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: BLUESUIT TECHNOLOGY, LLC.

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQU IREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF a) DJI INSPIRE 1UNMANNED AIRCRAFT

SYSTEMS P URSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)

Submitted on July 10 , 2015

BLUESUIT T ECHNOLOGY, LLC Sheila Walker, President 8855 Villa Ridge Drive #132 3

Fort Worth, TX 76108

682

- 235

- 7390
info@bluesuitechnology.com2 TABLE OF CONTENTS

Page

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

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

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

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

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

NAME AND ADDRESS OF PETITIONER............................................................. ......6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH, BLUESUIT TECHNOLOGY, LLC SEEKS EXEMPTION

............... ......................... .............. 7

THE EXTENT OF RELIEF BLUESUIT TECHNOLOGY, LLC SEEKS AND THE

REASON BLUESUIT TECHNOLOGY, LLC SEEKS THE RELIEF

............... .. . .........10

THE REASONS WHY GR ANTING BLUESUIT TECHNOLOGY, LLC ’S REQUEST

WOULD BE IN THE PUBLIC INTEREST ....................

................ ...............................13

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY

AFFECT SAFETY...

......................................................................................................... 1 5

CONCLUSION................................................................................................................. 2 83 GLOSSARY OF ABBREV IATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation R egulation

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)

SO Safety Observer

SOP Standard Op erating 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

BLUESUIT TECHNOLOGY, LLC Seeks exemption from the r e quirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMR A). This exemption will permit BLUESUIT TECHNOLOGY, LLC to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography for real estate photography, wedding videography, special events, film sets and lands cape over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

My name is Sheila Walker , Owner/President of BLUESUIT TECHNOLOGY,

LLC

. It is my mission to provide my clients with expertise and knowledge in all aspects of pic ture, video & audio production, as well as provide them with advanced technologies & solutions that will increase efficiency, productivity and effectiv eness. BLUESUIT TECHNOLOGY, LLC , also provides clients with the highest quality digital content for use i n their commercial, personal, and non

- profit multimedia projects. BLUESUIT TECHNOLOGY, LLC has several years of professional experience in photography and videography and has become recognized as an expert in

this field. BLUESUIT TECHNOLOGY, LLC has 2 year s of building expertise in aerial video and photography. The object ive of BLUESUIT TECHNOLOGY, LLC ’s aerial video and photography operations is to provide high quality imaging for a variety of commercial, public, and residential uses, specifically targetin g:

• Real Estate Videography and Photography

• Wedding Videography and Photography

• Land survey & appraisals

• Equipment Inspections

• Roof Inspections

• Construction sites before & after

• Precision Agriculture

• Creation of commercial messages f or Television

• Search and Rescue o perations in cooperation with local law enforcement

• Motion Picture Filming

• Increase public knowledge of UAS and promote safe UAS operations5 BACKGROUND Unmanned Aircraft System : DJI Inspire 1 UAS

BLUESUIT TECHNO LOGY, LLC s eeks an exemption to operate DJI systems for compensation or hire within the NAS. The DJI Inspire 1 are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone sys tems. The DJI Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of approximately 42 knots. The DJI Inspire 1 UA are equipped with four main rotors; driven by Lithium Polymer battery powered electric motors.

The DJI Inspire 1 UA that will be operated by BLUESUIT TECHNOLOGY, LLC will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft , as well as 14 C.F.R Part 47, Aircraft Registration

, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking

.

BASIS FOR PETITION

Petit ioner, BLUESUIT TECHNOLOGY, LLC , pursuant to the provisions of the

Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernizatio n and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereby petitions the Administrator to commercially o perate the DJI Inspire 1 UAS in the National Airspace System (NAS), and for an exemption from the require ments of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its op eration, BLUESUIT TECHNOLOGY, LLC

o peration of 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, BLUESUIT TECHNOLOGY, LLC r equests 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.

