UNITED STATES OF AMERICA

DE PART MENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:
LOCKTON ENTERPRISES , INCORPORATED

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF
TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

, SECTION S 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 COMMERCIALOPERATION OF A
DJI PHANTOM 3 PROFESSIONAL UNMANNED AIRCRAFT SYSTEM

PURSUANT TO
SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)

Dated December 21 , 2015

Robert Hopson , Vice President Aviation Specialist Lockton Enterprises , Inc. 444 W. 47 th Street #900 Kansas City, Missouri 64112 Direct (816) 960

- 9143 Mobile : (816) 260

- 8044 Email : rhopson@ lockton.comLockton Enterprises , Inc. FMRA Section 333 Exemption Petition Page 2 of 24 SUMMARY

Pursuant to Section 333 of the Federal Aviation Administration (FAA) Modernization and Reform Act of 2012 (FMRA), S ub section (f) of 49 USC Section 44701, and 14 CFR Part 11, Lockton Enterprises , Incorporated, the Petitioner ( hereafter referred to as Lockton Enterprises )

, see ks exemption from the following listed Code of Federal Regulations (CFR): 14 CFR Section s 61.113(a) and (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (a)(2), and 91.417(a) and (b)

. This exemption will permit Lockton Enterprise s to operate a n unmanned aircraft system (UAS)
f

or the commercial purpose of conducting aerial video , photography, and data collection of client properties over certain areas of the United States in the furtherance of our insurance and risk management services, including assessment and valuation , loss prevention, claims management
and catastrophe response.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Lockton Enterprises provides its clients , in p a rt
, with a broad array of commercial insurance and other risk management services. Our objective is to safely provide high quality imaging and data
collection in the furtherance of the services we offer our clients

.

BACKGROUND

The DJI Phantom 3 Profession al is a vertical takeoff and landing (VTOL) u nmanned a ircraft (UA) with a g round c ontrol s tation (GCS) utilizing an electronic tablet or smart phone

. The DJI
Phantom 3 Professional is approximately 16 inches square, 8 inches high, with a maximum weight of less than 3 pounds and a maximum speed of approximately 31 knots. It is equipped with four main rotors, driven by l ithium

- p olymer battery

- powered electric motors.

The DJI Phantom 3 Professional UA that will be operated by Lockton Enterprises will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft , as well as 14 CFR Part 47, Aircraft Registration , and marked in accordance with 14 C FR Part 45, Identification and Registration Marking

.

BASIS FOR PETITION

The Petitioner, Lockton Enterprises

, pursuant to the provisions 14 C FR Section 11.61 (b) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereby petitions the Administrator to commercially operate th e DJI Phantom 3 Professional UA in the National Airspace System (NAS), and for an exemption from the requirements of 14 CFR Section s 6 1.113(a) and (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (a)(2), and 91.417(a) and (b).Lockton Enterprises , Inc. FMRA Section 333 Exemption Petition Page 3 of 24 In consideration of the modest speed, weight, size, and limited operating area associated with
the DJI Phantom 3 Professional UA , it meets the conditions of FMRA Section 333 and therefore requires no airworthiness cert ificate in accordance with 14 CFR Part 21, s ub p art H.

In accordance with 14 C FR Section 11.81 (a) through (e)

, Lockton Enterprises provides the following information in support of his petition for exemption:

NAME AND MAILING ADDRESS OF THE PETITIONER (14 CFR 11.81(a) )

The name and address of the Petitioner and point of contact (POC) is:

Lockton Enterprises , Inc. POC : Robert Hopson , Vice President
444 W. 47 th Street #900 Kansas City, MO 64112 Direct : (816) 960

- 9143 Mobile: (816) 260

- 8044 Email : rhopson@lockton.com

SPECIFIC SECTION S FOR WHICH EXEMPION IS SOUGHT (14 CFR 11.81(b) )

1. Section 61.113 , Private pilot privileges and limitations: Pilot in comman d Subsections (a)
and (b) :
(a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of
an aircraft that is ca rrying 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 business or employment if

— (1) T he flight is only incidental to that business or employment; and

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

2. Section 91.7, Civil Aircraft Airworthiness Subsection (a) :
(a) No person may operate a civil aircraft unless it is in an airworthy condition.

