1 UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC

Regulatory Docket No.

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: Altiora Media, LLC FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 1 4 OF THE CODE OF FEDERAL REGULATION S SECTIONS 61.101(e)(4) & (5), 61.113(a) & (b), 61.23(a), 61.315(a), 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 INSPIRE 1 UNMANNE D AIRCRAFT SYSTEM S PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95 )

Submitted on May 11, 2015 Daniel O. Montaño/Altiora Media, LLC 37 Vista Alegre Belen, NM 87002 Tel: (505)450

- 7123 Email: daniel@neonbuffalo.co m2 TABLE OF CONTENTS Pag e

GLOSSARY OF ABBREVIATIONS ..................................................................................3

SUMMARY ................................................................................................................ ..........4

INTRODUCTION AND INTERESTS OF PETITIONER....................................................4

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

BASIS FOR PETITION... ..................................................................................................... 5

NAME AND ADDRESS OF PETITIONER. ........................................................... 8

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH ALTIORA MEDI A , LLC SEEKS EXEMPTION................................................. 8

THE EXTENT OF RELIEF ALTIORA MEDIA , LLC SEEKS AND THE REASON ALTIORA MEDIA , LLC SEEKSTHE RELIEF................1 2

THE REASONS WHY GRANTING ALTIORA MEDIA , LLC’S REQUEST WOULD BE IN THE PUBLI C INTEREST ..................................... 1 7

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY ......................................................................... 20

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER. ... . 3 4

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO

SUPPORT ALTIORA MEDIA , LLC’S REQUEST.... .............3 4

CONCLUSION ..........................................................................................................

.................. 343 GLOSSARY OF ABBREVIATIONS AGL Above G round 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 Regula tion 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 Modernization and Reform Act of 2012 (FMRA) Section 333 SO Safet y 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 Landing4 SUMMARY Daniel O. Montaño seeks exemption from the requirements of 14 C.F.R §§ 61.101(e)(4) and (5), 61.315(a), 61.23(a), 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 Aircra ft System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Feather Light Media LLC to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting

a erial video and photography of forestry project sites, wildfire zones, construction sites, building inspection s, agricultural lands, outdoor recreational facilities, real estate, special events, and landscapes within the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

A ltiora Media, LLC will provide its clients with the highest quality digital content for use in their commercial, personal, and non

- profit multimedia projects. Altiora Media, LLC will bring together years of professional marketing expertise, award

- winning p roduction talent and state

- of

- the

art technology to make studio quality productions within reach for organizations of any size. Altiora

Media , LLC will also leverage years of professional forestry, fire, and film experience to become a leading provider of geomapping and image analysis services to the forestry and environmental monitoring industries. Altiora Media , LLC has over 2 0 years commercial experience in all aspects of forestry/fire and 15 years in the film industry . The objective of Altiora Media , LL C aerial video and photography operations is to provide high quality imaging for a variety of commercial, public, and residential uses, specifically targeting:

• Aerial event filming and photography

• Feature film and Documentary cinematography

• Promotional v ideos for businesses, non

- profits & government entities

• Agricultural surveys and environmental monitoring

• Forestry/land surveys and documentation5 BACKGROUND Unmanned Aircraft Systems: DJI Inspire 1 UAS

Altiora Media , LLC seeks an exemption to operate DJI systems for compensation or hire within the NAS. The DJI Inspire 1 (Inspire 1) is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The Inspire 1 is an electric powered rotary wing UAS that is capable of transmitting live airborne video images and location information to a Ground Control Station (GCS). The Inspire stores the photographs and data on board and makes them available for download after complet ion of the flight. The Inspire is 22 in x 22 in x 8 in and weighs 6.4 pounds, well under the 55 lbs mandated in the FMRA. The Inspire can conduct hovering flight and has a maximum cruising speed of 42 knots. It is battery powered, has a flight endurance of 22 minutes and can operate in temperatures ranging from 0° to 40° C. The Inspire’s omni

- directional antenna has a range of 2.1 km and operates

in the 2.420

– 2.483 GHz frequency range. The Inspire 1 that will be operated by Altiora Media , LLC will be reg istered 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, Altiora Me dia , LLC, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereby petitions the

Administrator to co mmercially operate the DJI Inspire 1 in the National Airspace System (NAS), and6 for an exemption from the requirements of 14 C.F.R §§ 61.101(e)(4) and (5), 61.315(a), 61.23(a), 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, Altiora Media’s operation of the DJI Inspire 1 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, Altiora Media , LLC 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.

