1



### UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulator Docket No. ______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Smooth Shot, LLC FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS: 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b)

CONCERNING COMMERCIAL OPERATION OF UNMANNED AIRCRAFT

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZAION AND REFORM ACT OF 2012

(PUBLIC LAW 112

- 95)

Submitted on July 30 , 2015

Smooth Shot, LLC

9131 Blanco Dr Lantana, TX 76226

Tel: 469

- 236

- 20052



### TABLE OF CONTENTS

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

SUMMARY......................................................................................................................

......... . .....4

INTRO DUCTION AND INTEREST OF THE P ETITIONER..........................................

....... ......4

BACKGROUND...................................................................................................................

.. ........5

BASIS FOR PETITION

............................................................................................... ..... ....... . ......5

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

.................... .... .....22

APPENDIX A

......................................................................................................................... .......24

APPENDIX B

............................................................................................. ............................ ..... ..26

APPENDIX C

......................................................................................................................... ..... ..273



### GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

RPA Remotely Piloted Aircraft

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorologic al Conditions

VTOL Vertical Takeoff and Landing4



### SUMMARY

Smooth Shot, LLC 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 (UAS) pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA).

This exemption will permit Smooth Shot, LLC to operate a Remotely Piloted Aircraft (RPA) or UAS for the commercial purpose of conducting aerial video and photography of construction sites, real estate property, search and rescue, and natural landscapes in the United States.

INTRODUCTION AND INTER EST OF THE PETITIONER

Smooth Shot, LLC is owned and operated by Alex Boling and Jeremy Sweat located in Dallas, TX, and was founded in 2015 for the sole purpose of leveraging a UAS for capturing high quality aerial video, photographs, and raw data for comm ercial use, after successfully being exempt from the aforementioned requirements pursuant to Section 333 of the FAA FMRA.

The objective of Smooth S hot LLC is to provide quality imagery for a variety of commercial and public uses, specifically :

 Real Estate videography and photography

 Construction sites before and after

 Re search and Development

 Search and Rescue operations5



### BACKGROUND Unmanned Aircraft Systems: DJI Inspire 1

Smooth Shot, LLC seeks an exemption to operate DJI systems for compensation or hire within

the United States National Airspace System.

The DJI Inspire 1 is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) ut ilizing an electronic tablet and/or smart phone system. The Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of approximately 42 knots. The DJI Inspire 1 UA is also equipped with 4 main rotors; driven by Lithium Polymer battery powered

electric motors.

Two (2) DJI Inspire 1 s that will be operated by Smooth Shot, LLC will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R. Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking.

BASIS FOR PETITION

Petitioner, Smooth Shot, LLC , pursuant to the provisions of the Federal Aviation Regulations (14

C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereby petitions the Administrator to commercially operate the DJI Inspire 1 UAS in the 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, Smooth Shot, LLC ’s operation of DJI Inspire 1 UAS s meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Sub part H.

Accordingly, Smooth Shot, LLC requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate

.
Smooth Shot, LLC submits that the requested relief is proper, as an equivalent level of safety

will be ensured. Smooth Shot, LLC will ensure all safety and maintenance procedures outline by the UAS manufacture are complied with. Only authorized personne l or technicians will perform maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents provided by the UAS manufacture. All maintenance will be logged in the UAS maintenance record maintained by Smooth Shot , LLC

. Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges

and limitations : Pilot in command , is requested by Smooth Shot, LLC to the extent necessary to6



### allow a Pilot in Command (PIC) holding a private pilot o r 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 DJI Inspire 1 UAS in a manner consistent with this exempti on, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

Smooth Shot, LLC seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness

, because the DJI Inspire 1 UAS doe s not require an airworthiness certificate in accordance with

14 C.F.R . Part 21, Subpart H. As such, Smooth Shot, LLC submits that all maintenance and care

will be conducted to will ensure the DJI Inspire 1 UAS is in an airworthy condition, prior to

every flight, by determining that the UASs are in compliance with the operating documents provided by the UAS manufacture, and that the aircraft are in a condition for safe flight.

