5. Extent Of Relief JDS Design Concepts Media Seeks And The Reason JDS Design Concepts Media Seeks Relief F rom Sections91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), And 91.417(a) & (b). Since Sections 91.405(a) , 91.407(a)(l), 91.409(a)(l) & (a)(2) , and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, IDS Design Concepts Media requests relief from these Sectio ns because the DJI Phantom 3 UAS does not require

a irworthiness certificates. As set forth more fu ll y below, the DJI Phantom 3 UAS meets the cond iti ons of FMRA Section 333 for operat ion without an airworthin ess certificate. Accordingl y , JDS Design Co ncepts Media will use train ed technicians to perfo rm maintenance, alterations , or preventive maintenance on the UASs using the methods , techniques , and practices prescribed in the UAS operating documents (i .e. , the Aerial Operations Manual , Monthly Maintenance Log , and DJI Phantom 3 Instruction Manual ). Furthermore , IDS Design Concepts Media will document and maintain all maintenance records for the DJI Phantom 3 UAS

.
D. The Reasons Why Granting JDS Design Concepts Media Request Would Be In The Public Interest ; That Is, How It Would Benefit The Public As A Whol e. Granti ng the present Petit ion will further the public interest by allowin g JDS Design Concepts Media to safel y , efficient l y, and economical l y perfo rm aerial video and photo g r ap hy for Non-Profit and C ommuni ty Organizations, as well as , pursue revenue for a Small Business in the USA as we provide commercial services for Homes and Land for sale, Places of Lodging , Golf Courses , and other commercial properties seek in g the described serv ices for marketing purposes over certain areas of the Lafayette , Lo ui s iana and the surrounding areas . Additionall y , use of the DJI Phantom 3 UAS wi ll decrease congestion of the NAS a nd r educe pollution , since past aerial photography required large mannedaircrafts for extended periods of time. Notably, the benefits of JDS Design Concepts Media proposed operation of the DJI Phantom 3 UAS will be realized without implicating any privacy issues. 

### 1

. The Public Will Benefit From Decreased Congestion Of The NAS. The DJI Phantom 3 U A are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utili ze d to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the us e of a DJI Phantom 3 UAS would reduce th e amount of manned aircraft in th e NAS, reduce noise and air pollution , as well as increase th e safet y of lif e and property in the air and o n the gro und (as outlined in Ex hibit D). Further more, by reducin g th e number of manned aircraft operating in the NAS , congestion around airports caused b y arriv in g and departing aircraft w ill be reduce d. The DJI Phantom 3 UA do not require an airport to takeoff or land. Likewise , a reduction of manned aircraft cond ucting aerial video and photography mi ss ions wou ld result in fewer aircraft that mu st be handled by air traffic control during the ground , takeoff , d eparture, arrival , and landing phases of flight op erations. 

### 2

. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 3 UAS. Conducting aerial acquisition s with the DJI Phantom 3 UAS, in stead of manned aircraft, will greatly b e n efit the public by drastically reducing the levels of air and noise pollution generated durin g traditional aerial video and st ill photography flight operat ions. By using battery power and electric motors , the DJI Phantom 3 UAS produce no a ir pollution , and is th e most viable environmentally conscious alternative to th e cabin clas s, six cylinder internal comb u stion e ngine aircraft that ar e typicall y utili ze d for aerial video and photography, while burning approximately 20-30 gallons 

# t6per hour of leaded aviation fuel. The DJI Phantom 3 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 DJI Phantom 3 UAS to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground , which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft , the DJI Phantom 3 UA (weighing approximately 2 pounds 11 ounces and 6 pounds 7.5

ounces respectively, at their maximum 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 , 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 fuel capacity of 180 gallons).


### 3. Performing Aerial Video and Photography Operations with The DJI Phantom 3 UAS Will Benefit Non-Profit and Community Organizations. IDS Design Concepts Media As stated earlier in this petition, provides free services to Non- Profit and Community Organization that normally could not afford to have their event or site professionally photographed. The community and surrounding areas benefits. 