3. Section 91.121 , Altimeter Settings Subsection (a) :
(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the c ase 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;Lockton Enterprises , Inc. FMRA Section 333 Exemption Petition Page 4 of 24 (ii) If there is no station within the a rea prescribed in paragraph (a)(1)(i) of
this Section , the current reported altimeter setting of an appropriate available station; or

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

4. Section 91.151 , Fuel Requirements for Flight in VFR Conditions Subsection (b):

(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.

5. Section 91.405, Maintenance required Subsection (a):

Each owner or operator of an aircraft

— (a) Shall have that aircraft inspected as prescribed in S ub p art E of this Part and shall between required inspections, except as provided i n paragraph (c) of this Section , have discrepancies repaired as prescribed in Part 43 of this chapter[.]

6. Section 91.407, Operation after m aintenance, p reventive m aintenance, r ebuilding, or

a lteration , Subsection (a)(1) :
(a) No person may operate 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.

7. Section 91.409 , Inspections , Subsection (a):

(a) Except as provided in paragraph (c) of this Section , no person may operate an aircraft unless, within the preceding 12 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; or

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

8

. Section 91.417 , Maintenanc e Records , S ub s ection s (a) and (b) :
(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 :Lockton Enterprises , Inc. FMRA Section 333 Exemption Petition Page 5 of 24 (1) Records of the maintenance, preventive maintenance, and alteration and records
of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an 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 containing the following information:

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

(ii) The current statu s of life

- limited p art s of each airframe, engine, propeller, rotor, and appliance.

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

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

(v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, th e 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 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 s ection 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 s ection 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 this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.Lockton Enterprises , Inc. FMRA Section 333 Exemption Petition Page 6 of 24 EXTENT OF RELIEF SOUGHT AND REASONS (14 CFR 11.81(c))

1. Regulation and Extent of Relief Sought: 14 CFR Section 61.113(a) a nd (b)

Relief from Section 61.113(a) and (b)

, Private Pilot Privileges and Limitations: Pilot in command , is requested to the extent necessary to allow a PIC holding a sport pilot or higher level certificate, as well as a current and valid airman medical certificate or driver’s license , and who has met certain flight

- hour and currency requirements, to conduct the proposed UAS flight operations.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircr aft does not carry passengers or property for compensation or hire.

As set forth more fully below, Lockton Enterprises submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the DJI Phantom 3 Professional U A unless that PIC has met certain flight

- hour and currency requirements, demonstrating that the PIC is able to safely operate either the DJI Phantom 3 Professional UA in a manner consistent with the specifications as described in this exemption and FAA

- iss ued Conditions and Limitations

, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles, and structures.

Further, Lockton Enterprises submits that all flights of the DJI Phantom 3 Professional UA, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to Lockton Enterprises ’ business; (2) will not carry passengers or property for compensation or hire ; and (3) will be operated over areas of controlled access.

2. Regulation and Extent of Relief Sought: 14 CFR Section 91.7(a)

Relief from Section 91.7(a)

, Civil aircraft airworthiness , is requested to allow Lockton Enterprises to determine that the DJI Phantom 3 Professional UA is in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., Exemption Conditions and Limitations and the DJI Phantom 3 Professional User Manual ).

Lockton Enterprises see ks the relief because the DJI Phantom 3 Professional UA does not require an airworthiness certificate in accordance with 14 CFR Part 21, S ub p art H. Therefore, Lockton Enterprises will ensure that the DJI Phantom 3 Professional UA is in airworthy condition based upon its compliance with the operating documents (i.e., Exemption Conditions and
Limitations and the DJI Phantom 3 Professional User Manual ) prior to every flight, and further, determine that the aircraft is in condition for safe flight, as stated in the conditions and limitations below.Lockton Enterprises , Inc. FMRA Section 333 Exemption Petition Page 7 of 24 3. Regulation and Extent of Relief Sought: 14 CFR Section 91.121

Relief from Section 91.121, Altimeter s ettings

, is required to allow flight operations of the DJI Phantom 3 Professional UA, which utilizes 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 cont rol 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), Lockton Enterprises seeks relief because the DJI Phantom 3 Professional UA’s altime termay be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to com ply with the applicable conditions and limitations stated below. Asmore fully set forth herein, an equivalent level of safety will be maintained since the DJI Phantom 3 Professional UA is equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the PIC with altitude information of the UA on the heads

- up display of the GCS.