Smooth Shot, LLC also seeks an exemption from the requirements of Section 91.121 , entitled Altimeter Settings, as the DJI Inspire 1 UA will not have a typical aircraft barometric altimeter

onboard. However, a ltitude information of the DJI Inspire 1 UA will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path

. This altitude information, combined with Smooth Shot, LLC’s operation of the DJI Inspire 1 UAS within

Vis ual Line of Sight, at or below 2 00 feet AGL, with the m ajority of flights at or below 1 00 feet AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, Smooth Shot, LLC seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for fligh t in VFR conditions

. Smooth Shot, LLC submits that granting an exemption will reduce current risk levels, as there is reliance on combustible fuel for the operation of the DJI Inspire 1 UA during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR) will ensure the UA is operated in a safe manner compliant with applicable regulations.

In accordance with 14 C.F.R. § 11.81, Smooth Shot, LLC 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:

Smooth Shot, LLC

9131 Blanco Dr Lantana, TX 76226

Tel: 469

- 236

- 2005

Email: SmoothShotL LC@gmail.com7



### B. The Specific Sections Of 14 C.F.R. From Which Smooth Shot, LLC Seeks Exemption.

1) Smooth Shot, LLC 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 only incidental to that business or employment; and

2. The aircraft does not carry passengers or prop erty for compensation or

hire.

2) Smooth Shot, LLC Seeks Exemption From The Requirements Of Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness , subsection (a), states the following:

a. No person may operate a civil aircraft unless it is in an airworthy condition.

3) Smooth Shot, LLC 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, by reference to an altimeter that is set, when operating

— 1. Below 18,000 feet MSL, to

— i. The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft;

ii. If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, t he 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) Smooth Shot, LLC Seeks Exemption From The Requirements Of Section 91.151(b).8



### Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection

b. States the following 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) Smooth Shot, LLC Seeks Exemption From The Requirement of Section 91.405(a)

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

— (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall

bet ween required inspections, except as provided in paragraph 10 of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.]

6) Seeks Exemption From The Requirements Of Section 91.407(a)(1)

Section 91.407, entitled Operation a fter 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 by a person authorized under § 43.7 of this chapter[.]

7 ) Smooth Shot, LLC Seeks Exemption From The Requirements Of Section s 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 servic e by a person authorized by § 43.7 of this ch apter;

or 2. An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.

8) Smooth Shot, LLC Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b).

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

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator sh all keep the following records for the periods specified in paragraph (b) of this

section:9

(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. 9

ii The current status of life

- limited parts of each airframe, engine, pr opeller, rotor, and appliance.

iii The time since last overhaul of all items installed on the aircraft which are required to be overha uled 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 applicab le 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 whe n the next action is re quired.

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 recor ds for the peri ods prescribed:

1

. The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed.

2. The rec ords 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 Smooth Shot, LLC Seeks And The Reason Smooth Shot, LLC Seeks The

Relief.10

1. Extent Of Relief Smooth Shot, LLC Seeks And The Reason Smooth Shot, LLC Seeks Relief From Section 61.113(a) And (b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in

command , is requested to the extent necessary to allow a PIC holding a private pilot or higher level certificate, as well as a curr ent and valid airman medical certificate, and who has met certain flight

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

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

As set forth more fully below, Smooth Shot, LLC submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the DJI Inspire 1 UA unless that PIC has met certain flight

- hour a nd currency requirements, demonstrating that the PIC is able to safely
operate the DJI Inspire 1 UA 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, Smooth Shot, LLC submits that all flights of the DJI Inspire 1 UAS s , conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to Smooth Shot, LLC busi ness; and (2) will not carry passengers or property for compensation or hire.