### 4. Performing Aerial Video and Photography Operations with The DJI Phantom 3 UAS Will Benefit The Economy. In addition to being safe and efficient, the DJI Phantom 3 is also an economical alternative to using manned aircraft to conduct similar aerial operations. As such ,operation of the DJI Phantom 3 UAS will allow United States based companies , like

, IDS Design Concepts Media 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") regu l atory actions phasing out leaded aviation fuels , U .S. owned and operated companies must adopt new and alternative technology in order to

rema in competitive. Operating the battery powered DJI Phantom 3 UAS is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provide s such flexibility without the high operational cost of a traditional manned aircraft. By operating the DJI Phantom 3 UAS , companies such a IDS Design Concepts Media , can remain competitive and profitab le , and therefore , provide greaterjob stabi li ty to employees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved financ ial performance of U.S. companies , through commerc i al

us e of the DJI Phantom 3 UAS , provides a stab le 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. 

### 5. There Are No Privacy Issues. Similar to the manned aerial acquisition flight operations that have been conducted for decades , IDS Design Concepts Media proposed operation of the DJI Phantom 3 UAS will not implicate any privacy issues. Specifically, the DJI Phantom 3 UAS will be operated only in compliance with operating documents (i.e., the IDS Design Concepts Media Aerial Operations Manual, Monthly Maintenance Log , and DJI Phantom 3 Instruction Manual) which requires property owner involvement as well as local law enforcement notification, 

# t8and in accordance with the Federal Aviation Regulation s , includ in g the 

### minimwn 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 Eq ual To That Provided By The Rule From Which JDS Des ign Concepts Media Seeks Exe mption. 1. 

### Reasons Why The DJI Phantom 3 UA Meet The Conditions Of The FAA Modernization and Reform Act of2012 (FMRA) Section 333. In consideration of the size, weight, speed , and limite d operating area associated with the unmanned aircraft and its operation JDS Design Co ncepts Media , operation of the DJ I Phantom 3 UAS meet the conditions ofFMRA Section 333 , and will not require

an a irworthiness certificate in accordance wit h 1 4 C.F.R. Part 21 , Subpart H. Sectio n 333 provides authority for a UAS to operate w itho ut airworthi n ess cert ific ation and sets forth requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise po se a threat to national security. Specificall y, FMRA Section 333 states the following , in p art: (a) in GeneraL--Notwithstanding any other requirement of this s ubtitle, and not later than 180 days after th e date of enactment ofthis Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace

**.~Jystem** before completion of the plan and rulemaldng required by section 332 of this Act o r the guidance required by section 334 of this Act. (b) Assessment ofUnmanned Aircraft Syslems.--ln making the dete rmination 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 opera/ion within visual line of s i

ght do not creale a hazard to users of the national airspace system or !h e public or pose a threat to national security; and (2) whether a certificate of waiver , certifica te of authorization, or ainvorthiness certification under section 44704 of title 49 , United States Code, is required for the operation ofunmcmned aircraftsystems identified un de r paragraph (1). (c) R equ irements for Safe O p eration.

- -If the Sec r etar y dete rm ines unde r th is section that ce rta in unmanned aircraft systems may operate safely in the national airspace system, the Secreta r y shall establish requirements for the safe opera ti on of such a i rcra ft systems in the n ational airspace system. JDS Design Concepts Medi a 

### In seekin g thi s exe mpt i on , s ubmits that th e DJI P hantom 3 UAS can op erate safe ly in th e NAS p urs u a nt to FMRA Sec tio n 333, as d emonstra ted by: (a) th e ch aracte ri s tics of th e DJI Phanto m 3 UAS; (b) th e pil ot certifica ti on req uiremen t;

an d (c) the s pec ifi c op e r a tin g li mita ti o n s.



### a. The Specifications Of The DJI Phantom 3 UAS Demonstrat e Its Safe C haracteristics. Th e DJI Ph antom 3 U AS does n ot create a hazard to users of th e NAS o r the pu bli c , o r oth erw i se pose a threat to na ti o nal secur ity co n s i dering its s i ze , we i ght , sp eed , and o p erati ona l capab ili ty . 

### i

. T echnical S pecifications Of The DJI Ph a ntom 3 UAS. The tec hni cal spec ificat i on s of th e DJ I Phantom 3 UAS is set fo rth by th e DJI Ph anto m 3 Specification s an d D ata Shee t, attac hed h ereto as Exhib it A. 

### ii

. The DJI Phantom 3 UAS Autonomous F light And Navigation Modes Enable The U AS To Remain Within A Defined Operational Area. Th e DJI Ph anto m 3 UAS m ay b e opera ted in bo th manua l and fully autonomous fl ight modes. A co mpl ete desc ri pti o n of th e fli ght an d n av igati o na l mo des of the DJI Ph an to m 3 UAS is p ro v id ed at pages 25

-32 o f the DJI Phan to m 3 User M a nua l , attached hereto as Exhi b it B

. 