BLUESUIT TECHNOLOGY, LLC submits that the requested relief is proper since an equivalent level of safety will be ensured. BLUESUIT TECHNOLOGY, LLC will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techni ques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, DJI Inspire 1 Instruction Manual). Furthe rmore, BLUESUIT TECHNOLOGY, LLC

, will document

and maintain all maintenance record s for the DJI Inspire 1 UAS

.6 Relief from c ertain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command , is requested by BLUESUIT TECHNOLOGY, LLC to the extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher leve l certificate, as well as an airman medical certificate, and who has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely op erate 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.

BLUESUIT TECHNOLOGY, LLC seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness , because the DJI Inspire 1 UAS do not r equire an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, BLUESUIT TECHNOLOGY, LLC submits that they will ensure that the DJI Inspire 1 UAS are in an airworthy condition, prior to every flig ht, by determining that the UA S are in compliance with the operating documents (i.e., Monthly Maintenance Log, DJI Inspire 1 Instruction Manual), and that the aircraft are in a condition for safe flight.

BLUESUIT TECHNOLOGY, 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 1UAs will be provided to the PIC via Global Positioning System (GPS) equipment and

radio co mmunications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combine d with BLUESUIT TECHNOLOGY, LLC ’s operation of the DJI Inspire 1 UAS within visual line of sight, at or bel ow 500 feet AGL, will ensure a level of safety equivalent to

Section 91.121.

Additionally, BLUESUIT TECHNOLOGY, LLC seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR

conditions. BLUESUIT TECHNOLOGY , 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 approximately 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

In accordance with 14 C.F.R. § 11.81, BLUESUIT TECHNOLOGY, LLC provides the following information in support of its petition f or exemption:

A. Name And Address Of The Petitioner. The name and address of the Petitioner and point of contact is: Sheila Walker c/o BLUESUIT TECHNOLOGY, LLC. 8855 Villa Ridge Drive #1323 Fort Worth, TX 76108 Tel: ( 682 ) 235

- 7390

Email: info@bluesuitechnology.com7 B. The Specific Sections Of 14 C.F.R. From Which BLUESUIT TECHNOLOGY,

LLC Seeks Exemption.

1. BLUESUIT TECHNOLOGY, LLC Seeks Exemption From The Requirements Of Section Part 21, Subpart H

14 C.F.R. Part 21, Subpart H, establishes the procedural requirements for the issuance of airworthiness certificates as required by 14 C.F.R. §91.203(a)(1)

2. BLUESUIT TECHNOLOGY, LLC Seeks Exemption From The Requirements Of Section 61.113(a) And (b).

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

, subsections (a) and (b) prescribe the following, in relevant part: (a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PIC of an aircraft.

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any busines s or employment if

—

(1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire.

3. BLUESUIT TECHNOLOGY, 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 aircraft unless it is in an airworthy condition.

4. BLUESUIT TECHNOLOGY, LLC Seeks Exemption From The Requirements Of Sect ion 91.121.

Section 91.121, entitled Altimeter settings , subsection (a), states the following, in

part: (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an alt imeter 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 s tation; or8 (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure.

5. BLUESUIT TECHNOLOGY, LLC Seeks Exemption From The Requirements Of Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions

, subsection (b), states the f ollowing:

(b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.

6. BLUESUIT TECHNOLOGY, LLC Seeks Exemption From The Requirement Of Section 91.405(a).

Section 91.405, entitled Maintenance required , subsection (a), states the following: Each owner or operator of an aircraft

—

(a) Shall ha ve 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[.]

7. BLUESUIT TECHNOLOGY, LLC Seeks Exemption From The Requirements Of Section 91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration , subsection (a)(1), states the following: (a) No person may operate any aircraft tha t 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[.]

8. BLUESUIT TECHNOLOGY, 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 12 calendar mon ths, 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; or (2) An inspection for the issuance of an airworthiness certificate in ac cordance with part 21 of this chapter.9 9. BLUESUIT TECHNOLOGY, LLC Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b).

