1 LEE M. WOODWOTH

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### Exemption Request

Regulatory Docket Number: TBD

The following petition is submitted by Lee M. Woodworth and made to

UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTATION WASHINGTON, DC 20591

for an exemption from Title 14, Code of Federal Regulations (14 CFR) part 21, subpart H; and 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 DJI Phantom 2 Vision +, DJI Phantom 3, and DJI Inspire 1 unmanned aircraft systems

.

Submitted on June 4, 2015

Lee M Woodworth

26 Union Street Plymouth, MA 02362 Tel: (781) 864

- 31512 LEE M. WOODWOTH

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### TABLE OF CONTENTS

SUMMARY...................................................................................................................................................3

INTRODUCTION......................................................

................................................................................... .3

BASIS FOR PETITION........................................................................................................................... ........3

NAME AND MAILING ADDRESS OF PETITIONER..................................................................... ..4

SPECIFIC SECTION s OF 14 C.F.R. FROM WHICH LEE M. WOODWORTH SEEKS
EXEMPTION .............................................................................................................................. 4

EXTENT OF RELIEF LEE M. WOODWORTH SEEKS AND THE REASON LEE M. WOODWORTH

SEEKS THE RELIEF

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

HOW THIS REQUEST WOULD BENEFIT THE PUBLIC AS A WHOLE...

....................................... 9

REASONS WHY THIS EXEMPTION WOULD NOT ADVERSLY AFFECT SAFTEY ................ ....11

A SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER...

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

ANY ADDITIONAL INFORMATION, VIEWS, ARGUMENTS AVAILABLE TO SUPPORT LEE M.
WOODWORTHS REQUEST.......

...... . .......................................................................................... .23

CONCLUSION.....

...................................................................................................................................................... .23

APPENDICES..

..................................................................... ....................................................................................... 243 LEE M. WOODWOTH

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### SUMMARY

Lee M. Woodworth seeks exemption from the requirements of 14 C.F.R. part 21, subpart H ; and

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) , 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 Lee

M. Woodworth to operate an UAS for the commercial purpose of conduction aerial vide o and photography for construction sites, real estate, surveying, and landscape over certain areas of

the United States.



### INTRODUCTION

Lee M. Woodworth has over 30 years of experience flying fixed wing, helicopter, and multi rotor air craft as a hobbyist. Woodworth has been a member of the Academy of Model Aeronautics (AMA) since 1985 (member #209920) and is an AMA certified instructor as well as a certified safety officer . Woodworth has been active in the Civil Air Patrol for the past 20 years and taught secondary technology education for 35 years . Woodworth also has experience designing and engineering all types of model aircraft.

The objective of Lee M. Woodworth’s aerial video and photography operation is to provide high quality imagery for a variety of commercial, public, and residential uses including:

 Aerial i nspections of public and private structures

 Aerial video and images for private and public property owners

 Aerial video and images for environmental consulting

 Increase public knowledge of UAS and promote safe UAS operations

In order to conduct such opera tions, Lee M. Woodworth seeks an exemption to operate DJI

systems , specifically the DJI Phantom 2 Vision+ and DJI Inspire 1, for compensation or hire within the National Airspace System (NAS). The DJI Phantom 2 Vision+ and DJI Inspire 1 are vertical takeof f and landing (VTOL) unmanned aircraft (UA) with a ground control station (GCS). All UAs will be operated by an individual with a pilot certification, current FAA airman medical certificate or a valid U.S. drivers’ license, and meet the flight review requi rements specified in

14 C.F.R. § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. All UAs 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 , a nd marked in accordance with 14 C.F.R. Part 45, Identification and Registration Markings.



### BASIS FOR PETITION

Petitioner, Lee M. Woodworth , pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Moder nization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereby petitions the Administrator to4 LEE M. WOODWOTH

– PETITION FOR EXEMPTI ON

commercially ope rate the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R part 21, subpart H; and

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).

Name And Address Of The Petitioner:

Lee M. Woodworth

26 Union Street Plymouth, MA 02632 Tel: (781)864

- 3151
Email: LeeMWoodworth@gmail.com

Specific Sections Of 14 C.F.R. From Which Lee M. Woodworth Seeks Exemption :

1. Lee M. Woodworth 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 airc raft 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 property for compensation or hire.

2. Lee M. Woodworth Seeks Exemption From The Requ irements 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. Lee M. Woodworth Seeks Exemption From The Requireme nts 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

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(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 pr escribed 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. Lee M. Woodworth 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

minutes.