2. Extent Of Relief Smooth Shot, LLC Seeks And The Reason Smooth Shot, LLC Seeks Relief From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness

, is requested to the extent required to allow Smooth Shot, LLC to determine that the DJI Inspire 1 UAS are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., the Smooth Shot, LLC Aeria l Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual).

Smooth Shot, LLC seeks the requested relief because the DJI Inspire 1 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. The refore, Smooth Shot, LLC will ensure that the DJI Inspire 1 UAS are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual) prior to every flight, and further, dete rmine that the aircraft are in condition for safe flight, as stated in the conditions and limitations below.

3. Extent Of Relief Smooth Shot, LLC Seeks And The Reason Smooth Shot, LLC Seeks

Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the DJI Inspire 1 UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PIC at

t he ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above gr ound level (AGL), Smooth Shot, LLC seeks the requested relief because the DJI Inspire 1 UA’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight.11

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought

to the extent nece ssary 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 DJI Inspire 1 UA are equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provides

the PIC with altitude information of the UA on the heads

- up display of the GCS.

4. Extent Of Relief Smooth Shot, LLC Seeks And The Reason Sm ooth Shot, LLC Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to allow flights of the battery powered DJI Inspire 1 UA during daylight hours i n 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. Smooth Shot, LLC seeks t he requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery DJI Inspire 1 UA will severely constrain the practicality of any aerial video or still photo flight operations that Smooth Shot, LLC proposes t o conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the JI Inspire 1 UAS, the DJI DJI Inspire 1 operating documents, and Smooth Shot, LLC proposed operating limitations, ensure that Smooth Shot, LLC will safely operate the battery powered DJI Inspire 1 UA during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

5. Extent Of Relief Smooth Shot, LLC Seeks And The Reason Smooth Shot, LLC Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, Smooth Shot, LLC requests relief from these Sections because the DJI Inspire 1 UAS do not require airworthin ess certificates. As set forth more fully below, DJI Inspire 1 UAS meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, Smooth Shot, LLC will use trained technicians to perform maintenance, alterations, o r preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the UAS operating documents 12 (i.e., the Smooth Shot, LLC Aerial Operations Manual, Monthly Maintenance Log, DJI Inspire 1 Instruction Manual). Furthermore,

Sm ooth Shot, LLC will document and maintain all maintenance records for DJI Inspire 1 UAS.

D. The Reasons Why Granting Smooth Shot, LLC Request Would Be In The Public Interest; That Is, How It Would Benefit The Public As A Whole

. Granting the present Petit ion will further the public interest by allowing Smooth Shot, LLC to safely, efficiently, and economically perform aerial video and photography for wedding films, real estate, special events, film sets, and landscape over certain areas of the United States

. Additionally, use of the DJI Inspire 1 UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of Smooth Shot, LLC proposed operation of DJI Inspire 1 UAS will be realized without implicating any privacy issues.

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

The DJI Inspire 1 UA are battery powered and serve as a safe, efficient, and economical

alternative to the manned aircraft traditio nally utilized to obtain aerial imagery. By reducing the12

amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJI Inspire 1 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollu tion, as well as increase the safety of life and property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by 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 UAS

.
Conducting aerial acquisitions with DJI Inspire 1 UAS , instead of manned aircraft, will greatly

benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, the DJ I Inspire 1 UAS produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically utilized for aerial video and photography, while burning approximately

20

- 30 gallons per hour of leaded aviation fuel. The DJI Inspire 1 UA, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAs are propelled by battery powered electric motors, rather than an internal combustion engine.

By using the D JI Inspire 1 UAS to p erform aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI Inspire 1 UA (weighing approximately 6 pounds 7.5 ounces, at it’s maximum gross weight with a length of 17.3 inches, width of 17.7 inches, and with no fuel on board), has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fu el capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations With The DJI Inspire 1 UAS Will Benefit The Economy.