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

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preventive maintenance, and alteration and

re cords 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 description (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 co ntaining the following information: (i) The total time in service of the airframe, each engine, each propeller,

and each rotor. (ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance. (iii) The time since la st overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under whic h 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 safe ty 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 each major alteration to the airframe and currently installed engines, rotors, propellers, and 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 work 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 operator under § 43.11

of th is chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.10 C. The Extent Of Relief BLUESUIT TECHNOLOGY, LLC Seeks And The Reason BLUESUIT TECHNOLOGY, LLC Seeks The Relief.

1. BLUESUIT TECHNOLOGY, LLC S eeks Exemption From The Requirements Of Section Part 21, Subpart H

Given the size and limited operating area associated with the UAS to be utili zed by BLUESUIT TECHNOLOGY, LLC , an exemption from Part 21 Subpart H meets the requirements of an equivalent le vel of safety under Part 11 and Section 333 of the

Reform Act.

The Federal Aviation Act (49 U.S.C.§ 44701(f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon considera tion of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular UAS.

In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restr icted environment and under the conditions proposed will be at least as safe, or safer, than a conventional rotorcraft operating with an airworthiness certificate without the restrictions and conditions of the proposed UAS operations.

2. Extent Of Relief BLUESUIT TECHNOLOGY, LLC Seeks And The Reason BLUESUIT TECHNOLOGY, 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 neces sary to 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 compensatio n or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if: (1) The flight is only i ncidental 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, BLUESUIT TECHNOLOGY, LLC submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the DJI Inspire 1 UAS unless that PIC has met certain flight

- hour and currency requirements, demonstrating that the PIC is able to safely operate either the DJI Inspire 1 UAS in a manner consistent with the operations specif ications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures.11 Further, BLUESUIT TECHNOLOGY, LLC submits that all fligh ts of the DJI Inspire 1

UAS , conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to BLUESUIT TECHNOLOGY, LLC.' business; and (2) will not carry passengers or property for compensation or hire.

3. Extent Of Relief BLUESUIT TECHNOLOGY, LLC Seeks An d The Reason BLUESUIT TECHNOLOGY, LLC Seeks Relief From Section 91.7(a)

.

Relief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to the extent required to allow BLUESUIT TECHNOLOGY, LLC to determine t hat the DJI Inspire 1

UAS are i n airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., Monthly Maintenance Log, DJI Inspire 1 Instruction Manual).

BLUESUIT TECHNOLOGY, LLC s eeks the requested relief be cause the DJI Inspi re 1

UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, BLUESUIT TECHNOLOGY, LLC will ensure that the DJI Inspire 1 UAS are in airworthy condition based upon its compliance with the operating

documen ts (i.e., Monthly Maintenance Log, DJI Inspire 1 Instruction Manual) prior to every flight, and further, determine that the aircraft are in condition for safe flight, as

stated in the conditions and limitations below.

4. Extent Of Relief BLUESUIT TECHNOLO GY, LLC Seeks And The Reason BLUESUIT TECHNOLOGY, LLC Seeks Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings , may be required to allow flight operatio ns of the DJI Inspire 1 UAS , which utilize a barometric pressure senso r, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), BLUESUIT TECHNOLOGY,

LLC s eeks the requested relief be cause the DJI Inspire 1 UA altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude,

befor e each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply with the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent le vel of safety will be maintained since the DJI Inspire 1 UA are equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the PIC wi th altitude information of the

UA on the heads

- up display of the GCS.12 5. Extent Of Relief BLUESUIT TECHNOLOGY, LLC Seeks And The Reason BLUESUIT TECHNOLOGY, LLC Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to allow flights of the battery powered DJI Inspire 1 UA during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 13.5 minut es to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. BLUESUIT TECHNOLOGY, LLC s eeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the batte ry powered DJI Inspire 1 UA will severely constrain the practicality of any aerial video or still photo flight operations that BLUESUIT TECHNOLOGY, LLC proposes to conduct pursuant

to this Petition.