4. Regulation and Extent of Relief Sought: 14 CFR Section 9 1.151(b)

Relief from Section 91.151(b)

, Fuel Requirements for Flight in VFR Conditions , is requested to the extent required to allow flights of the battery

- powered DJI Phantom 3 Professional UA during daylight hours in visual meteorological conditions (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.

Lockton Enterprises seeks the relief because without an exempt ion from Section 91.151(b), the flight time duration of the battery

- powered DJI Phantom 3 Professional UA will severely constrain the practicality of any aerial video , still photography, or data collection proposed here.

Significantly, as set forth below, the technical specifications of the DJI Phantom 3 Professional UA, and Lockton Enterprises ’ proposed Co nditions and L imitations , ensure that Lockton Enterprises will safely operate the battery powered DJI Phantom 3 Professional 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 19 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minu tes.

5. Regulation and Extent of Relief Sought: 14 CFR Section s 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), a nd 91.417(a) & (b)

Since Section s 91.405(a), Maintenance r equired ; 91.407(a)(1), Operation after maintenance ; 91.409(a)(1) & (a)(2)

, Inspections ; and 91.417(a) & (b)

, Maintenance r ecords

, only apply to aircraft with an airworthiness certificate, Lockton Enterprises requests relief from these as the DJILockton Enterprises , Inc. FMRA Section 333 Exemption Petition Page 8 of 24 Phantom 3 Professional UA does not require an airworthiness certificate. As set forth more fully below, the DJI Phantom UAS meets the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, Lockton Enterprises will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS operating documents (i.e

., e xemption Conditions and Limitations and the DJI Phantom 3 Professional User Manual ). Furthermore, Lockton Enterprises will document and maintain all maintenance records for the DJI Phantom 3 Professional UAS.

REASONS WHY G RANTING THIS REQUEST WOULD BE IN THE PUBLIC
INTEREST (14 CFR 11. 81(d))

Granting th is Petition will further the public interest by allowing Lockton En terprises to safely, efficiently, and economically perform aerial video

, photography , and data collection of client properties over certain areas of the United State s.

Use of the DJI Phantom 3 Professional UAS in lieu of an aircraft will 1) decrease conges tio n of the NAS ; 2) reduce pollution and noise ; 3) provide significant benefits to the public ; 4) allow Lockton Enterprises to remain competitive; and 5) avoid privacy issues

.

1. The p ublic w ill b enefit f rom d ecreased c ongestion o f t he NAS

The DJI Phantom 3 Professional UA is battery powered and serves as a safe, efficient, and economical alternative to the manned aircraft traditionally ut ilized to obtain aerial imagery and data
collection. A n exemption allowing the use of a DJI Phantom 3 Profession al UAS would reduce
the number of manned aircraft in the NAS , particularly those loitering at a work site while taking photographs or collecting data.

2. The public will benefit from r educed pollution and n oise

R educing the number of manned aircraft operating in the NAS reduces congestion around airports caused by arriving and de p art ing aircraft , and increase the safety of life and property in the air and on the ground. The DJI Phantom 3 Professional UA does not require an airport to takeoff
or land

, and, in fact, will not be operated near airports

.

3

. The public will benefit from the safety and efficiency of the DJI Phantom 3 Professional
UAS

Conducting aerial video, photography, and data collection with the DJI Phantom 3 Professional UAS, instead of manned aircraft

, will benefit the public by substantially reducing the levels of air and noise pollution generated

. Using battery power and electric motors, the DJI Phantom 3 Professional UAS produce no end

- user air pollution, and is the most viable env ironmentallyLockton Enterprises , Inc. FMRA Section 333 Exemption Petition Page 9 of 24 conscious alternative to the internal combustion or turbine engine aircraft that are typically utilized for aerial video and photography

. Those non

- emission controlled engines typically burn approximately 10 to 2 5 gallons of leaded aviation ga soline or jet fuel per hour

. The DJI Phantom 3 Professional UA, while reducing the carbon footprint of aerial operations

, also virtually eliminates noise pollution . M anned aircraft are powered by a n engine that drives

a rotor system or propeller that produces considerable noise

.
U sing the DJI Phantom 3 Professional UAS to perform photography and data collection, any risk to life and property in the air and on the ground associated with traditional manned aircraft flight operations will be virtua lly eliminated. Aside from not having flight crew members , the
DJI Phantom 3 Professional UA weighs less than three pounds and carries no flammable fuel.