### iii

. The DJI Phantom 3 UAS Are Designed For Autom a tic Return To Home Point Or Hover In T he Event Of Loss Of T he C ontrol Link Or Naviga tion. When th e Contro l 

### Link i s los t , t he DJI Phantom 3 UA wi ll rema in

20stationa ry , in flight , for 3 seconds or more. If , after 3 seconds , the DJl Phantom 3 UA does not reacquire contro l link data from the GCS, th e UA will assume that the Contro l Link is lost and the UA will return to the home po sitio n (i.e. , fa il safe mode) via GPS , and w ill descend to the takeoff position and shutdown.

A complete description of the Fail safe F un c ti ons of the DJI Phantom 3 UAS are

se t forth at pages 27 through 28 of the DJI Phantom 3 Use r M anu a l, attac h ed he reto as Exh ibit B. 

### iv. The DJI Phantom 3 GCS And Its Operation. A co mplete description ofthe operation and s p ecifications of th e DJI Phantom 3 GCS and flight control software is provided at pages 32 through 43 of the DJl Phantom 3 User Manual. DJI Phantom 3 User Manu al i s attached hereto as Exhib it 

### B. b

. Flight Operations OfDJI Phantom 3 UAS Arc Limited To The Line Of Sight Of A Certificated Pilot in Co mmand With A Safety Observer

.

. IDS Design Concepts Media wi ll only utilize certificated pilots who possess a

c urre n t a nd va lid a im1an med ical certificate to act as a pilot in com mand (PIC) of the DJI Phantom 3 UAS. Additionally, a safety observe r wi ll ass is t a ll pilots during flight time. And the guidel in es exhibited in D , will be fo ll owed at a ll -times e ns urin g t h e safety of all i nvolved.



### c. Flights Of DJI Phantom 3 UAS Will Be Co nducted Pursuant To S pecific Operating Limitations. in seeking this exempt i on, proposes to commerciall y operate DJI Phant om 3 UAS for the spec ia l purpose of conductin g aerial v i deo and photo graphy over certain areas of Oneida Co unty and s urrounding areas, purs u ant to the fo ll owing speci fic operati ng limitation s: 

## 2.11. Operations authorized by this grant of exe mpti o n will be limi ted to the fo ll ow in g aircraft d esc rib ed in the operating documents , rotorcraft UASs weighing less than 55 pounds maximwn gross weight: DJI Phantom 3 Unmanned Aircraft System. Proposed operations of any other a ircraft wi ll 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 indi cated airspeed exceed in g 20 knots. 4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL) , as indi cated by the procedures specified in the operating documents unless a special request is made and approved by ATC. All a ltitud es reported to ATC must be in feet AGL. 5

. The UAS must be operated within visual line of s ight (VLOS) of the PIC at all times. This requires the PIC to be ab le to use hwnan vision unaided by any device other than correcti ve lenses , as specified on the PIC ' s FAA-issued airman medical certificate. 6

. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted. 7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capab ili ty. The SO and PIC must be able to communicate verba ll y at a ll times. Electronic messaging or texting i s not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the SO can perform the functions prescribed in the operating documents. 8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is not permitted to operate the camera or other instrwnents. 9. The operating documents and the grant of exempt ion must be accessib le 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 co nditi ons and limitations contained in the grant of exemption take precedence and must be followed. Otherwise , the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator ' s responsibility to track such 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 operator determines that any update or revision wou ld affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to it s grant of exemption. The FAA ' s U AS Integration Office (AFS-80) may be contacted if questions arise regarding updates or revisions tothe operating documents. l 0. 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 cond ition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the n ecessary maintenance has been performed and the UAS is found to be in a cond iti on for safe flight. The Ground Control Station must 

### be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records. 11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics , e.g. replacement of a flight critica l 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 a ll potential discrepanc ies , e.g. inoperable components , items , or equipment, not already covered in the relevant sectio ns of the operating documents. 13. The operator must fo ll ow the UAS manufacturer ' s aircraft/component , maintenance , overhaul , replacement, inspection , and life limit requirements. 14. The operator must carry out its maintenance , inspections , and record keeping requirements , in accordance with the operating documents. Maintenance , inspection , alterations , and status of replacement/overhaul component parts must be noted in the aircraft records , including total tim e in service , descripti on 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 cert i ficate. 18. The operator may not permit any PIC to operate unless the PIC meets the operator ' s qualification cr iteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption , inclu ding 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). Fli ghts for the purposes of training the operator's PICs arepermitted under the terms of the exe mption. However , training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience-building flights , all persons not essential for flight operations are considered nonparticipants , and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. 