Significantly, as set forth below, the technica l specifications of the DJI Inspire 1 UAS , the DJI Inspire 1 operating documents, and BLUESUIT TECHNOLOGY, LLC.’s proposed operating limitations, ensure that BLUESUIT TECHNOLOGY, LLC will safely operate the battery powered 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 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at lea st 4.5 minutes.

6. Extent Of Relief BLUESUIT TECHNOLOGY, LLC Seeks And The Reason BLUESUIT TECHNOLOGY, LLC Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1 ) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, BLUESUIT TECHNOLOGY, LLC requests relief from these Sections because the DJI Inspire 1 UAS do not require airworthiness certificates. As set forth more fully b elow, t he DJI Inspire 1 UAS meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, BLUESUIT TECHNOLOGY, LLC will use trained technicians to perform maintenance, alterations, or pr eventive maintenance on the UAS us ing the methods, techniques, and practices prescribed in the UAS operating documents (i.e., Monthly Maintenance Log, DJI Inspire 1 Instruction Manual). Furthermore, BLUESUIT TECHNOLOGY, LLC will document and maintain all maintenance records for the DJI

Ins pire 1 UAS

.13 D. The Reasons Why Granting BLUESUIT TECHNOLOGY, LLC Request Would

Be In The Public Interest; That Is, How It Would Benefit The Public As A Whole.

Granting the present Petition will further the public interest by allowing BLUESUIT TECHNOLOGY, LLC to safely, efficiently, and economically perform aerial video and photography of, real estate, wedding films, special events, precision agriculture, land survey & appraisal, construction sites, equipment & roof inspections, film sets , search and

rescu e and landscape 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 benef its of BLUESUIT TECHNOLOGY, LLC ’s proposed operation of the DJI Inspire 1 UAS will be realized without implicating any privacy issues.

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

The DJI Inspire 1 UA are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a or DJI Inspire 1 UAS would reduce the amount of

manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arrivi ng and departing aircraft will be reduced. The DJI Inspire 1 UA 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 aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The DJI Inspire 1

UAS

.

Conducting aerial acquisitions with the DJI Inspire 1 UAS , in stead 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 mo tors, the DJI I nspire 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 approximate ly 20

- 30 gallons per hour of leaded aviation fuel. The DJI Inspire 1 UA , while reducing the carbon footprint of aerial acquisitions, also

elimin ates noise pollution, as the UA are propelled by battery powered electric motors,

rather than an internal combus tion engine.14 By using the DJ I Inspire 1 UAS to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduc ed or completely eliminated. Aside from the lack of flight crew members located onboard the air craft, the DJI Inspire 1

UA (weighing approximately 2 pounds 11 ounces and 6 pounds 7.5 ounces respectively, at their maximum gross weights with lengths of 16 in ches and 17.3 inches respectively,

widths of 16 inches and 17.7 inches respectively, and with no fuel on board), has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typi cally conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations With The DJI Inspire 1

UAS Will Benefit The Economy.

In addition to being safe and efficient, the DJI Inspire 1 UAS are 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 bas ed companies , like BLUESUIT TECHNOLOGY, LLC , to remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviat ion fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the batter y powered DJI Inspire 1 UAS is one such technology that not only allows companies greater operational flexibility com pared to manned aircraft, but provides such flexibility without the high operational cost of a

traditional manned aircraft.

By oper ating the DJI Inspire 1 UAS , companies s uch as BLUESUIT TECHNOLOGY,

LLC , can remain competitive and profitable, and therefor e, provide greater job stability to employees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through commercial u se of the DJI Inspire 1 UAS , provides a stable workforce th at increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the United States and

abroad.