It s very low weight inherently has less physical potential for collateral damage to life and property compared to the manned aircraft weighing the thousands of pounds that it replaces.

Using the DJI Phantom 3 Professional UAS also eliminates the need for direct human access and proximity to points of interest, which can now be accomplished remotely. There will be no need for personnel to scale buildings, towers, structures, etc. under precarious conditions when the same observation and evaluation can be conducted in utter safety from the ground.

4

. The public will benefit by allow ing Lockton Enterprises to remain a competitive in the use of emerging technologies

In addition to being safe and efficient, the DJI Phantom 3 Professional UA is also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of
the DJI Phantom 3 Professional UAS will allow United States based companies, like Lockton Enterprises , to remain innovative and competitive

, and contribute to growth of the U.S. economy

Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (EPA) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive.

Operating the battery powered DJI Phantom 3 Professional UAS is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operati ng cost of a traditional manned aircraft.

5

. T he public will benefit as there a re n o p rivacy i ssues
Similar to the manned aerial acquisition flight operations that have been conducted for decades

, Lockton Enterprises ’ proposed operation of the DJI Phantom 3 Professional UAS will not implicate any privacy issues. Specifically, the DJI Phant om 3 Professional UAS will be operated only in compliance with operating documents which require property owner involvement as well as
occasional law enforcement cooperation

, ATC notification, and in accordance with the Federal Aviation Regulations, includ ing the minimum altitude requirements of 14 CFR § 91.119.Lockton Enterprises , Inc. FMRA Section 333 Exemption Petition Page 10 of 24 THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY, AND HOW THE EXEMPTION WOULD PROVIDE A LEVEL OF SAFETY AT LEAST EQUAL TO THAT PROVIDED BY THE RULE FROM WHICH
LOCKTON ENTERP RISES SEEKS EXEMPTION (14 CFR 11.81(e))

1. Reasons why the DJI Phantom 3 Professional UA meets the conditions of the FAA Modernization and Reform Act of 2012 (FMRA), Section 333
In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, Lockton Enterprises’ operation of the DJI Phantom 3 Professional UAS meets the conditions of FMRA Section 333, and will not req uire an airworthiness
certificate in accordance with 14 CFR Part 21, Sub p art H.

Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in p art :

(a) In General.

-- Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of en actment 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 re quired by Section 334 of this Act.

(b) Assessment of Unmanned Aircraft Systems.

-- In making the determination under
sub s ection (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 usersof the national airspace system or the public or pose a threat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under Section 44704 of title 49, United States Code, isrequired for the operation of unmanned aircraft systems identified under paragraph (1).

(c) Requirements for Safe Opera tion.

-- If the Secretary determines under this Section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airs pace system.Lockton Enterprises , Inc. FMRA Section 333 Exemption Petition Page 11 of 24 In seeking this exemption, Lockton Enterprises submits that the DJI Phantom 3 Professional UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by a) the characteristics of the DJI Phantom 3 Professional UA; b) the pilot certification requirement; and c) the specific operating limitations.

a. The s pecifications o f t he DJI Phantom 3 Professional UAS d emonstrate i ts

s afe c haracteristics

The DJI Phantom 3 Professional UAS does not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its modest size, weight, speed, limited operational range and endurance, and designed

- in safety featu res.

i

. Technical s pecifications Of The DJI Phantom 3 Professional UAS

The technical specifications of the DJI Phantom 3 Professional UAS are set forth by the DJI Phantom 3 Professional User Manual, attached as a link in Appendix A.

ii

. The DJI Phantom 3 Professional UAS a utonomous f light a nd n avigation

m odes e nable t he UAS t o r emain w ithin a d efined o perational a rea
The DJI Phantom 3 Professional UAS may be operated in both manual and fully autonomous flight modes. A complete descriptio n of the flight and navigational modes of the DJI Phantom 3 Professional UAS is provided at pages 11 through 15 of the DJI Phantom 3 Professional User Manual, attached as a link in Appendix A.

iii

. The DJI Phantom 3 Professional UAS are designed for automatic return
to home (RTH) point or hover in the event of loss of the c ontrol link or navigation

When the c ontrol l ink is lost, the DJI Phantom 3 Professional UA remain s stationary, in flight, for 3 seconds or more. If, after 3 seconds , the DJI Phantom 3 Professional UA does not reacquire control link data from the GCS, the UA will assume that the c ontrol l ink is lost and theUA will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff location and shutdown.