Altiora Media , LLC submits that the requested relief is proper since an equivalent level of safety will be ensured. Altiora Media , LLC will use experienced person nel or technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). Furtherm ore, Altiora Media , LLC will document and maintain all maintenance records for the DJI Inspire 1 UAS. Relief from certain requirements of Section 61.101(e)(4) and (5) entitled Recreational pilot privileges and limitations: Pilot in command , and from Secti on 61.315(a) entitled What are the privileges and limits of my sport pilot certificate , and from Section 61.23(a) entitled Medical certificates: Requirements and duration , is requested by Altiora Media , LLC to the extent necessary

to allow a Pilot in Comma nd (PIC) holding a sport pilot or higher level certificate, as well as a valid driver’s license, and who has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI Inspire 1 UAS in a manner co nsistent with7 this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

Altiora Media , LLC seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness , be cause the DJI Inspire 1 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Altiora Media , LLC submits that it will ensure that the DJI Inspire 1 UAS are in an airworthy condition, prior to every flight , by determining that the UASs are in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual), and that the aircraft are in a condition for safe flight.

Altiora Media , LLC also seeks an exemption from the requirements of Section 91.121,

entitled Altimeter Settings , as the DJI Inspire 1 UA will not have a typical barometric altimeter onboard. However, altitude information of the DJI Inspire 1 UA 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 Altiora Media , LLC’s operation of the DJI Inspire 1 UAS within visual lin e of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. Additionally, Altiora Media , LLC seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions

. Alti ora Media , LLC submits that safety will not be affected by operation of the DJI Inspire 1 UA during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration of approxima tely 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.8 In accordance with 14 C.F.R. § 11.81, Altiora Media , LLC provides the following information in support of its petitio n for exemption:

A. Name And Address Of The Petitioner. The name and address of the Petitioner and point of contact is:



### Daniel O. Montano Altiora Media, LLC 37 Vista Alegre Belen, NM 87002 Tel: (505)450

- 7123 Email: daniel@noenbuffalo.com B. The Specific Sections Of 14 C.F.R. From Which Altiora Media , LLC Seeks Exemption.

1. Altiora Media , LLC Seeks Exemption From The Requirements Of Section 61.101(e)(4) and (5). Section 61.101, entitled Recreational pilot privileges and limitations: Pilot in

command , subsection (e)(4) and (5) prescribe the following, in relevant part: (e) Except as provided in paragraphs (d) and (i) of this section, a recreational pilot may not act as pilot in command of an aircraft

- (4) For compensation or hire; (5) In furtherance of a business;

2. Altiora Media , LLC Seeks Exemption From The Requirements Of Section 61.23(a). Section 61.23(a), entitled Operations requiring a medical certificate: Requirements

and duration , subsection (a) prescribe the following, in relevant part: (f) Except as provided in paragraphs (d) and (i) of this section, a recreational pilot may not act as pilot in command of an aircraft

-9 3. Altiora Media , LLC Seeks Exemption From The Requirements Of Section 6 1.315(a). Section 61.315(a), entitled What are the privileges and limits of my sport pilot certificate , subsection (a) prescribe the following, in relevant part: (c) You may not act as pilot in command of a light

- sport aircraft: (2) For compensation or hire. (3) In furtherance of a business.

-

4. Altiora Media , LLC Seeks Exemption From The Requirements Of Section 91.7(a). Section 91.7, entitled Civil aircraft airworthiness , subsection (a), states the following: (a) No person may operate a civil aircr aft unless it is in an airworthy condition.