5. Lee M. Woodwort h 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 t hi s 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. Lee M. Woodworth 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 by a person authorized under §43.7 of this chapter[.]

7. Lee M. Woodworth Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2).

Section 91.409, entitled Inspectio ns , 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

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(1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by § 43.7 of this chapter;

or

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

8. Lee M. Woodworth 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 shal l 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) Th e 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 airfram e, each en gine, 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 air craft, including the time since
the last inspection required by the inspection program under which the aircraft and its appliances are maintained.

(v) The current status of applicable ai r worthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required

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(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

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

(2) The records specified in paragraph (a)(2) of this section shal l 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.

Extent Of Relief Lee M. Woodworth Seeks And The Reason Lee M. Woodworth Seeks The
Relief:

1. Extent Of Relief Lee M. Woodworth Seeks And The Reason Lee M. Woodworth 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 medica l 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 or property for compensation or hire.

As set forth more fully below, Lee M. Woodworth submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the DJI Phantom 2 Vision+ UAS or DJI Inspire 1 UAS unless that PIC has met certain flight

- hour and currency requirements, demonstrating that the PIC is able to safely operate either the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency

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

Further, Lee M. Woodworth submits that all flights of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs, conducted by the PIC pursuant to the grant of thi s Petition: (1) will be
incidental to Lee M. Woodworth’s business; and (2) will not carry passengers or property for compensation or hire.8 LEE M. WOODWOTH

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2. Extent Of Relief Lee M. Woodworth Seeks And The Reason Lee M. Woodworth 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 Lee M. Woodworth to determine that the DJI Phantom 2
Vision+ and DJI Inspire 1 UASs are in airworthy condition prior to every flight by ensuring
that t he UAS is in compliance with the operating documents (i.e. Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1 Instruction Manual).

Lee M. Woodworth seeks the requested relief because the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Lee M. Woodworth will ensure that the DJI
Phantom 2 Vision+ and DJI Inspire 1 UASs are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI
Phantom 2 Vision+ 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 Lee M. Woodworth Seeks And The Reason Lee M. Woodworth
Seeks Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the DJI Phantom 2 Vision+ and DJI Inspire 1 U ASs, 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 UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), Lee
M. Woodworth seeks the requested relief because the DJI Phantom 2 Vision+ and 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.

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 limitatio ns stated below. As more fully set forth herein, an equivalent level of safety will be maintained since the DJI Phantom 2 Vision+ and DJI Inspire 1 UAs are equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a

gro und 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 Lee M. Woodworth Seeks And The Reason Lee M. Woodworth
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 Phantom 2 Vision+ and DJI Inspire 1 UAs during daylight hours in visua l 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 at9 LEE M. WOODWOTH

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least 4.5 minutes. Lee M. Woodworth seeks the requ ested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered DJI Phantom 2 Vision+ and DJI Inspire 1 UAs will severely constrain the practicality of any aerial video or still photo flight operations that Lee M. Woodworth proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs, the DJI Phantom 2 Vision+ and DJI Inspire 1 operating documents, and Lee M . Woodworth’s proposed operating limitations, ensure that Lee
M. Woodworth will safely operate the battery powered DJI Phantom 2 Vision+ and DJI Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total duration of 13.5
minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes

.

5. Extent Of Relief Lee M. Woodworth Seeks And The Reason Lee M. Woodworth 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, Lee M. Woodworth requests relief
from these Sections because the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs do not require airworthiness certificates. As set forth more fully below, the DJI Phantom 2
Vision+ and DJI Inspire 1 UASs meet the conditions of FMRA Se ction 333 for operation
without an airworthiness certificate. Accordingly, Lee M. Woodworth will use trained
technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in t he UAS op erating documents (i.e. Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1 Instruction Manual). Furthermore, Lee M. Woodworth will document and maintain all
maintenance records for the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs

. How This Request Would Benefit The Public As A Whole :

Granting the present Petition will further the public interest by allowing Lee M.
Woodworth to safely, efficiently, and economically perform aerial video and photography for construction sites, real e state, surveying, and landscape over cer tain
areas of the United States

. Additionally, use of the DJI Phantom 2 Vision+ and DJI Inspire
1 UASs will decrease congestion of the NAS, reduce pollution, and provide significant
benefits to the economy. Notably, the benefits of Lee M. Woodworth’s proposed operation of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs will be realized without implicating any privacy issues.

