UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINI STRATION WASHI NGTON, DC

**Exemption Request under Section 333 of the FAA Reform Act and Part 11 of**  **the Federal Aviation**  **Regulations**

**Submitted on Monday, June 15,**  **2015** Nigel Martin 15143 Leicestershire St. Woodbridge VA 22191 202

- 631

- 5626**SUMMARY**

NI GEL MARTIN seeks exemption from the requirements 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 (FMRA). This exemption will permit NI GEL MARTIN to operate an Unmanned Aircraft System (UAV) for the commercial purpose of conducting aerial video and photography in the United States.

**INTRODUCTION AND INTERESTS OF THE**

**PETITIONER**
NI GEL MARTIN provides his clients with photography and videography for the purpose of advertising and filmmaking

. NI GEL MARTIN has hundreds of hours fl ying experience. He has 2 ye ars recreational/hobby experience in all aspects of aerial video and photography. The objective of NI GEL MARTIN and his aerial operations is to provide high quality imaging for a variety of commercial, public, and residential uses, specificall y targeting:

• Advertising

• Filmmaking

**BACKGROUND** Unmanned Aircraft Systems: DJI Inspire 1 UAV
NI GEL MARTIN seeks an exemption to operate DJIs ystems for compensation or hire within the NAS. The DJ I In spire 1 is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The DJ I Inspire 1 has a maximum gross weight of approximately 6.5 pounds, while having a length of 17.75 inches width of 17.24 inches and a height of 11.85 inches, and a maximum speed of approximately 42.76 knots. The DJ I Inspire 1 UAV is equipped with four main rotors; driven by Lithium Poly

mer battery powered electric motors.**BASIS FOR PETITION** 

Petitioner, NI GEL MARTIN , pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereb y petitions the Administrator to commercially operate the DJ I Inspire 1 UAV in the National Airspace System (NAS), and for an exemption from the requirements 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 operation, NI GEL MARTIN ’s operation of DJ I Inspire 1 UAV meet 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. Accordingl y, NI GEL MARTIN requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate.
NI GEL MARTIN submits that the requested relief is proper since an equivalent level of safety will be ensured. NI GEL MARTIN will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UAV using the methods, techniques, and practices prescribed in the operating documents (i.e., DJI Inspire 1 Maintenance Manual v1.0, DJI Inspire 1 User Manual (EN) v1.2, and DJ I In spire 1 Safety Guidelines v1.0 ). Furthermore, NI GEL MARTIN will document and maintain all maintenance records for the DJ I Inspire 1 UAV

.
Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested by NI GEL MARTIN to the extent necessary

to allow a Pilot in Command (PIC) holding a private pilot or higher level 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 operate the DJ I Inspire 1 UAV in a manner consistent with this exemption, including evasive and emergency

maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.NI GEL MARTIN seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness ,

because the DJ I Inspire 1 UAV do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, NI GEL MARTIN submits that he will ensure that the DJ I Inspire 1 UAV is in an airworthy condition, prior to every flight, by determining that the UAV is in compliance with the operating documents (i.e., Monthly Maintenance Lo g, and DJI Inspire 1 Instruction Manual), and that the aircraft are in a condition for safe flight.
NI GEL MARTIN also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , as the DJ I Inspire 1 UA will not have a ty pical barometric altimeter onboard. However, altitude information of the DJ I Inspire 1 UA will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with NI GEL MARTI N ’s operation of the DJ I Inspire 1 UAV within visual line of sight, at or below 3 00 feet AGL, will ensure a level of safety equivalent to Section 91.121. Additionally, NI GEL MARTIN seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions

. NI GEL MARTI N submits that safety

will not be affected by

operation of the DJ I Inspire 1 UA in visual meteorological conditions (VMC) under visual flight rules (VFR), with a minimum of 30% battery power to fl y to the first point of intended landing