### § 91.119. 19. UAS operations may not be conducted during night , as defined in 14 C.F.R. § 19.1. All operations must be conducted under vis ual meteorological cond iti o n s (VMC)

. If flight at night is required, a special request will be made at th e FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized. 20. The UA ma y not operate within 5 nautical miles of an airport reference point as d enoted 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 NOT AM as required by the operator's COA. The letter of agreement with the airport management must be made avai l able to the Administrator upon r eq ue st. 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 pred etermi ned 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 fli ght unle ss (co nsidering wind and forecast weather conditions) there i s enough power to fly at norm al cruising speed to the intended landing point and land the U A with 25% battery pow er 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 exem ption. 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 hour s prior to the operation. All operations shall be conducted in accordance with airspace requirement s in the A TO iss ued COA including class of airspace, altitude le ve l and potential transponder requirements. 26. All aircraft operated in accordance with the exemption must be identifi ed by serial number, registered in accordance with 14 C.F.R. part 47 , and have identification (N- Number) markings in accordance with 14 C.F.R. part 45 , Subpart C. Markings must be as la rge as practicable. 27

. Before conducting operations , the radio frequency spectrum used for operation and control of th e UA must comply with th e FederalCommunicatio n s Commissio n (FCC) or other appropriate government oversight agency r equirements. 28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be avai lab le to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made ava il ab le to the dministrator or any law enfo rc ement official upon request. 29. IDS Design Co ncepts Media abides and enforces the safety check li st to as exhibited in sectio n D to ensure that we provide safety for everyone in and near to the site

.. 30. The UA must remain clear and yield the right of way to a ll manned aviation operations and acti vities at all times. 31. The UAS may no t be operated by the PIC from any movin g device or vehicle. 32. Flight operations must be cond u cted at least 400 feet from all nonparticipating persons (persons other than the PIC , SO , operator trainees or e ssent i a l p ersons) , vessels , vehicles , and structures unless:

a. Barriers or structures are present that s u fficiently protect nonparticipating persons from the UA and/or debris in the event of an acc ident. The operator must ens ure that nonparticipating persons remain und e r suc h protection. If a situation arises where nonparticipating persons leave s uch protection and are within 500 feet of the UA, flight operations must cease immediately and/or; b. The a ircraft i s operate d near vesse ls , ve hicl es or stru ctures where the owner /contro ll er of s uch vesse l s , ve hi c les or structures has granted permission and the PIC has made a safety assessment of the risk of operatin g closer to those objects and determined that it does not present an undue hazard , and;

c . Operations nearer to the PIC , SO , operator traine e s or e ssential persons do not present an undue hazard to those persons per 

### § 91.119(a). 33. All operations shall be conducted over private or controlled-access property with permission from the land owner/controller or authoriz ed representative

. Permission from land owner/controller or authorized representative wi ll be obta in ed for each flight to be conducted. 34. Any incident, accident , or flight operation that transgresses the lateral or vertical boundaries of the op erational area as defined by the app li cable 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.go, ·.2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety. IDS Design Concepts Media s ubmits that the equivalent level of safety established b y Section 61.1 I 3(a) and (b ) w ill be maintained because no PIC w ill be allo wed to ope r ate the DJI Phantom 3 UAS unless that PIC has demonstrated , by meet in g minimum flight- hour and currency require ments, that the PIC is able to safely operate the DJI Phantom 3 UAS in a mann e r consistent with the exemption , including evasive and emergency

maneuvers and maintaining appropriate distances from people , vesse l s , ve hicl es and structures. Considering IDS D es ign Concepts Media proposed area of operations, and the op erating limitation s set forth-above; the paralle l nature of private pilot aeronautical knowledge requirements to those of commercial pilot require me nts (See Exe mption No. 1I 062) ; and the airmanship ski ll s necessary to safe ly operate the DJI Phantom 3 UAS , ID S D es ign Concepts Media submits that the additional manned airmanship experience of

a commerc iall y certificated pilot would not correlate to th e airmanship skills necessary for IDS D es ign Co ncepts Media specific proposed flight operations. The FAA has previously granted relief from Section 61.113(a) and (b) s pec ific to UAS , in circumstances s imilar, in all mate ri al respects , to tho se presented h erein (e.g