A complete description of the f ailsafe RTH f unction of the DJI Phantom 3 Professional UAS is
set forth at page 14 of the DJI Phantom 3 Professional User Manual, attached as a link in Appendix A.

iv. The DJI Phantom 3 Professional GCS and its operation

A complete description of the operation and specifications of the DJI Phantom 3 Professional GCS is provided at pages 23 through 29 of the DJI Phantom 3 Professional User Manual. A link
to the DJI Phantom 3 Professional User Manuals are attached as a link in Appendix A.Lockton Enterprises , Inc. FMRA Section 333 Exemption Petition Page 12 of 24 b. Flight o perations of DJI Phantom 3 Professional UAS a re l imited t o t he l ine

o f s ight o f a c ertificated Pilot in Command (PIC) w ith a Visual Observer ( V O)

A certificated pilot will be the only person to act as a PIC of the DJI Phantom 3 Professional UAS. Additionally, a qualified Visual Observer will assist during flight time.

c. Flights o f DJI Phantom 3 Professional UAS w ill b e c onducted p ursuant t o

s pecific Conditions and Li mitations

In seeking this exemption, Lockton Enterprises proposes to commercially operate DJI Phantom 3 Professional UAS for the special purpose of conducting aerial video

, photography , and data collection over certain areas of the United States, pursuant to the following Conditions and Limitations (or other such similar Conditions and Limitations as the FAA may issue) :

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 3 Profe ssional UA when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this e xemption.

2. Operations for the purpose of closed

- set motion picture and television filming are not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be op erated at airspeedsgreater than the maximum UA operating airspeed recommended by the aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA must be o perated within visual line of sight (VLOS) of the PIC at all times. Thisrequires 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 or U.S.
driver’s li cense.

6. All operations must utilize a visual observer (VO). The UA must be operated within thevisual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The

V O 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 theLockton Enterprises , Inc. FMRA Section 333 Exemption Petition Page 13 of 24 flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are
herei nafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the

p rocedures outlined in the operating documents, the conditions and limitations hereintake precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The operator must also present updated and revised documents if it pet itions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemptio n. The FAA’s UAS Integration Office (AFS−80) may be contacted if questions arise regarding updates or revisions to the operating document.

8. 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 afunctional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other pe ople. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prio r to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g., inoperable components, items, or equipment. If the inspect ion revealsa 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.

11. The operator must follow the UAS ma nufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.Lockton Enterprises , Inc. FMRA Section 333 Exemption Petition Page 14 of 24 12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial,private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto R ico, a territory, a possession, or the Federal government. The PIC must also meet the flight review requirements specified in 14 CFR §61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to op erate unless the PIC demonstrates the abilityto safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, ve hicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience

- building) and determini ng the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessi ons. During training, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, andthe PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 9 1.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

16. The UA may not operat e within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAA

- published
aeronautical char t, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcemen t official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.Lockton Enterprises , Inc. FMRA Section 333 Exemption Petition Page 15 of 24 18. For tethered UAS operations, the tether line must have colored pe nnants or streamers attached at not more than 50 foot intervals beginning at 150 feet above the surface of the earth and visible from at least one mile. This requirement for pennants or streamers is not applicable when operating exclusively below the top o f and within 250 feet of any structure, so long as the UA operation does not obscure the lighting of the structure.

19. If the UAS loses communications or loses its GPS signal, the UA must return to a pre

determined location within the private or controlled

- access property.

20. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

21. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for th e UA to conduct the intendedoperation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greate r.

22. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations sh all be conducted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be
conducted under the terms of the attached COA.

23. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

24. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PICat the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon
request.