. In accordance with 14 C.F.R. § 11.81, NIGEL MARTI N provides the following information in support of its petition for exemption:
**A. Name And**  **Address Of The Petitioner.**  The name and address of the Petitioner and point of contact is: NI GEL MARTIN 15143 Leicestershire St. Woodbridge VA 22191
202

- 631

- 5626**B. The Specific Sections Of 14**  **C.F.R. From Which**  **NIGEL MARTIN Seeks** 

**Exemption.**
**1. NIGEL MARTIN**  **Seeks Exemption From The Requirements Of Section**  **61.113(a) And (b).**  Section 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 business or employment if

— (1) The flight is onl y incidental to that business or employment; and(2) The aircraft does not carry passengers or property

for compensation or hire. **2. NIGEL MARTIN**  **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. **3. NIGEL MARTIN**  **Seeks Exemption From The Requirements Of Section**  **91.121.**

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, b y reference to an altimeter that is set, when operating

-- (1) Below 18,000 feet MSL, to
--

(i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure.**4. NIGEL MARTIN**  **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 following:

(b ) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 min utes.
**5. NIGEL MARTIN**  **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 have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.]
**6. NIGEL MARTIN**  **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 that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

-- (1) It has been approved for return to service b y a person authorized under § 43.7 of this chapter[.]**7. NIGEL MARTIN**  **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 months, it has had

-- (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service b y 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. NIGEL**  **MARTIN 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 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 status of life

- limited parts 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 aircraft, 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, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next acti on is required. (vi) Copies of the forms prescribed b y § 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 ye ar 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 this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.**C. The Extent Of Relief**  **NIGEL MARTIN Seeks And The Reason** 

**NIGEL MARTIN Seeks The**  **Relief.**
**1. Extent Of Relief**  **NIGEL MARTIN Seeks And The Reason**  **NIGEL MARTIN**  **Seeks Relief From Section 61.113(a) And (b).**  Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command, is requested to the extent necessary 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 UAV flight operations for compensation 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 emplo ym ent if: (1) The flight is only incidental to that business or employ ment; and (2) The aircraft does not carry passengers or property

for compensation or hire. As set forth more full y below, NIGEL MARTIN submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the DJ I Inspire 1 UAV unless that PIC has met certain flight

-hour and currency requirements, demonstrating that the PIC is able to safel y operate either the DJ I Inspire 1 UAV in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency

maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures. Further, NI GEL MARTIN submits that all flights of the DJ I Inspire 1 UAV , conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to NIGEL MARTI N ’s business; and (2) will not carry passengers or property for compensation or hire.**2. Extent Of Relief**  **NIGEL MARTIN Seeks And The Reason**  **NIGEL MARTIN**  **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 NI GEL MARTI N to determine that the DJ I Inspire 1 UAV is in airworthy condition prior to every flight b y ensuring that the UAV is in compliance with the operating documents (i.e., the NI GEL MARTIN Aerial Operations Manual, Monthly Maintenance Lo g, and DJI INSPIRE 1 Instruction Manual).
NI GEL MARTIN seeks the requested relief because the DJ I Inspire 1 UAV do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, NI GEL MARTIN will ensure that the DJ I Inspire 1 UAV is in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual) prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated in the conditions and limitations below.

**3. Extent Of Relief**  **NIGEL MARTIN Seeks And The Reason**  **NIGEL MARTIN**  **Seeks Relief From Section 91.121.** 

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the DJ I Inspire 1 UAV , which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAV operations be reported to air traffic control (ATC) in feet above ground level (AGL), NI GEL MARTIN seeks the requested relief because the DJ I Inspire 1 UA’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight. 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 level of safety will be maintained since the DJ I Inspire 1 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. Extent Of Relief**  **NIGEL MARTIN Seeks And The Reason**  **NIGEL MARTIN Seeks Relief From Sectio**  **n 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 DJ I Inspire UA in visual meteorological conditions (VMC) under visual flight rules (VFR), with a minimum of 30% battery power to fly to the first point of intended landing. NI GEL MARTI N seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery

powered DJ I Inspire 1 UA will severel y constrain the practicality of any aerial video or still photo flight operations that NI GEL MARTIN proposes to conduct pursuant to this Petition. Signifi cantl y, as set forth below, the technical specifications of the DJ I Inspire 1 UAV , the DJ I Inspire 1 operating documents, and NI GEL MARTI N ’s proposed operating limitations, ensure that NIGEL MARTIN will safely operate the battery

powered DJ I Inspire 1 UA in visual meteorological conditions (VMC), under visual flight rules (VFR), with a minimum of 30% battery power to fly

to the first point of intended landing

. **5. Extent Of Relief**  **NIGEL MARTIN Seeks And The Reason**  **NIGEL MARTIN**  **Seeks Relief From Sections 91.40 5(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 a ppl y to aircraft with an airworthiness certificate, NI GEL MARTIN requests relief from these Sections because the DJ I Inspire 1 UAV do es not require an airworthiness certificate. As set forth more full y below, the DJ I Inspire 1 UAV meet s the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingl y, NI GEL MARTIN will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAV using the methods, techniques, and practices prescribed in the UAV operating documents (i.e., the NI GEL MARTIN Aerial Operations Manual, Monthly M aintenance Lo g, and DJ I Inspire 1 Instruction Manual). Furthermore, NI GEL MARTIN will document and maintain all maintenance records for the DJ I Inspire 1 UAV

.**D. The Reasons Why Granting**  **NIGEL MARTIN 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 b y allowing NIGELMARTIN to safely, efficientl y, and economicall y perform aerial video and photography in the United States. Additionally, use of the DJI Inspire 1 UAV will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of NI GEL MARTIN ’s proposed operation of the DJ I In spire 1 UAV will be realized without implicating any privacy issues.
**1. The Public Will Benefit From Decreased Congestion Of The**  **NAS.** The DJ I Inspire 1 UA is 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 DJ I Inspire 1 UAV 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, b y reducing the number of manned aircraft operating in the NAS, congestion around airports caused b y arriving and departing aircraft will be reduced. The DJI Inspire 1 UA do es 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**  **UAV .** 
Conducting aerial acquisitions with the DJIPhantom 2 and DJ I Phantom 3 UAV s, instead of manned aircraft, will greatly benefit the public by drasticall y reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By

using battery

power and electric motors, the DJ I Inspire 1 UAV produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically utilized for aerial video and photography, while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The DJ I In spire 1 UA, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UA is propelled b y battery powered electric motors, rather than an inter nal combustion engine. By using the DJ I Inspire 1 UAV 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 substanti ally reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJ I Inspire 1 UA has less phys ical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that ty pically 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**  **UAV Will Benefit The**  **Economy.**

In addition to being safe and efficient, the DJ I Inspire 1 UAV is also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJ I Inspire 1 UAV will allow United States based companies, like NI GEL MARTIN , to remain competitive and contribute to growth of the U.S. economy. Specificall y, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out l eaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery powered DJ I Inspire 1 UAV is one such technology that not only

allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditionalmanned aircraft.

By operating the DJ I Inspire 1 UAV , companies such as NI GEL MARTIN , can remain competitive and profitable, and there fore, 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 commercialuse of the DJI Inspire 1 UAV , provides a stable workforce that 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 the manned aerial acquisition flight operations that have been conducted for decades, NI GEL MARTIN ’s proposed operation of the DJ I Inspire 1 UAV will not implicate any

privacy issues. Specificall y, the DJ I In spire 1 UAV will be operated onl y in compliance with operating documents (i.e., the NIGELMARTIN Aerial Operations Manual, Monthly

Maintenance Log, and DJ I Inspire 1 Instruction Manual) which requires property owner involvement as well as local law enforcement notification, and in accordance with the Fe deral Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.
**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**  **NIGEL MARTIN Seeks**  **Exemption.**

**1. Reasons**  **Why The**  **DJI Inspire**  **1 UA**  **Meet s**  **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, NI GEL MARTIN ’s operation of the DJI Inspire 1 UAV meet s the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Section 333 provides authority for a UAV to operate without airworthiness certification and sets forth requirements for considering whether a UAV will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part:(a) In General.