4. There Are No Privacy Issues.

Similar to th e manned aerial acquisition flight operations that have been conducted for

de cades, BLUESUIT TECHNOLOGY, LLC proposed operati on of the DJI Inspire 1

UAS will not implicate any privacy issues. Specifically, the DJI Inspire 1 UAS will be operated only in com pliance with operating documents (i.e., Monthly Maintenance Log, DJI Inspire 1 Instruction Manual) which requires property owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, including t he minimum altitude requirements of 14 C.F.R. § 91.119.15 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 BLUESUIT TECHN OLOGY, LLC Seeks Exemption.

1. Reasons Why The DJI In spire 1 UA Meet The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333.

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

unmanned a ircraft and its oper ation, BLUESUIT TECHNOLOGY, LLC operation of the DJI Inspire 1 UAS 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 authori ty for a UAS to operate without airworthiness certification and sets forth 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. Specifically,

FMRA Section 333 st ates the following, in part:

(a) In General.

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

(b) Assessment of Unmanned Aircraft Systems.

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

-- (1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security; and (2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 4 4704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1).

(c) Requirements for Safe Operation.

-- If the Secretary determines under this section that certain unmanned aircraft systems ma y operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system.

In seeking this exemption, BLUESUIT TECHNOLOGY, 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.16 a. The Specifications Of The DJI In spire 1 UAS Demonstrate Its Safe C haracteristics.

The DJI Inspire 1 UAS do not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability.

i. Technica l Specificatio ns Of The DJI Inspire 1 UAS

. The technical specificatio ns of the DJI Inspire 1 UAS are 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 M odes 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 I nspire 1

UAS are provided at p ages 12

- 18 and 45

- 52 of the DJI Inspire 1 User Manuals, attached

hereto as Exhibit B

.

iii. The DJI Inspire 1 UAS Are Designed For Automatic Return To Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation.

When the Control Link is los t, the DJI Inspire 1 UA will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Inspire 1 UA do not reacquire control link

da ta 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 description of the Failsafe Functions for the DJI Inspire 1 at pages 13 through 15 of the DJI Inspire 1 User Manual, attached hereto as

Exhibit B

.

iv. The DJI Inspire 1 GCS And Its Operation. A complete description of the operation and specifications of the DJI Inspire 1 GCS and flight control software is provided at pages 24 through 34 of the DJI Inspire 1 User

Manual. DJI Inspire 1 User Manuals are attached hereto as Exhibits B

.

b. Flight Oper ations Of DJI Inspire 1 UAS Are Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer.

BLUESUIT TECHNOLOGY, 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 during flight time.17 c. F lights Of DJI Inspire 1 UAS Will Be Conducted Pursuant To Specific Operatin g Limitations.

In seeking this exemption, BLUESUIT TECHNOLOGY, LLC proposes to
commerciall y 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 specifi c operating limitations:

1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the oper ating documents, rotorcraft UAS weighing less than 55 pounds maximum gross weight: DJI Inspire 1 Unmanned Aircraft Systems. Proposed operations of 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 UA m ay 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 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 UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than

corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate.

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

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

8. The SO must not perform any other duties beyond assisting the PIC with seeing an d avoiding other air traffic and other ground based obstacles/obstructions and is not permitted to operate the camera or other instruments.18 9. The operating documents and the grant of exemption must be accessible during UAS

o perations and made avai lable 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 documents, the conditions and limitations contained in the grant of exe mption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such

revisions a nd 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 grant of exemption. If the operator determines that any update or rev ision 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) may 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 operatin g 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 airc raft records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional te st 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 already covered in the relevant sections of the operating documents.

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

14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. 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 autho rized person returning the UAS to service.

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

Bulletins.19 16. The authorized person must make an entry in the aircraft record of the corrective action taken against disc repancies 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 qualif ication 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 maintaining appropriate distances from persons, vessels,

veh icles 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, and the PIC must operate the UA with appropriate distance f rom nonparticipants in accordance with 14 C.F.R. § 91.119.

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will be made at the FAA 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 miles 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

manageme nt must be 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 statute miles from the PIC.