In addition to being safe and efficient, the DJI Inspire 1 UAS is also an economical alternative to using manned aircr aft to conduct similar aerial operations. As such, operation of the DJI Inspire 1

UAS will allow United States based companies, like Smooth Shot, LLC , to remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companie s must adopt new and alternative technology in order to remain competitive. Operating the battery powered DJI Inspire 1 UAS is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft.

By operating the DJI Inspire 1 UAS, companies such as Smooth Shot, LLC , can remain competitive and profitable, and therefore, provide greater job stability to employees and

c ontractors, which will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through commercial use of the DJI Inspire 1 UAS, provides a stable workforce that increases consumer spending; improves local, sta te, and federal tax revenues; and allows companies to invest in re search and development in order to remain competitive both in the United States and abroad.13

4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for decades, Smooth Shot, LLC , LLC proposed operation of the DJI Inspire 1 UAS will not implicate any privacy issues. Specifically, the DJI Inspire 1 UAS will be operated only in compliance with operating documents (i.e., the Smooth Sho t, LLC , LLC Aerial Operations Manual, Monthly Maintenance Log, 14 and DJI Inspire 1 Instruction Manual) which requires property owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, includ ing 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 Smooth Sh ot, LLC Seeks Exemption.

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

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

unmanned airc raft and its operation, Smooth Shot, LLC operation of the DJI Inspire 1 UAS meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Section 333 provides authority for a UA S 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

fo llowing, 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 operat e 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 air space 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 Saf

e 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 nation al airspace

system.

In seeking this exemption, Smooth Shot, LLC submits that the DJI Inspire 1 UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI Inspire 1 UAS ; (b) the pilot certificatio n requirement; and (c) the specific operating

limitations.14

a. The Specifications Of The DJI Inspire 1 UAS Demonstrate Its Safe

Characteristics.

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

i. Technical Specifications Of The DJI Inspire 1 UAS

.

The technical specifications of the DJI Inspire 1 UAS are set forth by the DJI Inspire 1 Specifications and Data Shee t, attached hereto as Appendix A

.
ii. The Inspire 1 UAS Autonomous Flight And Navigation Modes Enable

The UAS To Remain Within A Defined Operational Area.

The DJI Inspire 1 UAS may be operated in both manual and fully autonomous flight modes. A complete description of the flight and navigational modes of the Inspire 1 UAS is provided at pages 45

- 50 o f the DJI Inspire 1 User Manual

, attached hereto as Appendix B

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

When the Control Link is lost, the DJI Inspire 1 UA will remain stationary, in flight, for 3 seconds or more. If, a fter 3 seconds, the DJI Inspire 1 UA do not reacquire control link data from the GCS, the UA will assume that the Control Link is lost and the UAs 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 DJI Inspire 1 is set forth

at pages 13 through 15 of the DJI Inspire 1 User Manual , at tached hereto as Appendix B

.

iv. The DJI Inspire 1 GCS And Its Operation.

A complete description of t he operation and specifications of the DJI Inspire 1 GCS and flight control software is provided at pages 40 through 47 of the DJI Inspire 1 User Manual. The DJI Inspire 1 User Manual is attached hereto as Appendix B

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

.
Smooth Shot, LLC will only utilize certificated pilots who possess a current and valid airman medical certificate to act as a pilot in command (PIC) of the DJI Inspire 1 UAS

. Additionally, a safety observer will assist all pilots during flight time.

c. Flights Of DJI Inspire 1 UAS Will Be Conducted Pursuant To Specific Operating

Limitations

. In seeking this exemption, Smooth Shot, LLC proposes to commercially operate DJI Inspire 1 UAS for the special purpose of conducting aerial video and photography over certain areas of United States, pursuant to the following specific operating limitations:

1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UASs weighing less than 5515

pounds maximum gross weight: DJI Inspire 1 Unmanned Aircraft Systems. Proposed operations of any other aircraft will require a new petition or a petition to amend this
grant.