--Notwithstanding any other requirement 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 determination 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 44704 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 may 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, NI GEL MARTIN submits that the DJI Inspire 1 UAV can operate safel y in the NAS pursuant to FMRA Section 333, as demonstrated by : (a) the characteristics of the DJ I Inspire 1 UAV ; (b) the pilot certification requirement; and (c) the specific operating limitations.**a. The Specifications Of The DJI**  **Inspire 1 UAV**  **Demonstrate s**  **Its Safe**  **Characteristics.**

The DJ I Inspire 1 UAV do es 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. Technical Specifications Of The DJI**  **Inspire 1 UAV**  **.**

The technical specifications of the DJ I Inspire 1 is set forth by the DJ I Inspire 1 User Manual, attached hereto as Appendix A.

**ii. The DJI**  **Inspire 1 UAV**  **Autonomous Flight And**  **Navigation Modes Enable The**  **UAV To**  **Remain Within A Defined Operational**  **Area.**

The DJ I Inspire 1 UAV may be operated in both manual and fully autonomous flight modes. A complete description of the flight and navigational modes of the DJI Inspire 1 UAV is provided in the DJI Inspire 1 User Manual, attached hereto as Appendix A

.

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

When the Control Link is lost, the DJI Inspire 1 UA will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJ I Phantom 2 and DJI Phantom 3 UAV do not reacquire control link data from the GCS, the UAV 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 of the DJ I Inspire 1 UAV is set forth in the User Manual, attached hereto as Appendix A.**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 in the User Manual attached hereto as Appendix A.

**b. Flight Operations Of DJI**  **Inspire 1 UAV**  **is Limited**  **To The Line Of**  **Sight Of A Certificated Pilot in Command With A Safety**  **Observer.**

NI GEL MARTIN will be the only person to act as a pilot in command (PIC) of the DJ I Inspire 1 UAV

. Additionally, a safety observer will assist in flights.

**c. Flights Of DJI**  **Inspire 1 UAV**  **Will Be Conducted Pursuant**  **To Specific Operating**  **Limitations.**

In seeking this exemption, NI GEL MARTIN proposes to commerciall y operate DJ I Inspire 1 UAV for the special purpose of conducting aerial video and photography over certain areas of United States, pursuant to the following specific operating limitations:

1. Operations authorized b y this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UAV s weighing less than 55 pounds maximum gross weight: DJ I Inspire 1 Unmanned Aircraft System. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant.

2. UAV operations under this exemption will be limited to conducting operations for the purpose of aerial video and photography.

3. The UA may

not be flown at an indicated airspeed exceeding 20 knots.

4. The UA must be operated at an altitude of no more than 3 00 feet above ground level (AGL), as indicated b y the procedures specified in the operatingdocuments unless a special request is made and approved b y 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 PI C 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 and avoiding other air traffic and other ground based obstacles/ obstructions and is not permitted to operate the camera or other instruments.

9. The operating documents and the grant of exemption must be accessible during UAV operations and made available to the Administrator upon request. If a discrepancy

exists between the conditions and limitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisionsand 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 revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its grant of exemption. The FAA’s UAV 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 UAV to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAV , the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAV is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records.

11. Any UAV that has undergone maintenance or alterations that affe ct the UAV operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraft records.

12. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents.

13. The operator must follow the UAV 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 authorized person returning the UAV to service.

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

16. The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections.
17. The operator may

not permit any

PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safel y operate the UAV in a manner consistent with how the UAV will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PI C 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 arepermitted 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 from nonparticipants in accordance with 14 C.F.R. § 91.119.

18. UAV 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.19. 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 management must be made available to the Administrator upon request.

20. 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.

21. If the UA loses communications or loses its GPS signal, it must return to a pre - determined location within the planned operating area and land or be recovered in accordance with the operating documents.