5. Altiora Media , LLC 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 flight level of t hat 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; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or (iii) In the case of an aircraft no t equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure.10 6. Altiora Media , LLC Exemption From The Requirements Of Section 91.151(b). Section 91.151, entitled Fuel requirements for fl ight in VFR conditions , subsection (b), states the following: (b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landin g and, assuming normal cruising speed, to fly after that for at least 20 minutes.

7. Altiora Media , LLC Exemption From The Requirement Of Section 91.405(a). Section 91.405, entitled Maintenance required , subsection (a), states the following: Each owner

o r 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[.]

8. Altiora Media , LLC 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 operat e any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

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

9. Altiora Media , LLC Seeks Exemption From The Requirements Of Sections 91.409(a)(1) and 91.409(a)(2). Section 91.409, entitled Inspections , subsection (a), states the following: (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft

unless, within the preceding 1 2 calendar months, it has had

- (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by § 43.7 of this chapter; or11 (2) An inspection for the issuance of an airworthiness ce rtificate in accordance with part 21 of this chapter. 10. Altiora Media , LLC 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 f or work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preventive maintenance, and alteratio n and records of the 100

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

- (i) A des cription (or reference to data acceptable to the Administrator) 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) Th e 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 pr ogram under which the aircraft and its appliances are maintained. (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, the time and date when the next action is required. (vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each12 major alteration to the airframe and currently installed engines, rot ors, propellers, a nd appliances. (b) The owner or operator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other w ork or for 1 year after the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a registered owner or op erator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.

C. The Extent Of Relief Altiora Media , LLC Seeks And The Reason Altiora Media , LLC Seeks The Relief.

1. Extent Of R elief Altiora Media , LLC Seeks And The Reason Altiora Media , LLC 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 t o allow a PIC holding a private pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met certain flight

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

h ire. 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 inciden tal to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. As set forth more fully below, Altiora Media , LLC submits that an equivalent level of safety

will be maintained because no PIC will be allowed to operate the DJI Inspire 1 UAS UA unless that13 PIC has met certain flight

- hour and currency requirements, demonstrating that the PIC is able to safely operate either the DJI Inspire 1 UAS in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate d istances from people, vessels, vehicles and structures

. Further, Altiora Media , LLC submits that all fli ghts of the DJI Inspire 1 UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to Altiora Media , LLC business; and (2) will not carry passengers or property for compensation or hire.

2. Extent Of Relief Altiora Media , LLC Seeks And The Reason Altiora Medi , a LLC Seeks Relief From Section 61.23(a). Relief from Section 61.23(a), entitled Operations requiring a medical certificate: Requirements and duration, is requested to the extent required to necessary to allow a PIC holding a sport pilot certificate or high er level certificate, as well as a current and valid driver’s license, to conduct the proposed UAS flight operations for compensation or hire. This relief is requested since the limitations set forth in Section 61.23(a) otherwise require the PIC of any fl ight for compensation or hire to hold a comprehensive FAA issued medical certificate. In Exemption No. 11213 to Aeryon Labs, Inc., the FAA “finds that, because of the risk mitigations established in the conditions and limitations of this exemption, a perso n that holds a U.S. issued driver’s license who is operating a UAS will not adversely affect safety. The FAA is granting relief from § 61.23(a) to allow any pilot that holds one of the pilot’s certificates discussed above to operate a UAS under this exempt ion with a U.S. issued driver’s license, in lieu of an FAA

- issued medical certificate. The FAA is also granting relief from § 61.23(c) to allow sport pilot certificate holders to operate aircraft other than LSA with a U.S. issued driver’s license under thi s exemption.”14 3. Extent Of Relief Altiora Media , LLC Seeks And The Reason Altiora Media , LLC Seeks Relief From Section 61.315(a). Relief from Section 61.315(a) entitled What are the privileges and limits of my sport pilot certificate , is requested to the extent necessary to allow a PIC holding a sport pilot or higher level certificate to conduct the proposed UAS flight operations for compensation or hire. This relief is requested since the limitations set forth in Section 61.315(a) restrict a sport pilot from acting as the PIC of any flight for compensation or hire, or for the furtherance of any business. In Exemption No. 11213 to Aeryon Labs, Inc., the FAA re

- assessed the level of pilot certificate that would be appropriate for the petitioner’s operati ons. In evaluating this petition, similar to the evaluation of the private and commercial pilot certificates in Exemption No. 11062, the agency compared the aeronautical knowledge requirements of the recreational and sport pilot certificates to

those of th e private pilot certificate. They found that the aeronautical knowledge requirements that would be applicable to a UAS operation for a recreational pilot and sport pilot certificate are substantially similar as those for a private pilot certificate.