25. The UA must remain clear and give way to all manned aviation operations and activities
at all times.

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

27. All f light operations must be conducted at least 500feet from all nonparticipating persons, vessels, vehicles, and structures unless:Lockton Enterprises , Inc. FMRA Section 333 Exemption Petition Page 16 of 24 a. Barriers or structures are present that sufficiently protect nonparticipating persons
from the UA and/or debris in the event of an ac cident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and
b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present
an undue hazard.

28. All operations shall be conducted over private or controlled

- access property with permission from the property owner/controller or authorized representative. Permission from
property owner/controller or authorized representative will be obtained for each flight to
be conducted.

29. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Website: www.ntsb.gov.

Unless otherwise specified in granting th is grant of exemption, the UAS, the UAS PIC, and the UAS operations will comply with all applicable parts of 14 CFR including, but not limited to,

P arts 45, 47, 61, and 91

.

2. Reasons w hy a n e xemption f rom t he r equirements o f Section 61.113(a) & (b) w ould

n ot a dversely a ffect s afety

Lockton Enterprises submits that the equivalent level of safety established by Section 61.113(a)
& (b) will be maintained because no PIC will be allowed to operate the DJI Phantom 3 Professional UAS unless that PIC has demonstra ted, by meeting minimum flight

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

Considering Lockton Enterprises’ proposed area of operations and the operating limitations set
forth above, the parallel nature of sport pilot aeronautical knowledge requirements to those of commercial p ilot requirements with regards to airspace, and the airmanship skills necessary toLockton Enterprises , Inc. FMRA Section 333 Exemption Petition Page 17 of 24 safely operate the DJI Phantom 3 Professional UAS, Lockton Enterprises submits that the additional manned a eronautical experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for Lockton Enterprises’ specific proposed flight operations.

The FAA has previously granted relief from Section 61.113(a) & (b) 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, 11158, 11159, 11160, 11161 , 1 2645 ).

Lockton Enterprises will not allow any PIC to operate the DJI Phantom 3 Professional UAS unless that PIC has demonstrated, by meeting minimum flight

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

Specifically, t he 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 (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 operat ions 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
ob tained in compliance with applicable regulations will ensure an equivalent level of safety during Lockton Enterprises’ proposed operati ons. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable r egulations would ensure safe operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for thepurpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a man ner 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 m inimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than additive;
i.e. 5 hours make and model time may be included in the 10 hours of multi

- rotor timeand 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 curr ency purposes). The FAA finds that at a minimum, the flight

- hour requirements in Exemption No. 11062 are appropriate to practice and buildLockton Enterprises , Inc. FMRA Section 333 Exemption Petition Page 18 of 24proficiency in the skills necessary to safely conduct the petitioner’s proposed operations. The FAA also finds that p rior documented flight experience that was obtained incompliance 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 requir ed flight time. During training, proficiency, and experience

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

3. Reasons w hy a n e xemption f rom t he r equirements o f Section 91.7(a) w ould n ot a dversely

a ffect s afety

The equivalent level of safety established by Section 91.7(a) will be maintained because prior to every flight, Lockton Enterprises will ensure that the DJI Phantom 3 Professional UAS is in an airworthy condition based upon comp liance with its operating documents and as stated in the
C onditions and L imitations herein.

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented he rein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161 , 12645 ).

4. Reasons w hy a n e xemption f rom t he r equirements o f Section 91.121 w ould n ot a dversely a ffect s afety

The equivalent level of safety established by Section 91.121 will be maintained because the altitude information of the DJI Phantom 3 Professional 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.

This altitude information, combined with Lockton Enterprises’ operation of the DJI Phantom 3 Professional UA within visual line of sight, at or below 4 00 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. P rior 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 all material respects, to those present ed herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161 , 12645 ).

5. Reasons w hy a n e xemption f rom t he r equirements o f Section 91.151(b) w ould n ot

a dversely a ffect s afetyLockton Enterprises , Inc. FMRA Section 333 Exemption Petition Page 19 of 24 A grant of this exemption would ensure an equivalent level of safety established by 14 CFR Section 91.151(b) as a result of ( 1) the technical specifications of the DJI Phantom 3 Professional UAS; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, Lockton Enterprises will ensure that it will safely operate the battery

- powered DJI Phantom 3 Professional UA during daylight hours in VFR conditions, with enough batte ry power to fly for a total duration of approximately 18 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 5 minutes.

Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 3 Professional UAS, the Conditions and Limitations on the proposed flight operations, and the location of the proposed operations, will ensure an equivalent level of safety established by 14 CFR
Section 91.151(b).

The DJI Phantom 3 Professional U AS provides audible and visual warnings to the PIC at theGCS when the UA experiences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and again at approximate ly 10% remaining battery power (warning thresholds are user programmable). At the critically low battery level, the DJI Phantom 3 Professional UAS will descend and land automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely af fected when the technical characteristics and operating limitations of theUAS 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. Mo reover, 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 , 12645 ).

6. Reasons w hy a n e xemption from t he r equirements o f Section s 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), a nd 91.417(a) & (b) w ould n ot a dversely a ffect s afety

In seeking this exemption, Lockton Enterprises submits that the equivalent level of safety with regard to the regulatory maintenance and alteration requirements established by Section s 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because Lockton Enterprises will use technicians to perform maintenance, preventive maintenance , or alterations on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e. t he e xemption Conditions and Limitations and the DJI Phantom 3 Professional User Manual ). Furthermore, Lockton Enterprises will document and maintain all maintenance records for the
DJI Phantom 3 Professional UAS.

Since the DJI Phantom 3 Professional UAS will be inspected as prescribed by the operating documents, Lockton Enterprises will maintain the equivalent level of safety established byLockton Enterprises , Inc. FMRA Section 333 Exemption Petition Page 20 of 24 Section s 91.405(a), 91.409(a)(1), and 91.409(a)(2). A link to the DJI Phant om 3 Professional
User Manual is attached in Appendix A; a copy of Lockton Enterprises’ DJI Phantom 3 Professional UAS Maintenance L og is attached hereto as Appendix B.

Likewise, the exemption sought will not adversely affect safety because Lockton Enterprises will use technicians to perform maintenance, alterations or preventive maintenanceon the UAS using the methods, techniques, and practices prescribed by the operating documents.
Significantly, previous exemptions granted by the FAA concerning Section s 91.405(a),91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered.

In consideration of Lockton Enterprises’ p roposed Conditions and Limitations , the operating documents, and the technical aspects of the DJI Phantom 3 Professional UAS, Lockton Enterprises submits that safety will not be adversely affected by granting exemption from 14 CFR
Section s 91.405(a), 91.40 7(a)(1) & (a)(2), 91.409(a)(2), and 91.417(a) & (b). The FAA has previously granted relief specific to UAS in circumstances similar, in all material respects, to those presented herein (e.g.

, Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161

, 12645 ).

7. The FAA m ay p rescribe a ny o ther c onditions f or s afe o peration

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA)
and 14 CFR § 21.16

, Special Conditions, Lockton Enterprises requests that the FAA prescribe special conditions for the intended operation of the DJI Phantom 3 Professional UAS, which
contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 CFR Part 21, Sub p art H, and 14 CFR §§ 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 UA for the limited purpose of conducting aerial video

, photography , and data collection over certain areas of the United States in the
furtherance of our business . 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 threatto national security; and further, provides the authority for such UAS to operate without airworthiness certif ication 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 CFR § 21.16, for operation of the DJI Phantom 3 Professional UA S, since the airworthiness regulations of 14 CFR Part 21 do not contain adequate or appropriate safety standards, dueLockton Enterprises , Inc. FMRA Section 333 Exemption Petition Page 21 of 24 to the novel or unusual design features of the aircraft. Section 21.16, 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 propeller because of a novel or unusual design feature of the aircraft, aircraft engine or p ropeller, 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 find s necessary to establish a level of safety equivalent to that established in the regulations.

Therefore, in accordance with FMRA Section 333 and 14 CFR § 21.16, the FAA may prescribe special conditions for Lockton Enterprises’ intended operation of the DJ I Phantom 3 Professional UAS, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 CFR Part 21, Sub p art H, and 14 CFR
Section s 61.113(a) & (b), 91.7(a), 91.121, 91.15 1(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER (14 CFR 11.81(f))

Lockton Enterprises , Inc. , Kansas City, Missouri, seeks exemption from the requirements of
14 CFR 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) . This exemption will permit Lockton Enterprises

,Inc. to commercially operate an unmanned aircraft system (UAS) for the purpose of conducting a erial video, photography and data collection over certain areas of the United States.