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

23. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fl y at normal cruising speed to the intended landing point and land the UA with 25% battery power remaining.24. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requirements.

25. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (N

- Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable.

26. Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.

27. 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 UAV any time the UAV is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

28. The UA must remain clear and yi eld the right of way to all manned aviation operations and activities at all times.

29. The UAV may

not be operated by

the PIC from any

moving device or vehicle.30. Flight operations must be conducted at least 2 00 feet from all nonparticipating persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 2 00 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 permission 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).

31. 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 authorized representative will be obtained for each flight to be conducted.

32. 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 UAV 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**2. Reasons Why An Exemption From The Requirements Of**  **Section 61.113(a) And (b) Would Not Adversely Affect**  **Safety.**

NI GEL MARTIN 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 DJ I Inspire 1 UAV unless that PIC has demonstrated, by meeting minimum flight

-hour and currency requirements, that the PIC is able to safely operate the DJ I Inspire 1 UAV in a manner cons istent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering NI GEL MARTI N ’s proposed area of operations, and the operating limitations set forth

- above; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary

to safely operate the DJ I Inspire 1 UAV , NI GEL MARTIN submits that the additional manned airmanship experience of a commerciall y certificated pilot would not correlate to the airmanship skills necessary for NI GEL MARTIN ’s specific proposed flight operations. The FAA has previousl y granted relief from Section 61.113(a) and (b) specific to UAV , 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). NI GEL MARTIN will not allow any PIC to operate the DJ I Inspire 1 UAV unless that PIC has demonstrated, b y meeting minimum flight

-hour requirements or the DJI Inspire 1 UAV training and currency

requirements, that the PIC is able to safel y operate the DJ I Inspire 1 UAV in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Specificall y, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAV rotorcraft pilot (with a minimum of 5 hours of those hours as a UAV pilot operating the same make and model of UAV to be used for operations under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes).As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that

was obtained in compliance with applicable regulations will ensure an equivalent level of safety during NI GEL MARTIN ’s 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 UAV rotorcraft pilot including at least 10 hours logged as a UAV pilot with a multi

-rotor UAV . Prior to operations under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of 5 hours as a UAV pilot operating the same make and model of UAV to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi

-rotor time and the 10 hours may be included in the total 25 hours of UAV 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

-hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary to safel y conduct the petitioner’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance 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

building 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. Accordingl y, NI GEL MARTIN will ensure safe operations b y not allowing any P IC to operate the DJ I Inspire 1 UAV unless that PIC has demonstrated, by meeting minimum flight

-hour and currency

requirements, that the PIC is able to safel y operate the DJ I Inspire 1 UAV in a manner consi stent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.**3. Reasons Why An Exemption From The Requirements Of Section**  **91.7(a) Would Not Adversely Affect**  **Safety.**

The equivalent level of safety established b y Section 91.7(a) will be maintained because prior to every

flight, NI GELMARTIN will ensure that the In spire 1 UAV is in an airworthy condition based upon the UAV ’s compliance with its operating documents and as stated in the conditions and limitations herein. Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAV , 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 b y Section 91.121 will be maintained because the altitude information of the DJ I 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. This altitude information, combined with NI GEL MARTI N ’s operation of the DJ I Inspire 1 UA within visual line of sight, at or below 3 00 feet AGL , will ensure a level of safety equivalent to Se ction 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 UAV s at ground level. The FAA has previousl y granted relief from Section 91.121 specific to UAV , in circumstances similar, 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 Requirements 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 UAV ; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingl y, NI GEL MARTI N will ensure that it will safely operate the battery

powered DJ I Inspire 1 UA during daylight hours in VFR conditions, with at least 30% battery

power to fl y to the first point of intended landing. Here, as in Exemption No. 11109, the technical specifications of the DJ I In spire 1 UAV ; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safety established b y 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJ I Inspire 1 UAV provide audible and visual warnings to the PIC at the GCS when the UAV experiences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and again at approximately

10% remaining battery power. At the criticall y low battery level, the DJ I Inspire 1 UAV will descend and land automatically