Addit ionally, similar to the private and commercial pilot certificates, holders of recreational and sport pilot certificates are subject to security screening by the Department of Homeland Security (DHS). Therefore, because they must demonstrate aeronautical k nowledge relevant to UAS operations and are subject to DHS screening, factors that were considered by the FAA in allowing private pilot operations under previous exemptions, the FAA now determines that holders of recreational and sport pilot certificates m ay serve as the PIC for UAS operations.15 4. Extent Of Relief Altiora Media LLC Seeks And The Reason Altiora Media , LLC Seeks Relief From Section 91.7(a). Relief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to the extent require d to allow Feather Light Media LLC to determine that the DJI Inspire 1 UAS are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., the DJI Inspire 1 Maintenance Manual, Monthly Maintena nce Log, and DJI Inspire 1 Instruction Manual).

Altiora Media , LLC seeks the requested relief because the DJI Inspire 1 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Altiora

Media , LLC will ens ure that the DJI Inspire 1 UAS are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual) prior to every flight, and further, determine that the aircraft are in co ndition for safe flight, as stated in the conditions and limitations below.

5. Extent Of Relief Altiora Media , LLC Seeks And The Reason Altiora Media , LLC Seeks Relief From Section 91.121. Relief from Section 91.121, entitled Altimeter settings, may be r equired to allow flight operations of the DJI Inspire 1 UAS, 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 (GC S). Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), Altiora

Media , LLC seeks the requested relief because the 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.16 Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply with the a pplicable conditions and limitations stated below. As more fully set forth herein, an equivalent level of safety will be maintained since the DJI Inspire 1 UAs are equipped with a barometric pressure sensor and GPS equipment, which automatically ensures th at 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.

6. Extent Of Relief Altiora Media , LLC Seeks And The Altiora Media , LLC Relief From S ection 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 Inspire 1 UAs during daylight hours in visual meteorological condition s (VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. Altiora Media , LLC seeks the requested relief because wit hout an exemption from Section 91.151(b), the flight time duration of the battery powered DJI Inspire 1 UA will severely constrain the practicality of any aerial video or still photo flight operations that

Altiora Media , LLC proposes to conduct pursuant to this Petition. Significantly, as set forth below, the technical specifications of the DJI Inspire 1 UAS, the DJI Inspire 1 operating documents, and Altiora Media , LLC’s proposed operating limitations, ensure

that Altiora Media , LLC will safely operate th e battery powered 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 landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.17 7. Extent Of Relief Altiora Media , LLC Seeks And The Reason Altiora Media , LLC Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

Since Secti ons 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, Feather Light Media LLC requests relief from these Sections because the DJI Inspire 1 UAS does not require airworthiness certi ficates. As set forth more fully below, the DJI Inspire 1 UAS meets the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, Feather Light Media LLC will use 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 DJI Inspire 1 Maintenance Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, Feather Light Media will document and maintain all maintenance records for the DJI Inspire 1 UAS. D. The Reasons Why Granting Feather Light Media LLC Request Would Be In The Public Interest; That Is, How It Would Benefit The Public As A Whole. Granting the pres ent Petition will further the public interest by allowing Altiora Media , LLC to safely, efficiently, and economically conduct aerial video and photography of construction sites, building inspections, agricultural lands, wineries, outdoor recreational facil ities, real estate, special events, and landscapes over certain areas of the United States. Additionally, use of the DJI Inspire 1 UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the ben efits of Altiora Media , LLC’s proposed operation of the DJI Inspire 1 UAS will be realized without implicating any privacy issues.18 1. The Public Will Benefit From Decreased Congestion Of The NAS. The DJI Inspire 1 UAS are battery powered and serve as a s afe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJI Inspire 1 UAS would r educe 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