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

3. The UAs may not be flown at an indicated airspeed exceeding 20 knots.

4. The UA must be operated at an altitude of no more than 500 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved by ATC. All altitudes reported to ATC must be in

fee t 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 cert ificate.

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 capabil ity. The SO and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flig ht operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of th e 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/obs tructions and is not permitted to operate the camera or other instruments.

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

between the conditions and limitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, the operator

mus t 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 upon reque st. 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,

t hen the operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records.16

11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional 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 UAS manufacturer’s aircraft/component, mai ntenance, 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 UAS to service.

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

Bulletins.

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

17. The PIC must possess at least a private pilot certificate and at least a current third

class medical certificate.

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a mann er consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator’s PICs are permitted under the terms of the exemption. However, training operations may only be conducted during dedicated training sessions. During training, profic iency, 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

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

area of o perations. Flights under special visual flight rules (SVFR) are not authorized.

20. The UA may not operate within 5 nautical miles of an airport reference point as

denoted on a current FAA

- published aeronautical chart unless a letter of agreement with

tha t 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.

21. The UA may n ot 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.17

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

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

24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 25% battery power remaining.

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM ) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder

r equirements.

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

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

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

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made available to the Administrator or any law enforce ment official
upon request.

29. The UA must remain clear and yield the right of way to all manned aviation operations and activities at all times.

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

31. Flight operations must b e conducted at least 500 feet from all nonparticipating persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticip ating 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 500

feet of the UA, flight operations must cease immediately and/or; 20

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).18

3 2. 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.

33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the

NTSB Web site: www.ntsb.gov

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

Smooth Shot, LLC submits that the equivalent level of safety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI Inspire 1 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, v essels, vehicles and structures.

Considering Smooth Shot, LLC 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 (S ee Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI Inspire 1 UAS, Smooth Shot,

LLC , LLC submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for Smooth Shot,

LLC , LLC specific proposed flight operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemp tion Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

Smooth Shot, LLC will not allow any PIC to operate the DJI Inspire 1 UAS unless that PIC has demonstrated, by m eeting minimum flight

- hour requirements or the DJI Inspire 1 UAS training and currency requirements, that the PIC is able to safely operate the DJI Inspire 1 UAS in a manner consistent with this exemption, including 21 evasive and emergency maneuvers and m aintaining appropriate distances from people, vessels,

vehicles and structures.

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency

purpo ses).

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 Smooth Shot, LLC proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows:19

In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25

hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi

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

- rotor time and t he 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight

- ho ur requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the petitioner’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in complia nce with applicable regulations would satisfy this requirement. Training, proficiency, and experience

building flights can also be conducted under the grant of exemption to accomplish the required flight time. During training, proficiency, and experience

b uilding flights the PIC is required to operate the UA with appropriate distances

in accordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15. Accordingly, Smooth Shot, LLC will ensure safe operations by not allowing any PIC to operate the DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI nspire 1 UAS in a manner consis tent 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 by Section 91.7(a) will be maintained because prior to every flight, Smooth Shot, LLC will ensure that the DJI Inspire 1 UAS is in an airworthy condition based upon the UAS’s compliance with its operating docu ments and

as stated in the conditions and limitations 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 herein (e.g. Exemption Nos. 1106 2, 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 equivale nt level of safety established by Section 91.121 will be maintained because

the altitude information of the DJI Inspire 1 UA will be provided to the PIC via GPS equipment and a radio communications telemetry data link, which downlinks from the

UA to the GC S for active monitoring of the flight path and altitude. This altitude information, combined with Smooth Shot, LLC operation of the Inspire 1 UA within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to2 0

Section 91.1 21. 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 UASs at ground level. The FAA has previously granted relief from

Sect ion 91.121 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, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160,

111 61).