. Significantl y, previous exemptions granted b y the FAA concerning Section 91.151 establish that safety i s not adversel y affected when the technical characteristics and operating limitations of the UAV are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to UAV , 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, NI GEL MARTIN 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 NI GEL MARTIN will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAV s using the methods, techniques, and practices prescribed in the operating documents (i.e., the NIGELMARTIN Aerial Operations Manual, Monthly

Maintenance Log, and DJ I Inspire 1 Instruction Manual). Furthermore, NI GEL MARTIN will document and maintain all maintenance records for the DJ I Inspire 1 UAV

. Since the DJ I Inspire 1 UAV will be inspected as prescribed b y the operating documents, NI GEL MARTIN will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJ I Inspire 1 User Manual is attached hereto as Appendix A; a copy of the DJ I Inspire 1 UAV Maintenance LOG is attached hereto as Appendix B

. Likewise, the exemption sought will not adversely affect safety because NIGELMARTIN will use trained technicians to perform maintenance, alterations or preventive maintenance on the UAV using the methods, techniques, and practices prescribed by the operating documents. Furthermore, the exemption sought would maintain an equivalent level of safety established by

Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI Inspire 1 UAV will be performed b y trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log. Significantly, previous exemptions granted b y 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 adversel y affected when the technical characteristics and operating limitations of the UAV are considered. In consideration of NI GEL MARTIN ’s proposed operating limitations, the operating documents, and the technical aspects of the DJ I In spire 1 UAV , NI GEL MARTIN submits that safety will not be adversel y affected b y granting exemption from 14 C.F.R. Sections91.405(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 UAV in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). **7. The**  **FAA May Prescribe Any Other Conditions For Safe**  **Operation.** In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, NIGEL MARTIN requests that the FAA prescribe special conditions for the intended operation of the DJ I Inspire 1 UAV , which contain such safety standards that the Administrator finds necessary to establish a level of safety

equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special c onditions will permit safe operation of the UAV for the limited purpose of conducting aerial video and photography over certain areas of the United States for compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a UAV 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 UAV to operate without airworthiness certification in accordance with any requirements that must be established for the safe operation of the UAV in the NAS. Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of the DJ I Inspire 1 UAV , since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special Conditions, states the following: If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety

standards for the aircraft, aircraft engine or propeller as the FAA finds necessary

to establish a level of safety equivalent to that esta

blished in the regulations.

See 14 C.F.R. § 21.16.Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may

prescribe special conditions for Leading Edge’s intended operation of the DJI Inspire 1 UAV , 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).

**• A Summary That Can Be Published In The Federal**  **Register, stating: The Rules From Which**  **NIGEL MARTIN Seeks**  **Exemption:**

NIGEL MARTIN seeks 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 NIGEL MARTIN**  **Seeks:**

This exemption will permit NIGEL MARTIN to commercially operate an Unmanned Aircraft System ( UAV ) for the purpose of conducting aerial video and ph otography in the United States.

**• Any**  **Additional Information,**  **Views, Or**  **Arguments Available**  **To Support**  **NIGEL MARTIN ’s**  **Request.**

This Petition is made pursuant to the FAA Modernization and Reform Act of2012 (FMRA) Section 333, which directs the Secretary o f Transportation to determine if certain UAV may

operate safel y in the NAS. As such, NI GEL MARTIN ’s request for exemption may

b e granted pursuant to the authority o f FMRA Section 333 and 14 C.F.R. Part 11, as set forth above.FMRA Section 333 sets forth the requirements for considering whether a UAV 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 UAV to operate without airworthiness certification. As discussed in detail above, NI GEL MARTIN will operate the DJ I Inspire 1 UAV safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security

.**CONCLUSION**

As set forth herein, NI GELMARTIN seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJ I Inspire 1 UAV commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing NI GEL MARTI N to safely, efficientl y, and economically operate the DJI Inspire 1 UAV commercially within the NAS. **WHEREFORE** , in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, NI GEL MARTIN 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)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Leading Edge to operate the DJ I Inspire 1 UAV commerciall y for the purpose of conducting aerial video and photography over certain areas of the United States. Dated: April 20, 2015