22. If the UA loses commu nications 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.20 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 req uire the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class o f 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) marking s 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 (FC C) 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 struct ures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating per sons 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 vessels, vehicles or structures has granted p ermission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, and; c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present

an undue hazard to those persons per § 91.119(a).21 32. All operations shall be conducted over private or controlled

- access property with permission from the land owner/controller or authorized representative. Permission from

land owner/controller or auth orized 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 applicable COA must be reported to

the F AA'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: www.ntsb.gov

.

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

BLUESUIT TECHNOLOGY, LLC submits that the equivalent level of safety established by Section 61.113(a) and (b) will be maintained because no PIC will be

allowed to 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 or DJI Inspire 1 UAS in a manner consistent with the exemption, including evasive and emerg ency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

Consi dering BLUESUIT TECHNOLOGY, LLC ’s proposed area of operations, and the operating limitations set forth

- above; the parallel nature of private pilot

aer onautical 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, BLUESUIT TECHNOLOGY, LLC submits that the additional manned airmanship experi ence of a commercially certificated pilot would not correlate to the airmanship skills necessa ry for BLUESUIT TECHNOLOGY, LLC ’s specific proposed flight operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in c ircumstances 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, 11158, 11159, 11160, 11161).

BLUESUIT TECHNOLOGY, LLC w ill not allow any PIC to operate the DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum fl ight

- hour requirements or the DJI Inspire 1 UAS training and currency requirements, that the PIC i s able to safely operate the DJI Inspire 1 UAS i n a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.22 Specifically, the PIC must have accumulated and logged, in a manner consistent

with 1 4 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, th e 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

equ ivalent level of safety during BLUESUIT TECHNOLOGY, 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 m odel 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 t he 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the 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, BLUESUIT TECHNOLOGY, LLC will ensure safe operations by not allowing any P IC to operate the or DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI Inspire 1 UAS in a manner consistent with the exemption, including evasive and emergency maneuv ers and maintaining appropriate distances from people, vessels, vehicles and structures.23 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, BLUESUIT TECHNOLOGY, LLC will ensure that the DJI Inspire 1 UAS is in an airworthy condition based upon the UAS compliance with its operating documents and as stated in the conditions and limitations herei n. Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

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

The equivalent level of safety established by Section 91.121 will be mai ntained because the altitude information of the DJI Inspire 1 UA will be provided to the PIC via GPS equipment and a radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path and altitude. Thi s altitude information, combine d with BLUESUIT TECHNOLOGY, LLC ’ operation of the DJI Inspire 1 UA within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically established by the UAS at ground level.

The FAA has previously granted relief from Section 91.121 specific to UAS, in

circumstances s imilar, in all 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 Req uirements Of Section 91.151(b) Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJI Inspire 1 UAS ; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, BLUESUIT TECHNOLOGY, LLC will ensure that it will safely operate the battery powered DJI Inspire 1 UA during daylight

hours in VFR cond itions, 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.24 Here, as in Exemption No. 11109, the technical specificat ions of the DJI Inspire

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 ensur ed as the DJI Inspire 1 UAS provide audible and visual warnings to the PIC at the GCS when the UA experiences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery power. At th e 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

a nd operating limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted

reli ef 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, BLUESUIT TECHNOLOG Y, 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 BLUESUIT TECHNOLOGY, LL C will use trained technicians to perform maintenance, alterations, or pr eventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual ). Furthermore, BLUESUIT TECHNOLOGY, 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, BLUESUIT TECHNOLOGY, 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 o f the DJI Inspire 1 User Manual is attached hereto as Exhibit B ; a copy of the DJI Inspire 1

UAS Maintenance LOG is attached hereto as Exhibit C.

Likewise, th e exemption sought will not adversely affect safety because BLUESUIT TECHNOLOGY, LLC will use trained technicians to perform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed by the operat ing documents.25 Furthermore, the exemption sought would maintain an equivalent level of safety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI 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 a ffected when the technical characteristics and operating limitations of

the UAS are considered.