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

The DJI Phantom 2 Vision+ an d DJI Inspire 1 UAs are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform10 LEE M. WOODWOTH

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aerial acquisitions, an exemption allowing the use of a DJI Phantom 2 Vision+ or DJI Inspire 1 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced.
The DJI Phantom 2 Vision+ and DJI Inspire 1 UAs do not require an airport to takeoff or
land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would result in fewer 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 Phantom 2 Vision+ and DJI Inspire 1 UASs.

Conducting aerial acquisitions with the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs, instead of manned aircraft, will greatly benefit the public by drastical ly reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs 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 aviatio n fuel. The DJI Phantom 2 Vision+ and DJI Inspire 1 UAs, 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.

B y using the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs 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 substan tially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI Phantom 2 Vision+ and DJI Inspire 1 UAs (weighing approximately 2 pounds 11 ounces and 6 pounds 7.5 ounces respectively, at their

maxi mum gross weights with lengths of 16 inches and 17.3 inches respectively, widths
of 16 inches and 17.7 inches respectively, and with no fuel on board), has less physical potential for collateral damage to life and property on the ground, and in the air,

co mpared 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 fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations With The DJI Phantom 2 Vision+ and DJI Inspire 1 UASs Will Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs are also an economical alternative to using ma nned aircraft to conduct simi lar aerial operations. As such, operation of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs will11 LEE M. WOODWOTH

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allow United States based companies, like Lee M. Woodworth , 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 companies must adopt new
and alternative technology in order to remain competitive. Operating the battery

p owered DJI Phantom 2 Vision+ and DJI Inspire 1 UASs 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

a ircraft. By operating the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs, companies such

as Lee M. Woodworth , can remain competitive and profitable, and therefore, provide
greater job stability to employees and contractors, which will ultimately contribute t o growth of the U.S. economy. Improved financial performance of U.S. companies, through commercial use of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs, 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 f or decades, Lee M. Woodworth’s proposed operation of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs will not implicate any privacy issues. Specifically, the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs will be operated only in compliance with operating
d ocuments (i.e. Monthly Maintenance Log, and DJI Phantom 2 Vision+ 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

Reasons Why This Exemption Would Not Adversely Affect Safety :

1. Reasons Why The DJI Phantom 2 Vision+ and DJI Inspire 1 UAs 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 aircraft and its operation, Lee M. Woodworth’s operation of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs meet the conditions of FMR A Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

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

(a) In General.

-- Notwithstanding any other requirement of this subtitle, and not
lat er than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate12 LEE M. WOODWOTH

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safely in the national airspace system before completion of the plan and rulemaking required by secti on 332 of this Act or the guidance required by section 334 of this Act.

(b) Assessment of Unmanned Aircraft System s.

-- 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 un der 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

opera tion of such aircraft systems in the national airspace system.

In seeking this exemption, Lee M. Woodworth submits that the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs; (b) the pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The DJI Phantom 2 Vision+ and DJI Inspire 1 UASs
Demonstrate Its Safe Characteristics.

The DJI Phantom 2 Vision+ and DJI Inspire 1 UASs 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 Specif ications Of The DJI Phantom 2 Vision+ and DJI Inspire

1 UASs.

The technical specifications of the DJI Phan tom 2 Vision+ and DJI Inspire 1

UASs are set forth by the DJI Phantom 2 Vision+ and DJI Inspire 1 User
Manuals , attached hereto as Exhibit A and B.

ii. The DJI Phantom 2 Vision+ and DJI Inspire 1 UASs Autonomous Flight And Navigation Modes Enable The UASs To Remain Within A Defined Operational Area.

The DJI Phantom 2 Vision+ and DJI Inspire 1 UASs may be operated in
both manual and fully autonomous fl ight modes. A complete description of the flight and navigational modes of the DJI Phantom 2 Vision+ and DJI13 LEE M. WOODWOTH

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Inspire 1 UASs is provided at pages 25

- 35 of the DJI Phantom 2 Vision+ and pages 12

- 16 and 45

- 50 of the DJI Inspire 1 User Manuals, attached.

iii. The DJI Phantom 2 Vision+ and DJI Inspire 1 UASs 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 Phantom 2 Vision+ and DJI Inspire 1

UAs will remain sta tionary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 2 Vision+ and DJI Inspire 1 UAs do not reacquire control link data from the GCS, the UAs 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 Phantom 2

Vision+ UAS are set forth at pages 27 through 29 and for the DJI Inspire 1 at pages 13 through 15 of the DJI Phantom 2 Vision+ and DJI Inspire 1

User Manuals, attached

. iv. The DJI Phantom 2 Vision+ and DJI Inspire 1 GCS And Its Operation.