Respectfully submitted,

NI GEL MARTIN

15143 Leicestershire St Woodbridge , VA 22191 202

- 631

- 5626Appendices :

A

– DJ I Inspire 1 User Manual: B

– Monthly

Maintenance Lo g C

– DJIInspire 1 Technical SpecificationsAPPENDIX

– C **DJI PHANTOM 2 VISION+ TECHNICAL SPECIFICATIONS** Aircraft Model: T600 Weight (Battery Included): 2935 g Hovering Accuracy (GPS Mode): Vertical: 0.5 m, Horizontal: 2.5 m Max Angular Velocity: Pitch: 300°/s, Yaw: 150°/s Max Tilt Angle: 35° Max Ascent Speed: 5 m/s Max Descent Speed: 4 m/s Max Speed: 22 m/s (ATTI mode, no wind) Max Flight Altitude: 4500 m Max Wind Speed Resistance: 10 m/s Max Flight Time: Approximately 18 min utes Motor Model: DJI 3510 Propeller Model: DJI 1345 Indoor Hovering: Enabled by default Operating Temperature Range:
- 10° to 40° C Diagonal Distance: 559 to 581 mm Dimensions: 438x451x301 mm
Gimbal Model: ZENMUSE X3 Output Power (With Camera): Static: 9 W In Motion: 11 W Operating Current: Station: 750 mA, Motion: 900 mA Angular Vibration Range: ±0.03° Mounting: Detachable Controllable Range: Pitch:
- 90° to +30°, Pan: ±320° Mechanical Range: Pitch:
- 125° to +45°, Pan: ±330° Max Controllable Speed: Pitch: 120°/s, Pan: 180°/s
Remote Controller Name: C1 Operating Frequency: 922.7~927.7 MHz (Japan Only), 5.725~5.825 GHz, 2.400~2.483 GHz Transmitting Distance (Outdoor And Unobstructed): 2 km EIRP: 10dBm@900m, 13dBm@5.8G, 20dBm@2.4G Power Supply: Built
- in battery Charging: DJI charger Dual User Capability: Host
- and
- Slave connection (Slave for Camera Control) Mobile Device Holder: Tablet or Phone Max Mobile Device Width: 170mm Output Power: 9 W Operating Temperature Range:
- 10° to 40° CStorage Temperature Range: Less than 3 months:
- 20° to 45° C, More than 3 months: 22° to 28° C Charging Temperature Range: 0
- 40° C Battery: 6000 mAh LiPo 2S Charger Model: A14
- 100P1A Voltage: 26.3 V Rated Power: 100 W Battery (Standard) Name: Intelligent Flight Battery Model: TB47 Capacity: 4500 mAh Voltage: 22.2 V Battery Type: LiPo 6S High voltage battery Energy: 99.9 W h Net Weight: 570 g Operating Temperature Range:
- 10° to 40° C Storage Temperature Range: Less than 3 months:
- 20° to 45° C ., More than 3 months: 22° C to 28° C Charging Temperature Range : 0° to 40° C Max Charging Power : 180 W Battery (Optional) Name : Intelligent Flight Battery Model : TB48 Capacity : 5700 mAh Voltage : 22.8 V Battery Type : LiPo 6S Energy : 129.96 W h Net Weight : 670 g Operating Temperature Range : - 10° to 40° C Storage Temperature Range : Less than 3 months:
- 20 to 45° C , More than 3 months: 22° to 28° C Charging Temperature Range : 0° to 40° C Max Charging Power : 180 W Vision Positioning Velocity Range : Below 8 m/s (2 m above ground) Altitude Range : 5
- 500 cm Operating Environment : Brightly lit (lux > 15) patterned surfaces Operating Range : 0
- 250 cm DJI Pilot App Mobile Device System Requirements : iOS 8.0 or later , Android 4.1.2 or later