aroun d airports caused by arriving and departing aircraft will be reduced. The DJI Inspire 1 UAS do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would result in fewer aircra ft 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 Inspire 1 UAS. Conducting aerial acquisitions wit h the DJI Inspire 1 UAS, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, the DJI Inspire 1 UAS 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 Inspire 1 UAS, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UASs are propelled by battery19 powered electric motors, rather than an internal combustion engine. By using the DJI Inspire 1 UAS to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground,

which is usua lly associated with traditional manned aircraft flight operation s, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI Inspire 1 UAS (weighing approximately 6.5 pounds maximum gross weights with a length of 17.3 inches, width of 17.7 i nches, 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 typically conduct similar operations (weighing approximately 6,000 pounds with a

w ingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons). 3. Performing Aerial Video and Photography Operations With The DJI Inspire 1 UAS Will Benefit The Economy. In addition to being safe and efficient, the DJI Inspir e 1 is also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Inspire 1 UAS will allow United States based companies, like Altiora Media , LLC, to remain competitive and contribute to grow th 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 Inspire 1 UAS 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 Inspire 1 UAS, companies such as Altiora Media , LLC, can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors,20 which will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through commercial use of the DJI Inspire 1 UAS, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows co mpanies 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,

Altiora Me dia , LLC proposed operation of the DJI Inspire 1 UAS will not implicate any privacy issues. Specifically, the DJI Inspire 1 UAS will be operated only in compliance with the conditions set forth in any exemption granted under this petition.

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 Altiora Media , LLC Seeks Exemption. 1. Reasons Why The DJI Inspire 1 UA Meet The Cond itions 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, Altiora, Media LLC operation of the DJI Inspire 1 UA S meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirement s 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. Specifically, FMRA Section 333 states the following, in part: (a) In General.

-- Notwithstanding any other requirement o f this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of21 the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act. (b) Assessment of Unmanned Aircraft Systems.

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

-

(1) which t ypes of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace syste m 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 air craft systems identified under paragraph (1). (c) Requirements for Safe Operation.

-- If the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish req uirements for the safe operation of such aircraft systems in the national airspace system. In seeking this exemption, Altiora Media , LLC submits that the DJI Inspire 1 UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI Inspire 1 UAS; (b) the pilot certification requirement; and (c) the specific operating limitations. a. The Specifications Of The DJI Ins pire 1 UAS Demonstrate Its Safe Characteristics. The DJI Inspire 1 UAS does not c reate 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 Inspire 1 UAS. The technical specifications of the DJI Inspire 1 UAS is set forth by the DJI Inspire 1 Specifications and Data Sheet, attached hereto as Exhibit A. ii. The DJI Inspire 1 UAS Autonomous Flight And Navigation Modes Enable The UAS To Remain Within A Defined Operational Area. The DJI Inspire 1 UAS may be operated in both manual and fully autonomous flight modes. A complete description of the flight and navigational modes of the DJI Inspire 1 UAS is provided in the DJI Inspire 1 User Manual, attached hereto as Exhibit B.22 iii. The DJI Inspire 1 UAS Ar e 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 Inspire 1 UA will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Inspi re 1 UA does not reacquire control link data from the GCS, the UA will assume that the Control Link is lost and the UA will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown. A complete descri ption of the Failsafe Functions of the DJI Inspire 1 UAS are set forth in the DJI Inspire 1 User Manual, attached hereto as B. iv. The DJI Inspire 1 GCS And Its Operation. A complete description of the operation and specifications of the DJI Inspire 1 GC S and flight control software is provided in the DJI Inspire 1 User Manual. DJI Inspire 1 User Manual is attached