A complete description of the operation and specifications of the DJI
Phantom 2 Vision+ and DJI Inspire 1 GCS and fl ight control software is provided at pages 32 through 43 of the DJI Phantom 2 Vision+ User Manual and pages 40 through 47 of the DJI Inspire 1 User Manual. DJI Phantom 2 Vision+ and DJI Inspire 1 User Manuals are attached

. b. Flight Operations Of DJI Phantom 2 Vision+ and DJI Inspire 1 UASs Are Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety
Observer.

Lee M. Woodworth 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
Phantom 2 Vision+ and DJI Inspire 1 UASs. Additionally, a safety observer will assist all pilots during flight time.

c. Flights Of DJI Phantom 2 Vision+ and DJI Inspire 1 UASs Will Be Conducted Pursuant To Specific Oper ating Limitations.

In seeking this exemption, Lee M. Woodworth proposes to commercially operate

DJI Phantom 2 Vision+ and DJI Inspire 1 UASs 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 e xemption will be limited to the following aircraft described in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: DJI Phanto m 2 Vision+ and14 LEE M. WOODWOTH

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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 purpos e 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 operati ng documents unless a special request is made and approved by ATC. All altitudes reported to ATC must be in feet AGL.

5. The UAs must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human visi on 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 obser ver (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be able to communicate verbally at all times.
Electronic messaging or texting is not permitted during flight operations. T he 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 dut ie s beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is not permitted to operate the camera or other

instruments.

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

a discrepancy exists between the conditions and limitations contained in the
grant of exemption and the procedures outlined in the operating documents, the
conditions and limita tions 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 respo nsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. If the operato r 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 of15 LEE M. WOODWOTH

– PETITION FOR EXEMPTI ON

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 air craft 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 b e properly
documented in the aircraft records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PI C 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, maintenance, overhaul, replacement, inspection, and life limit requirements.

14. The operator must carry out its maint enance, 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 accomplis hed, 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

correct ive 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 manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator’s PICs are permitted under the terms of the exemption. Howeve r, training operations may only be conducted during dedicated training sessions. During training, proficiency, and16 LEE M. WOODWOTH

– PETITION FOR EXEMPTI ON

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 fli ght at night is required, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized.

20. The UA may not operate within 5 nautical mile s of an airport referen ce 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.

21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the

PIC.

22 . If the UA loses 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 intend ed 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 incl uding class of airspace, altitude level and potential transponder requirements.

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

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

27. Before conducting operations, the ra dio frequency spectrum used for operation and control of the UA must comply with the Federal Communications1 7 LEE M. WOODWOTH

– PETITION FOR EXEMPTI ON

Com mission (FCC) or other appropriate government oversight agency requirements.

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

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

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

31. Flight operations must be condu cted 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 pr esent 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 nonparticipati ng persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has gra nted 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).

32. All operations shall be conducted over private or controlled

- access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or 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 t he 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 Exe mption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety.18 LEE M. WOODWOTH

– PETITION FOR EXEMPTI ON

Lee M. Woodworth 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 Phantom 2 Vision+ and DJI Inspire 1 UASs unless that P IC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PI C is able to safely operate
the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS in a manner consistent with t he exemption, including evasive and emergency maneuvers and maintai ning appropriate
distances from people, vessel s, vehicles and structures.

Considering Lee M. Woodworth’s proposed area o f operations, and the operating
limitations set forth

- above; the parallel nature of priva te pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062);
and the airmanship skills necessary to safely operate the DJI P hantom 2 Vision+ or DJI Inspire 1 UAS, Lee M. Woodworth submits that the additional ma nned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for Lee M. Woodworth’s specific proposed flight operations.

The FAA has previously granted relief from Sec tion 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 110 67, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 1115 6, 11158, 11159 , 11160, 11161).

Lee M. Woodworth will not allow any PIC to opera te the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight

- hour requirements or the DJI Phantom 2 Vision+ or DJI Insp ire 1 UAS training and currency requirements, that the PIC is able to safely operate t he DJI Phantom 2 Vision+ or DJI Inspire 1 UAS in a manner consistent with this e xemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels,
vehicles and structures.