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 techni cal specifications of the DJI Inspire 1 UAS; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, Smooth Shot, LLC will ensure that it will safely operate the battery powered DJI Inspir e 1 UA during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5

minutes. Here, as in Exemp tion No. 11109, the technical specifications of the DJI Inspire 1 UAS; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Fur thermore, safety will be ensured as DJI Inspire 1 UAS provide audible and visual warnings to the PIC at the GCS when the UAs experiences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and again at approximate ly 10% remaining battery power. At the critically low battery level, the DJI Inspire 1 UASs will descend and land automatically

. Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover , the FAA has previously granted 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, 1110 9, 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 see king this exemption, Smooth Shot, LLC submits that the equivalent level of safety with regard to the regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met

because Smooth Shot, LLC will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., the Smooth Shot, LLC Aerial Operation s Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, Smooth Shot, LLC will document and maintain all maintenance records for the DJI Inspire 1 UAS.21

Since the DJI Inspire 1 UAS will be inspected as prescribed by the operating documents, Smooth Shot, LLC 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 DJI Inspire 1 User Manual is

attached hereto as Appe ndix B ; a copy of the DJI Inspire 1 UAS Maintenance LOG is attached hereto as Appendix C

. Likewise, the exemption sought will not adversely affect safety because Smooth Shot,

LLC will use trained technicians to perform maintenance, alterations or preventi ve maintenance on the UAS using the methods, techniques, and practices prescribed by the operating documents. Furthermore, the exemption sought would maintain an equivalent level of safety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI Inspire 1 UAS will be performed by trained technicians. Maintenance will be

documente d and maintained utilizing the monthly maintenance log. Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the technical characteristics and operating limitations of the

UAS are considered.

In consideration of Smooth Shot, LLC proposed operating limitations, the operating documents, and the technical aspects of the DJI Inspire 1 UAS

, Smooth Shot, LLC

submits that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted relief specific to UAS in circumstances similar, in all

material res pects, 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 Oper ation.

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, Smooth Shot, LLC requests that the FAA prescribe special conditions for the intended operation of DJI Inspire 1

UAS , which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407 (a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAs for the limited purpose of conducting aerial video and photography over certain areas of the United States for compensation or hire. FMRA Sect ion 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness cer tification in accordance with any requirements that must be established for the safe operation of the UAS in the

NAS. Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of the DJI Inspire 1 UAS , since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special Conditions, states the following:

If the FAA finds th at 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 prescr ibes special conditions and amendments thereto for22

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 esta blish a level of safety equivalent to that established in the regulations.

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for Smooth Shot LLC’s intended operation of the DJI Inspire 1 UAS, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 9 1.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

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

From Which Smooth Shot, LLC Seeks Exemption: Smooth Shot, LLC 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 Smooth Shot, LLC

Seeks:

This exemption will pe rmit Smooth Shot, LLC to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States.

G. Any Additional Information, Views, Or Arguments Available To Support Smooth Shot, LLC Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. As such, Smooth Shot, LL C ’s request for exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above.

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the p ublic, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification.

As discussed in detail above, Smooth Shot, LLC will operate the DJI Inspire 1 UAS safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.

CONCLUSION

As set forth herein, Smooth Shot, LLC seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of DJI Inspire 1 UAS commercially, without an airworthiness certificate, for the limited purpose of c onducting 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 of23

2012, while also advancing the interest s of the public, by allowing Smooth Shot, LLC to safely, efficiently, and economically operate the DJI Ins pire 1 UAS commercially within the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and

Reform Act of 2 012, Section 333, Smooth Shot, LLC respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Smooth Shot, LLC to operate the DJI Inspire 1 UAS commercially for the purpose of conducting aerial video and photography over certain areas of the United States.

Dated: July 27, 2015.