hereto as Exhibit B. b. Flight Operations Of DJI Inspire 1 UAS Are Limited To The Line Of Sight Of A Certificated Pilot in Command With A Saf ety Observer. Feather Light Media LLC 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 Inspire 1 UAS. Additionally, a safety observer will assist all pilots duri ng flight time. c. Flights Of DJI Inspire 1 UAS Will Be Conducted Pursuant To Specific Operating Limitations. In seeking this exemption, proposes to commercially operate DJI Inspire 1 UAS 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 le ss than 55 pounds maximum gross weight: DJI Inspire 1 Unmanned Aircraft System. Proposed operations of23 any other aircraft will require a new petition or a petition to amend this grant. 2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photography. 3. The UAs may not be flown at an indicated airspeed exceeding 20 knots. 4. The UA must be operated at an altitude of no more than 500 feet above ground level (AGL), as indicated by the procedu res 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 operati ons 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 permit ted 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 S O 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 request. If a discrepancy exists between the conditions and limitations contained in the grant of exemption and the procedures outlined in the operating doc uments, the conditions and limitations contained in the grant of exemption 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 docu ments. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the g rant of exemption. If the operator determines that any update or revision would affect the basis upon which 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) ma y be contacted if questions arise regarding updates or revisions to the operating documents. 10. Prior to each flight the PIC must inspect the UAS to 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 undergone maintenance or alterations t hat affect the UAS operation or24 flight characteristics, e.g. replacement of a flight critical component, must unde rgo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraft records.

12. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not alr eady covered in the relevant sections of the operating documents. 13. The operator must follow the UAS manufacturer’s a ircraft/component, maintenance,overhaul, replacement, inspection, and life limit requirements. 14. The operator must carry out its maintena nce, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, 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. The 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 safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and ma intaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the 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, a nd 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. §

19.1. 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 not authorized. 20. The UA may not operate within 5 nautical m iles of an airport 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 agreement with the airport management must be25 made available to the Administrator upon request. 21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 sta tute miles from the PIC. 22. If the UA loses communications or loses its GPS signal, it must return to a pre determined location within the planned operating area and land or be recovered in accordance with the operating documents. 23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents. 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 UA with 25% battery power remaining. 25. The 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 requireme nts in the ATO issued COA including class of airspace, altitude level and potential transponder requirements. 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 (N

- Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable. 27. Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made available to the Administrator or any law enforcement official upon request. 29. The UA 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 s ituation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such ve ssels, 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 not26 present an undue hazard, and; c. Operations nearer to the PIC, SO, operator trai nees 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. Permis sion from land owner/controller or authorized representative will be obtained for each flight to be conducted.

33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the a pplicable 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 (NTSB) per instructions contained on the NTSB Web site: w ww.ntsb.gov

. 2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety. Altiora Media LLC submits that the equivalent level of safety established by Section 61.113(a) and (b) will be maintained be cause no PIC will be allowed to operate the 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 Inspire 1 UAS in a manner consistent with the exempt ion, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering Altiora, Media LLC proposed area of operations, and the operating limitations set forth

- above; the parallel natu re of sport pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI Inspire 1 UAS, Altiora

Medi , a LLC submits that the additional manned ai rmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for Altiora Media , LLC specific proposed flight operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UA S, 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, 11153,2 7 11156, 11158, 11159, 11160, 11161).

Altiora Media , LLC will not allow any PIC to operate the DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight

- hour requirements or the DJI Inspire 1 UAS training and currency requirements, that the PIC is able to safely operate the DJI 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 will ensure an equivalent level of safety during Altiora Media , LLC 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 follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for 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, the PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and mod el 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 time 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). The28 FAA finds that at a minimum, the flight

- ho ur 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 complia nce 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 experience

- b uilding 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, Altiora Media , LLC will ensure safe operations by not allowing any PIC to operate the DJI I nspire 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 Inspire 1 UAS in a manner consistent with the exemption, including evasive and

emergency maneuvers an d 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 equivalent level of safety established by Section 91.7(a) will be maintained because prior to every flight, Altiora Media , LLC will ensure that the 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

. Additi onally, 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, 111 36, 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 Safety.29 The equivalent level of safety established by Section 91.121 will be maintained bec ause the altitude information of the DJI Inspire 1 UAS will be provided to the PIC via GPS equipment and a radio communications telemetry data link, which downlinks from the UAS to the GCS for active monitoring of the flight path and altitude. This altitud e information, combined with Altiora Media, LLC’s operation of the 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 equipm ent installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically established by the UASs at ground level. The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar, in al l material respects, to those presented herein (e.g. Exemption