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot opera ting the same make and model of UAS to be used for operations under the exemption). In add ition 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, pri or documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during Lee M. Woodworth’s propose d 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 p urpose of motion picture filming (or similar operations), the PIC mu st have accumulated and logged, in a manner consistent wi th 14 CFR 61.51(b), 25
hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as19 LEE M. WOODWOTH

– PETITION FOR EXEMPTI ON

a UAS pilot with a multi

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

- rotor time and the 10 hours may be in cluded in the total 25 hours of UAS rotorcraft time. In
additio n to the hour requirements, the PIC must accomplish 3 takeoffs and
la nding s in the preceding 90 days (for currency purposes). The FAA finds that at a

minimu m, the flight

- hour requirements in Exemption No. 11062 are appropriate to practi ce and build proficiency in the skills necessary to safely conduct the petitioner ’s propo sed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requ irement. Training, proficiency, and experience

- building flights can also be conduct ed under the gr ant of exemption to accomplish the required flight time. Du ring 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.

Acc ordingly, Lee M. Woodworth will ensure safe operations by not allowing any

PIC to operate the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight

- hour and currenc y requirements, that
the PIC is able to saf ely operate the DJI Phantom 2 Vision+ o r DJI Inspire 1 UAS in

a manner consistent with the exemption, including evasive and eme rgency 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, Lee M. Woodworth will ensure that the DJI Phantom 2 Vision+ or
DJI Inspire 1 UAS is in an airworthy condition based upon the UAS’s compliance with its operating documents and as stated in the con ditions and limitations herein.

Additionally, the FAA has previously granted relie f from Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 110 67, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

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

The equivalent level of safety established by Section 91.121 will be maintained because the altitude information of the DJI Phantom 2 Vision+ and DJI Inspire 1 U As will be20 LEE M. WOODWOTH

– PETITION FOR EXEMPTI ON

provided to the PIC via GPS equipment and a radi o communications telemetry data link,
which downlinks from the UA to the GCS for active mo nitoring of the flight path and altitude. This altitude information, combined with Lee M. Woodworth’s opera tion of the

DJI Phantom 2 Vision+ and DJI Inspire 1 UAs within visual line of sight, at or below 4 00
feet AGL, will ensure a level of safety equivalent to Section 9 1.121. The altitude
information will be generated by GPS equipment installed onboard the ai r craft. Prior to each flight, a zero altitude initiation point is automatically establish ed by the UASs at ground level.

The FAA has previously granted relief from Sec tion 91.121 specific to UAS, in circumstances similar, in all material respects, to those p resented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 110 80, 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 Ad versely 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 Phantom 2 Vision+ and DJI Inspire 1 UASs; (2) the lim itations on the proposed flight operations; and (3) the location of the proposed flight oper ations. Accordingly, Lee M. Woodworth will ensure that it will safely operate the battery po wered DJI Phantom 2 Vision+ and DJI Inspire 1 UAs during daylight hours in VFR condition s, 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 Exemption No. 11109, the technical spec ifications of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs; the limitations on the prop osed 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). Furth ermore, safety will be ensured as the
DJI Phantom 2 Vision+ and DJI Inspire 1 UASs provide audible and vi sual warnings to the
PIC at the GCS when the UAs experiences low battery voltage, the first warning occurring at approximately 33% remaining battery po wer, and again at approximately 10% remaining battery power. At the critically low battery level, the DJI Phantom Vision+ and DJI Inspire 1 UASs will de scend and land automatically.

Significantly, previous exemptions granted by th e FAA concerning Section 91.151 establish that safety is not adversely affected when th e technical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescrib ed in Section 91.151, in cluding Exemption Nos. 2689, 5745, and 10650. Moreover, the FA A has previously granted relief from Section 91.151 specific to UAS, in circumstances simila r, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 108 08, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 111 36, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).21 LEE M. WOODWOTH

– PETITION FOR EXEMPTI ON

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, Lee M. Woodworth 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), 91.40 9(a)(1) & (a)(2), and 91.417(a) & (b) will be met because Lee M. Woodworth will use trained technicians to pe rform maintenance, alterations, or preventive maintenance on the UASs using the met hods, techniques, and practices prescribed in the operating docu ments (i.e., the Lee M.
Woodworth Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2

Vision + and DJI Inspire 1 Instruction Manual). Furthermore, Lee M. Woodworth will
docume nt and maintain all maintenance records for the DJI Phantom 2 Vis ion+ and DJI Inspire 1 UASs.