. Exemption Nos

. 11062 , 1106 3,11064 , 11065 , 11066 , 11067 , 11080 , 11109 , 11110 , 11112 , 11136 , 11138 , 11150 , 11153 , 11156 , 11158 , 11159 , 11160 , 11161). IDS Design Concepts Media will not allow any PIC to operate the DJI Phantom 3 UAS unless that PIC has demonstrated , by meeting minimum flight-hour requirements or the DJI Phantom 3 UAS training and c urr e ncy requirements , that the PIC is able to safely operate the DJI Phantom 3 UAS in a manner consistent with this exemption , includin g evasive and emergency maneuvers and maintaining appropriate distances from people ,

# 27

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 oftotal time as a UAS rotorcraftpilot (w ith 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 und e r the exemptio n). In addition to the hour requiremen ts, the PIC must accomplish 3 takeoffs and landin gs in the preceding 90 days (for currency purposes). As in Exemption Nos. 11062, 11138 , and 11153 , prior documented flight experience that was obtained in compliance with applicable regulations will ensure an eq uival ent level of safety during JDS Design Concepts Media proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable regulation s would e nsure safe operations, stating as follows: In Exemption No. 11062 , the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar operations) , the PIC must have accumulated and lo gged , in a manner consistent with 14 CFR 61.51 (b) , 25 hours of total time as a UAS rotorcraft pilot includin g at least 10 hours lo gged as a UAS pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062 , the PIC must also have accumulated and lo gged a minimum of 5 hours as a UAS pilot operating the same make and model ofUAS to be us ed for ope r ation s under the exemption. For clarification, the FAA considers these minimum hour requireme nt s to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi-rotor time and the 10 hours may be included in the total 25 hours ofUAS rotorcraft time. In addition to the hour requirements, the PIC mu st accomplish 3 takeoffs and landings in the preceding 90 days (for currenc y purpo ses). The FAA finds that at a minimum, the flight-hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the ski lls necessary to safely conduct the petitioner's proposed operations. The FAA a lso finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience-building flights can also be conducted und er the grant of exe mption to accomplish the required flight time. During training, proficiency, and experience-bui ldin g flights the PIC is required to operate the UA with approp riatedistances in acco rdanc e wit h 14 C.F

.R 91.119. Exe mption No

. 111 38 at page 1 5. Accord in gly, ID S Design Concepts Media will ensure safe operations by not allowing any PIC to operate the DJI Phantom 3 UAS un less that PIC has de mo n strated, by meeting minimum fli ght-hour a nd currency requirements , that th e PIC is able to safely operate the DJI Phantom 3 UAS in a mann e r co ns i ste nt w ith th e exemp tio n , includin g evas ive and emerge nc y man euvers and maintaining appropriate distances fr

om people, vesse l s, vehic les and structures . 

### 3. Reasons Why An 

### Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety. IDS Design Concepts Media requires a tight set of rul es that follow best practices and FAA requirements and gui d el ines (Exhibit D ). T he equivalent level of safety estab li s hed by Sectio n 91

.7(a) will be maintained because prior to every flight , plus ID S Design Concepts Media a lso requires th e safety

c hec kli st in Exhibit D that ensures that the DJI Phantom 3 UAS is in an a irwo rth y condition based upon the UAS's comp li ance with its operating documents and as stated in th e co ndition s and limitatio ns herein. Additio nall y, the FAA ha s previo u sly granted r e li ef from Section 9 1.7 (a) specific to UAS, in c ircum s tan ces similar, in all material respects , to those presented herein (e.g. Exemption Nos. 11062,11063, 11064, 11065 , 1106 6,11067, 11080 , 11109 , 11110 , 11 1 12, 1 1136,11138, 11150 , 1115 3, 11156 , 111 57, 11158 , 111 59, 111 60, 11161). 

### 4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Mfect Safety. As outlined in Exhibit D , IDS D es ign Co ncepts Media fl y's only u nd er a very set rul es . We believe these rules include and go beyo nd c urr ent FAA gu ide lin es. T he r efore, the eq ui vale nt leve l of safety esta bli s hed by Sectio n 91.121 will be maintained because the