ADDITIONAL INFORMATION, VIEWS OR ARGUMENTS TO SUPPORT THIS REQUEST (14 CFR 11.81(g))

The FAA has set precedence by previously granted exemptions in circumstances similar , in a ll material respects, to those presented herein.

USE OF THIS EXEMPTION OUTSIDE THE UNITED STATES ; REASONS WHY (14 CFR 11.81(h))

No operations outside of the United States are sought.

CONCLUSION

As set forth herein, Lockton Enterprises seeks an exemption pursuant to 14 CFR § 11.61 and
Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safeoperation of the DJI Phantom 3 Professional UAS commercially, without an airworthiness certificate, for the limite d purpose of conducting aerial video

, photography , and data collection overLockton Enterprises , Inc. FMRA Section 333 Exemption Petition Page 22 of 24certain 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, w hile also advancing the interests of the public, by allowing Lockton Enterprises to safely, efficiently, and economically operate the DJI Phantom 3 Professional UAS commercially within the NAS.

WHEREFORE , in accordance with the Title 49 of the United Stat es Code, Title 14 Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, Lockton Enterprises respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 CF R Section s 61 .113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Lockton Enterprises to operate the DJI Phantom 3 Professional UAS commercially for the purpose of conducting aerial video

, photograph y , and data collection over certain areas of the United States.

Respectfully submitted,

Robert Hopson

Lockton Enterprises , Inc.

Dated: December 21 , 2015Lockton Enterprises , Inc. FMRA Section 333 Exemption Petition Page 2 3 of 24 APPENDIX A

DJI Phantom 3 Professional In the Box:

http://download.dji

- innovations.com/downloads/phantom_3/en/Phantom_3_Professional_In_the_Box_en_0901.pdf

DJI Phantom 3 Professional Quic k Start Guide:

http://download.dji

- innovations.com/downloads/phantom_3/en/Phantom_3_Professional_Quick_Start_Guide_en_v1.2.pdf

DJI Phantom 3 Professional User Manual:

http://download.dji

- innovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.6_en.pdf

DJI Phantom 3 Professional Intelligent Flight Battery Safety Guidelines:

http://download.dji

- innovations.com/downloads/phantom_3/en/Intelligent_Flight_Battery_Safety_Guidelines_en.pdf

DJI Phantom 3 Professional Safety Guidelines and Disclaimer:

http://download.dji

- innovations.com/downloads/phantom_3/en/Safety_Guidelines_Disclaimer_en_201509.pdfLockton Enterprises , Inc. FMRA Section 333 Exemption Petition Page 24 of 24 APPENDIX B



### Lockton Enterprises DJ I Phantom 3 Professional UAS Aircraft Log
N number_________ Serial number______________

NOTE : All inspections, maintenance, preventive maintenance , or alterations must be accomplished using the methods, techniques, and practices prescribed by the operating documents , manufacturer’s manuals

, and any FAA

- issued C onditions and L imitations

. Following any maintenance or alterations that affect the UAS operation or flight characteristics, e.g., replacement of a flight critical component, the aircraft must undergo a functional test flight prior to conducting further operations under this exemption

. See exemption Conditions and Limitations regarding functional test flights.

Firmware updates a nd DJI GO app iOS/Android version updates will be considered alterations.

Aircraft L og b ook page sample:

D ate Cumulative

H ours Discrepancy

o r Event Description of Inspection
, Maintenance , or Alteration Performed Returned to Service by

Safety B ulletin and Notice C ompliance page sample :

Date Cumulative

Hours Safety Bulletin
or Notice Description of Inspection
, Maintenance , or Alteration Performed Returned to Service by

Remote Controller and iOS /Android Version L ogbook page sample :

Date Device Discrepancy
or Event Description of Inspection
, Maintenance , or Alteration Performed Returned to Service by

( Above samples are representative of content only. Actual l ogbook pages will be maintained in a landscape format on page widths of at least 11 inches and will have data blocks of sufficient size so as to accommodate legible entries .)