Since the DJI Phantom 2 Vision+ and DJI Insp ire 1 UASs will be inspected as prescribed by the operating documents, Lee M. Woodworth wil l 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 Phantom 2 Vision+ and DJI Inspire 1 User Manuals a re attached hereto as Exhibit C and D; a copy of the DJI Phantom 2 Vision+ and DJI I nspire 1 UAS Maintenance LOG is
attached hereto as Exhibit E.

Likewise, the exemption sought will not adversely a ffect safety because Lee M.
Woodworth will use trained technicians to perform mainten ance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed by the operating documents.

Fur thermore, the exemption sought would maintai n an equivalent level of safety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of th e DJI Phantom 2 Vision+ and DJI Inspire 1 UASs will be pe rformed by trained technicians.

Maint enance will be documented and maintained utilizi ng 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
adve rsely affected when the technical characteristics a nd operating limitations of the
UAS are considered.

In consideration of Lee M. Woodworth’s proposed operating limi tations, the operating documents, and the technical aspects of the DJI Phan tom 2 Vision+ a nd DJI Inspire 1 UASs, Lee M. Woodworth 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 s pecific to UAS in circumstances similar, in all material respects, to those presented her ein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110 , 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).22 LEE M. WOODWOTH

– PETITION FOR EXEMPTI ON

7. The F AA 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, Lee M. Woodworth requests that the FAA prescribe special cond itions for the intended operation of the DJI Phantom

2 Vision+ and DJI Inspire 1 UASs, which contain such safety standards that the Administrator finds necessary to establish a level of safety eq uivalent 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 photogr aphy over certain areas of the United States for compensation or hire. FMRA Section 333 sets forth t he 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 f urther, provides the au thority for such UAS to operate
without airworthiness certification in accordance wit h any requirements that must be established for the safe op eration of the UAS in the NAS.

Likewise, the Administrator may prescribe special c onditi ons pursuant to 14 C.F.R. § 21.16, for operation of the DJI Phantom 2 Vision+ an d DJI Inspire 1 UASs, since the airworthiness regulations of 14 C.F.R. Part 21 do not co ntain adequate or appropriate safety standards, due to the novel or unusual design featu res of the aircraft. Section 21.16, entitled Special Co nditions, states the following:

If the FAA finds that the airworthiness regulations of this subchapter do not

con tain adequate or appropriate safety standards for an aircraft , aircraft engine,

or prop eller because of a novel or unusual design feature of t he aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product

. The special conditions are issued in accordance w ith Part 11 of this chapter and cont ain such safety standards for the aircraft, airc raft engine or propeller as the FAA finds necessary to establish a level of safety eq uivalent to
that established in the regulations.

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 an d 14 C.F.R. § 21.16, the FAA may prescribe special conditions for Leading Edge’ s intended operation of the

DJI Phantom 2 Vision+ and DJI Inspire 1 UASs, which contain such safety
standards that the Administrator finds necessary to establish a level of safe ty

eq uivalent 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 Regist er :

Lee M. Woodworth 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).23 LEE M. WOODWOTH

– PETITION FOR EXEMPTI ON

A Brief Description Of The Nature Of The Exemption Lee M. Woodworth Seeks:

This exemption will permit Lee M. Woodworth to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States.

Any Additional Information, Views, Or Arguments Available To Support Lee M. Woodworth’s Request:

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if

certain UAS may operate safely in the NAS. As such, Lee M. Woodworth’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 wheth er a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without
airworthiness certification.

As discussed in detail above, Lee M. Woodworth will operate the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.



### CONCLUSION

As set forth herein, Lee M. Woodworth seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs 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
al so advancing the interests of the public, by allowing Lee M. Woodworth to safely, efficiently, and economically operate the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs commercially
within the NAS.

Wherefore , in accordance with the Federal Aviation Regulat ions and the FAA Modernization and Reform Act of 2012, Section 333, Lee M. Woodworth 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), 9 1.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Leading Edge to operate the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs commercially for the purpose of conducting aerial video and photography over certain
areas of the United States.

Dated: June 4, 2015

Respectfully submitted,

Lee M. Woodworth24 LEE M. WOODWOTH

– PETITION FOR EXEMPTI ON



### APPENDICES

A

– DJI Phantom 2 Vision+ Manufacturer’s User Manual

B

– DJI Inspire 1 Manufacturer’s User Manual