375

612.208.3766

Appendices:

A – Exemption Request and Equivalent Level of Safety Showing Under Appli cable Rules Subject to Exemption B – Summary of Diebold Resources Section 333 Exemption Request

C – DJI Phantom 2 Manufacturer’s User Manual

D – DJI Phantom 3 Manufacturer’s User Manual E – DJI Inspire 1 Manufacturer’s User Manual

Page 7 of 14APPENDIX A

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SA FETY SHOWINGS UNDER

APPLICABLE RULES SUBJ ECT TO EXEMPTION

Diebold Resources requests an exemption from the followi ng regulations as well as any additional regulations that may technically apply to the operation of its sUAS:

14 C.F.R. § 45.23: Marking of the Aircraft

Regulation 45.23 provides: (a) Each operator of an aircraft must display on that aircraft marks consisting of the Roman capital letter “N” (denoting United States registration) followed by the registration number of the aircraft. Each suffix letter used in the marks displayed must also be a Roma n capital letter. (b) When marks include only the Roman capital letter “N” and the registration number is displayed on limited, restricted or light-sport categ ory aircraft or experi mental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in

letters not less than 2 inches nor mo re than 6 inches high, the words “ limited,” “restricted,” “light-sport,” “experimental,” or “provi sional,” as applicable.

The DJI Phantom 2 (Standard and Vision Plus V+), DJI Phantom 3 (Standard, Advanced and Professional), and DJI inspire 1 have no entrances to th e cabin, cockpit, or p ilot station on which the markings can be placed. Given the size of the sUAS, two-inch lettering will be im possible. Official marking systems for small UAS have not yet been established for operati ons inside the NAS. Die bold Resources 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): Private Pilot Privil eges and Limitations; Pilot in Command.

Section 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a conventional aircraft that carries a pilot, passengers, and cargo, the Phantom 2 (S tandard and Vision Plus V+), DJI Phantom 3 (Standard, Advanced and Professional), and DJI inspire 1 are in this case remotely controlled with no passengers or property of others on board. Section 61.133(a) requires an individual with a commercial pilot’s license to be pilot in command of an aircraft for compensation or hire . Diebold Resources respectfu lly proposes that operator requirements should take into account the ch aracteristics of the particular sUAS.

Diebold Resources respectfully propos es 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 Phantom 2 (Standard and Vision Plus V+), DJI Phantom 3 (Standard, Advanced and Professional), and DJ I inspire 1 sUAS in a manne r consistent with this exemption, including evasive and emer gency maneuvers and maintaining a ppropriate distances from people,

vessels, vehicles and structures.

14 C.F.R. § 91.7(a): Civil aircraft airworthiness.

Page 8 of 14This regulation requires that no person may operate a civil aircraft unless it is in ai rworthy condition. Due to the fact that the Phantom 2 (Standard an d Vision Plus V+), DJI Phantom 3 (S tandard, Advanced and Professional), and DJI inspire 1 sUAS do not require an airworthin ess certificate inaccordance with 14 C.F.R. Part 21, Subpart H. As such, Diebold Resources submits that it will ensure that the Phantom 2 (Standard and Vision Plus V+), DJI Phantom 3 (Standard, Advanced and Professiona l), and DJI inspire 1 s UAS are in an airworthy condition, prior to every flight, by de termining that the UASs are in comp liance with the operating documents (i.e., DJI Phantom 2, DJI Phantom 3, and DJI Inspire 1 user manuals), and that the airc raft are in a condition for safe flight.

14 CFR § 91.119: Minimu m Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, 91.119(c) limits aircraft flying over areas other than congested ar eas to an altitude of 500 feet above the surfa ce, except over open water or sparsely populated areas. In thos e cases, the aircraft may not be operate d closer than 500 feet to any person,

vessel, vehicle, or structure.

As set forth herein, the sUAS will ne ver operate at higher than 500 feet AGL . It will, however, be operated to avoid congested or populated areas that are depicted in yellow on VFR sectio nal charts. Because aerial survey, mapping and inspection work must be acco mplished at relatively low altitudes and at altitudes less than 500 feet AGL, an exemption from Sec tion 91.119(c) is needed.