In considerat ion of BLUESUIT TECHNOLOGY, LLC ’s proposed operating limitations, the operating documents, and the technical aspects of the DJI Inspire 1

UAS

, BLU ESUIT TECHNOLOGY, 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). The FAA has previously granted relief specific to UAS in circums tances 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, BLUESUIT TECHNOLOGY, LLC requests that the FAA prescribe special conditions f or the intended operati on 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), 9 1.7 (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 UA for the limited purpose of conducting aerial video and photography over certain areas of the Unite d 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 national security; and further, provides the authority for s uch UAS to operate without airworthiness certification in accordance with any requirements that must be established for the safe operation of the UAS in the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, f or operati on 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:26 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 propeller because of a novel or unusual design feature of the aircra ft, 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 p ropeller 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 fo r 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 established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61 .113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

F. A Summary That Can Be Published In The Federal Register, stating:

The Rules From Which BLUESUIT TECHNOLOGY, LLC Seeks

E xemption:

BLUESUIT TECHNOLOGY, LLC s eeks exemption from the requirements of 14 C.F.R

Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

A Brief Description Of The Nature Of The Exemption BLUESUIT

TECHNOL OGY, LLC Seeks :

This exemption will permit BLUESUIT TECHNOLOGY, LLC to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States.27 Any Additional Information, Views, Or Arguments Available To S upport BLUESUIT TECHNOLOGY, LLC ’s Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may o perate safely in the NAS. As such, BLUESUIT TECHNOLOGY,

LLC ’s request for exemption may be granted pursuant to the authority of FMRA Section

333 and 14 C.F.R. Part 11, as set forth above. FMRA Section 333 sets forth the requirements for considering whethe r a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification. As discussed in detail above, BLUESUIT TECHNOL OGY, LLC will op erate the DJI Inspire 1 UAS safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.28 CONCLUSION

As set forth herein, BLUESUIT TECHNOLOGY, LLC seeks an exemption

pu rsuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and

Reform Act of2012 (FMRA), which will permit safe operation of the DJI Inspire 1 UAS commercially, without an airworthiness certificate, for the

limited purpose of conducting aerial vi deo and photography over certain areas of

the United States. By granting this Petitio n , the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act

of 2012, while also advancing the interests of the public, by allowing BLUESUIT TECHNOLOGY, LLC to safely, efficiently, and economically

operate the DJI Inspire 1 UAS commercially within the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and

the FAA Modernization and Reform Act of 2012, Section 333,
BLUESUIT TECHNOLOGY, LLC respectfully requests that the

Administrator grant this Petition for an exemption from the requirements

of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91. 417(a) & (b), and permit BLUESUIT TECHNOLOGY

, LLC Leading Edge to operate the

DJI Inspire 1 UAS commercially for the purpose of conducting aerial

video and p hotography over certain areas of the United States.

Dated: July 9

, 2015

Respectfully submitted

, 

# Sheila Walker

S heila Walker

, President
BLUESUIT TECHNOLOGY, LLC 8855 Villa Ridge Drive #1323 Fort Worth, TX 76108

Tel: ( 682 ) 235

- 7390

Appendices:

A

- DJI Inspire 1 Specifications Data Sheet

B

- DJI Inspire 1 Manufacturer's User Manual

C

- Monthl y Maintenance Log29 APPENDIX

– A

TECHNICAL SPECIFICATIONS

DJI INSPIRE 1

BLUESUIT TECHNOLOGY, LLC only utilizes safe and reliable UAS . DJI is an industry leader i n small UAS production. DJI UAS are loaded with ground breaking software enabling the user t o set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJI software prov ides real

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

1

. 1 DJI Inspire 1

1.1 .1 Aircraft

1.1 .1.1 Model

– T600

1.1 .1.2 Weight (Battery Included)

– 6lbs 7.5291oz (2935g)