Submitted by,

Smooth Shot, LLC

____________________________________ Alex Boling , Co

- Founder Smooth Shot, LLC

9131 Blanco Dr Lantana, TX 76226

Tel: 469

- 236

- 2005

Appendices:

A

— DJI Inspire 1 Specifications Data Sheet

B

— DJI Inspire 1 Manufacturer’s User Manual

C

— Monthly Maintenance Log24

APPENDIX

— A

Smooth Shot, LLC’s only utilizes safe and reliable UASs. DJI is an industry leader in small UAS production. DJI UASs are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJI software provides real

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

.

3.2 DJI Inspire 1

3.2.1 Aircraft

3.2.1.1 Model

– T600 3.2.1.2 Weight (Battery Included)

– 6lbs 7.5291oz (2935g) 3.2.1.3 Hovering Accuracy (GPS Mode)

– Vertical: 0.5m; Horizontal: 2.5m 3.2.1.4 Max Angular Velocity

– Pitch: 300 0 /s; Yaw: 150 0 /s 3.2.1.5 Max Tilt Angle

- 35 0 3.2.1.6 Max Ascent Speed

– 5m/s 3.2.1.7 Max Descent Speed

– 4m/s 3.2.1.8 Max Speed

– 22m/s (ATTI mode, no wind

– NOT RECOMMENDED) 3.2.1.9 Max Flight Altitude

– 4500m 3.2.1.10 Max Wind Resistance

– 10m/s 3.2.1.11 Max Flight Time

– Approximately 18 minutes

3.2.1.12 Motor Model

– DJI 3510 3.2.1.13 Propeller Model

– DJI 1345 3.2.1.14 Operating Temperature Range

– 14 0 F to 104 0 F (

- 10 0 C to 40 0 C)

3.2.1.15 Dimensions

– 17 1⁄4” x 17 3⁄4” x 12”

3.2.2 Gimbal

3.2.2.1 Model

– ZENMUSE X3 3.2.2.2 Output Power (with camera)

– Static: 9W; In Motion: 11W 3.2.2.3 Operating Current

– Static: 750mA; In Motion: 900mA 3.2.2.4 Angular Vibration Range

- ±0.03 0
3.2.2.5 Mounting

– Detachable 3.2.2.6 Controllable Range

– Pitch:

- 90 0 to +30 0 ; Pan: ±320 0
3.2.2.7 Mechanical Range

– Pitch:

- 125 0 to 45 0 ; Pan: ±330 0
3.2.2.8 Max Controllable Speed

– Pitch: 120 0 /s; Pan: 180 0 /s

3.2.3 Camera

3.2.3.1 Name

– X3

3.2.3.2 Model

– FC350

3.2.3.3 Total Pixels

– 12.76M

3.2.3.4 Effective Pixels

– 12.4M 31 3.2.3.5 Image Max Size

– 4000x3000 3.2.3.6 ISO Range

– 100

- 3200

3.2.3.7 Field of View

- 94 0

3.2.3.8 CMOS

– Sony EXMOR 1/2.3” 3.2.3.9 HD Video Recording

– UHD( 4K): 4096x2160p24/25, 3840x2160p24/25/30; FHD: 1920x1080p24/25/30/48/50/60; HD: 1280x720p24/25/30/48/50/60 3.2.3.10 Operating Temperature Range

- 32 0 F

- 104 0 F (0 0 C

- 40 0 C)25

3.2.4 Transmitter

3.2.4.1 Name

– C1 3.2.4.2 Operating Frequency

– 5.728

- 5.850GH z; 2.400

- 2.483GHz 3.2.4.3 Communicating Distance (unobstructed)

– 2000m 3.2.4.4 Output Power

– 9W 3.2.4.5 Operating Temperature Range

- 14 0 F to 104 0 F (

- 10 0 C to 40 0 C) 3.2.4.6 Battery

– 600mAh LiPo 2S26

APPENDIX

— B

DJI Inspire 1 Manufacturer’s User Manual

User manual can be found at:

http://download.dji

- innovations.com/downloads/inspire_1/en/Insp ire_1_User_Manual_v1.2_en.pdf27



### APPENDIX

-- C