The equivalent level of safety will be achieved given the size, weight, speed, and material with which the DJI Phantom 2, DJI Phantom 3, and DJI Inspire 1 are built. Als o, no flight will be taken w ithout the permission of

the land owner or those who control the land. Because of the advance notice to the landowner, all affected

individuals will be aware of the flights. Compared to aerial survey operations conducted with aircraft or rotorcraft weighing far more than 6 lb s. and carrying flammable fuel, any ri sk associated with these operations will be far less than those currently allowed with c onventional aircraft operating at or below 500 feet AGL. Indeed, the low-altitude operations of the sUAS will maintain separation between these sUAS operations and the operations of conventional aircraft that must comply with Section 91.119.

14 CFR § 91.121: Altimeter Settings

Section 91.121 requires that each person operating an aircraft shall maintain cruising a ltitude or flight level by reference to an altimeter that is appr opriately set to the specified source.

The DJI Phantom 2, DJI Phantom 3, and DJI Inspire 1 s UAS will not have a typical barometric altimeter

onboard. However, altitude information of the DJI Phanto m 2, DJI Phantom 3, and DJI Inspire 1 sUAS will be provided to the PIC via Global Positi oning System (GPS) equipment and ra dio communications telemetry data

link, which downlinks from the UA to the GCS for act ive monitoring of the flight path. This altitude information, combined with Diebold Resources's ope ration of the DJI Phantom 2, DJI Phantom 3, and DJI Inspire 1 sUAS 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): Fuel Requirement s for Flight in VFR Conditions

Page 9 of 14This regulation prohibits an individual from beginni ng “a flight in an airplane 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 – (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.”

Diebold Resources submits that safety will not be a ffected by operation of the DJI Phantom 2, DJI Phantom 3, and DJI Inspire 1 sUAS during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough ba ttery power to fly for a total duration 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.

The FAA has granted similar exemptions to ot hers, including Exemptions 2689F, 5745, 10673 and 10808.

14 C.F.R. § 91.405(a); 407(a )(1); 409(a)(2); 417 (a): Maintenance Inspections

Section 91.405(a) requires that an aircra ft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall betw een required inspections, except as provi ded in paragraph (c ) of this section, have discrepancies repaired as prescribed in part 43 of this chap ter ...” Section 91.407 similarly makes reference to requirements in Part 43; Sect ion 91.409(a)(2) requires an annual insp ection for the issuance of an air

worthiness certificate. Section 91.417 (a) requires the owner or operator to keep records showing certain maintenance work that has been accomplished by certificat ed mechanics, under Part 43, or licensed pilots and records of approval of the aircra ft for return to service.

Diebold Resources requests relief from these sections as they set forth requirements for maintenance that only apply to aircraft with an airworthin ess certificate. Diebold Resources submits that the request is proper since an equivalent level of safety will be ensured. Diebold Re sources will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the sUAS using the methods, techniques, and practices prescribed in the operati ng documents (i.e., DJI Phantom 2, DJI Phantom 3, and DJI Inspire 1 user manuals). Furthermore, Diebold Res ources will document and maintain all maintenance records for the DJI Phantom 2, DJI Phantom 3, and DJI Inspire 1 sUAS.

Page 10 of 14APPENDIX B:

SUMMARY OF DIEBOLD RESOURCES SECTION 333 EXEMPTION REQUEST

Diebold Resources hereby provides pu rsuant to Part 11 a summary of its exemption application to allow commercial operation of the DJI Phantom 2, DJI Phantom 3, and DJI Inspire 1 small unmanned system in aerial video and photography applications. An exemption is requested from the following regulations:

14 C.F.R. 45.23(b); 14 C.F.R. 61.113(a) & (b); 14 C.F.R. 91.7(a);

14 C.F.R. 91.119; 14 C.F.R. 91.121; 14 C.F.R. 91.151(a); 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409(a)(2); 14 C. F.R. 91.417(a).

Page 11 of 14APPENDIX C:

DJI PHANTOM 2 MANUFACTURER'S USER MANUAL

Page 12 of 14APPENDIX D:

DJI PHANTOM 3 MANUFACTURER'S USER MANUAL

Page 13 of 14Page 14 of 14 APPENDIX E:

DJI INSPIRE 1 MANUFA CTURER'S USER MANUAL