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 5. Reasons Why An Exemption From The Requirements O f 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 specifications of the DJI Inspire 1 UAs; (2) the

limita tions on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, Altiora Media , LLC will ensure that it will safely operate the battery powered DJI Inspire 1 UA during daylight hours in VFR conditions, with enou gh battery power to fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.30 Here, as in Exemption No. 11109, the technical specifications of the DJI I nspire 1 UAS; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Inspire 1 UAS 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 critically low battery level, the DJI Inspire 1 UAS 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 lim itations 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 exemption, Altiora Media , LLC 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 Altiora31 Media , LLC will use trained technic ians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., the DJI Inspire 1 Maintenance Manual, Monthly Maintenance Log, and DJI Inspire 1

Instru ction Manual). Furthermore, Altiora Media , LLC will document and maintain all maintenance records for the DJI Inspire 1 UAS. Since the DJI Inspire 1 UAS will be inspected as prescribed by the operating documents, Altiora Media , LLC will maintain the equiv alent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI Inspire 1 User Manuals

are attached hereto as Exhibit B; a copy of the DJI Inspire 1 Maintenance Manual is attached hereto as Exhibit C; a copy of th e DJI Inspire 1 UAS Maintenance LOG is attached hereto as

Exhibit D. Likewise, the exemption sought will not adversely affect safety because Altiora Media , LLC will use trained technicians to perform maintenance, alterations or preventive maintenance

on t he 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 t he DJI Inspire 1 UAS 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 are32 considered.

In con sideration of Altiora Media, LLC proposed operating limitations, the operatin g documents, and the technical aspects of the DJI Inspire 1 UAS, Altiora Media , LLC 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). Th e 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 Conditions 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, Altiora Media , LLC requests that the FAA prescribe special conditions for the intended operation of the DJI Inspire 1 UAS, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 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 conducting ae rial video and photography over certain areas of the United States 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 threat to na tional 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 pres cribe special conditions pursuant to 14 C.F.R.33 § 21.16, for operation of the DJI Inspire 1 UAS, 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 aircraft, aircraft engine, or propelle r because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and 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 accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for Leading Edge’s intended operation of the DJI Inspire 1 UAS, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that establish ed 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). F. A Summary That Can Be Published In The Federal Register, stating: The Rules Fro m Which Feather Light Media LLC Seeks Exemption:

Altiora Media , LLC seeks exemption from the requirements of 14 C.F.R Sections 61.101(e)(4) and (5), 61.315(a), 61.23(a), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.41 7(a) & (b). A Brief Description Of The Nature Of The Exemption Altiora Media, LLC Seeks: This exemption will permit Altiora Media , LLC to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography o ver certain areas of the United States. G. Any Additional Information, Views, Or Arguments Available To Support Altiora Media , LLC Request.34 This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs t he Secretary of Transportation to determine if certain UAS may operate safely in the NAS. As such, Altiora Media , LLC 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 Sectio n 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 certi fication. As discussed in detail above, Altiora Media , LLC will operate the 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 forth here in, Altiora Media , LLC 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 Inspire 1 UAS commercially, without an airworthiness certificate, fo r 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 a lso advancing the interests of the public, by allowing Altiora Media , LLC to safely, efficiently, and economically operate the DJI Inspire 1 UAS commercially within the NAS.35 WHEREFORE , in accordance with the Federal Aviation Regulations and the FAA

Modern ization and Reform Act of 2012, Section 333, Altiora Media , LLC respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.101(e)(4) and (5), 61.315(a), 61.23(a), 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 Altiora Media LLC to operate the DJI Inspire 1 UAS commercially for the purpose of conducting aerial video and photography over areas of the

United States. 

### Respectfully su bmitted ,



### Daniel Montaño

Altiora Media, LLC 37 Vista Alegre Belen, NM, 87002 Tel: (505)450

- 7123 Email: daniel@neonbuffalo.com