1.1 .1.3 Hovering Accuracy (G PS Mode)

– Vertical: 0.5m; Horizontal: 2.5m

1.1 .1.4 Max Angular Velocity

– Pitch: 3000/s; Yaw: 1500/s

1.1 .1.5 Max Tilt Angle

- 350

1.1 .1.6 Max Ascent Speed

– 5m/s

1.1 .1.7 Max Descent Speed

– 4m/s

1.1 .1.8 Max Speed

– 22m/s (ATTI mode, no wind

– NOT RECOMMEN DED)

1.1 .1.9 Max Flight Altitude

– 4500m

1.1 .1.10 Max Wind Resistance

– 10m/s

1.1 .1.11 Max Flight Time

– Approximately 18 minutes

1.1 .1.12 Motor Model

– DJI 3510

1.1 .1.13 Propeller Model

– DJI 1345

1.1 .1.14 Operating Temperature Range

– 140F to 1040F (

- 100 C to 400C)

1

. 1 .1.15 Dimensions

– 17 1⁄4” x 17 3⁄4” x 12”

1

. 1 .2 Gimbal

1.1 .2.1 Model

– ZENMUSE X3

1.1

. 1.1 Output Power (with camera)

– Static: 9W; In Motion: 11W

1.1 .2.3 Operating Current

– Static: 750mA; In Motion: 900mA

1.1 .2.4 Angular Vibration Range

- ±0.030

1.1 .2.5 Mounting

– Detachable

1.1 .2.6 Controllable Range

– Pitch:

- 900 to +300; Pan: ±3200

1.1 .2.7 Mechanical Range

– Pitch:

- 1250 to 450; Pan: ±3300

1.1 .2.8 Max Controllable Speed

– Pitch: 1200/s; Pan: 1800/s

1.1 .3 Camera

1.1 .3.1 Name

– X3

1.1 .3.2 Model

– FC350

1.1 .3.3 Total Pixels

– 12.76M30 1.1 .3.4 Effective Pixels

– 12.4M

1.1 .3.5 Image Max Size

– 4000x3000

1.1 .3.6 ISO Range

– 100

- 3200

1.1 .3.7 Field of View

- 940

1.1 .3.8 CMOS

– Sony EXMOR 1/2.3”

1.1 .3.9 HD Video Recording

– UHD(4K):4096x2160p24/25, 3840x2160p24 /25/30; FHD: 1920x1080p24/25/30/48/50/60; HD: 1280x720p24/25/30/48/50/60

1.1 .3.10 Operating Temperature Range

- 320F

- 1040F (00C

- 400C)

1.1 .4 Transmitter

1.1 .4.1 Name

– C1

1.1 .4.2 Operating Frequency

– 5.728

- 5.850GHz; 2.400

- 2.483GHz

1.1 .4.3 Communicatin g Distance (unobstructed)

– 2000m

1.1 .4.4 Output Power

– 9W

1.1 .4.5 Operating Temperature Range

- 140F to 1040F (

- 100C to 400C)

1.1 .4.6 Battery

– 600mAh LiPo 2S31 APPENDIX

- B



### DJ I Insp i r e 1 Manufacturer’ s Use r M anua l

User manual can be found at:

http://www.dji.com/product/inspire

- 1/download32 APPENDIX

- C

MO N T H L Y MAI N T E N AN CE L O G

m on th : ' '' y e ar : ''

U AS ( #: ( D ate ' Is s u e '

Discovered D ate ' Is s u e '

Ad d res s ed Is s u e '' D e s c r i p ti on ' & ' Mai n te n an c e ' C ondu c te d Mai n te n an c e ' P e r f o r m e d ' b y : ''

P r i n t' & ' S i g n

S o f

tw ar e ' U pd ate s

A i r f ram e

Engines

Pro p el l ers

C am e r a' G i m b al

L an d i n g ' G e ar

V i b rati on ' D am p e n i n g

O th e r :