# 2-'1

altitude inf o rmation of th e DJI Phantom 3 UA will be provided to the PIC v ia GPS equipment and a radio communications telemetry data link , which downlinks from the UA to t he GCS fo r active monitorin g of the flight path and altitude. This altitude information , combined w ith IDS De s ign Concepts Media operation of th e DJI Phan tom 3 UA wi thin visual line of s i ght , at or below 400 feet AGL, will en sur e a level of safety eq ui valent to Sect ion 91.121. The altitude information will be ge nerated by GPS

equipm ent in stall e d onboard the aircraft. Prior to eac h fli ght, a ze r o altitude ini tiation point is a uto m atica ll y estab li s hed b y the UASs at ground level. The FAA has previously grante d relief from Section 91.1 2 1 spec ific to UAS , in

c ircumstances si milar, in all material respec ts , to thos e presented he r e in (e

. g. Exe mption Nos. 11062 , 11063 , 11064 , 11065 , 11066 , 11067 , 11080, 11109, 1111 2 , 11136, 11 1 38 , 11150 , 1115 3 , 11156 , 111 57 , 111 58 , 11159 , 11160 , 11161 ). 

### 5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely Affect Safety. A grant of this exemption wo uld ensure an eq ui va l e nt level of safety e stabl i s hed by 14 C.F.R

. Section 91. 151 (b) as a res ult of ( 1) the technical specifications of the OJ I Phantom 3 UAS; (2) the limitatio ns on the propo sed fligh t operations; and (3) th e locati on of the propo sed fli ght operations. Accordingly, ID S D es ign Concepts Media will e nsure that it will safel y operate the battery powered DJI Phantom 3 UA during daylight hours in VFR conditions , with eno ugh battery power to fly for a total duration of 1 3 .5 minutes to the fir st point of intended landin g and , ass umin g no rm a l cruising spee d , to fly after that for a t leas t 4.5 minutes.
Here, as in Exemption No

. 11109 , the technical spec ific at ion s of t he DJI Ph an tom 3 UAS; the limitation s on th e proposed flight operations; and the locatio n of t he proposed operations , will en s ure an eq uival ent leve l of safet y es ta bli shed by 1 4 C.F.R

. Sectio n 91. 151 (b). Furthermor e , safety will be ensured as the DJI Phantom 3 UASprov id e audible and vis ual warnin gs to the PIC at the GCS wh en the UAS experiences low battery voltage , the fust warning occurring at approximately 33% remaining battery power, and again at approximate ly 10 % remaining battery power. At the critica ll y low battery level , the OJI Phantom Vision + UAS w ill d escend and land automatically. Significantly, previous exemptio ns granted by the FAA concerning Section 9 1.1 51 establ is h that safety is not adverse ly affected when the technical characteristics and operating l imitations 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 Exempt ion Nos

. 2689 , 5745 , and 10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS , in circ um stances simi l ar, in all material respects , to those presented herein (e.g. Exemption Nos. 88 11 , 10808, 10673, 11042 , 110 62 , 11063 , 11064,11065,11066,11067 , 1 1080 , 111 09 , 111 10,11136 , 111 38 , 11150 , 11153 , 11156 , 111 57 , 11158 , 11159 , 11160 , 11161). 6. Rea so ns Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety. 

### In seeking this exemption , IDS Design Concepts Media submits that the equ i valent level of safety with regard to the regulatory maintenance and alteration requirements estab li s hed by Sections 9 1. 405(a) , 91.407(a)( 1) , 91.409(a)(l) & (a)(2) , and 91.417(a) & (b) will be met because IDS Design Concepts Media will use trai ned technicians to perform maintenance, a lterations, or preventive maintenance on the UAS using the methods, techniques , and practices prescribed in the operatin g documents (i.e. , the JDS Design Concepts Med ia Aerial Operations Manu al , Monthly Maintenance Log , and DJI Phantom 3 Instruction Manual). Furthermore , JDS Design Concepts Media wi ll document and maintain all maintenance records

# '?I

for the DJI Phantom 3 UAS.

Since the DJI Phantom 3 UAS will be inspec ted as prescribed by the operating documents, IDS Design Concepts Media w ill maintain the equivalent lev el of safety established by Sections 91.405(a ), 91.409(a)(l), and 91.409(a)(2). A copy of the DJI Phantom 3 User Manuals are attached hereto as Exhibit B ; a copy of th e DJI Phantom 3 UAS Maintenance LOG i s attached hereto as Ex hibit C. Likewise , the exemption sought will not adversely affect safety becau se JDS Des ign Concepts Media will use trained technicians to perfom1 maintenance , a lterations or preve ntive Maintenance on the VAS u s ing the methods , t echniques , and practices prescribe d by the operating document s . Furthermore, the exe mption so ught would mai ntain an equivalent le ve l of safety estab li s hed by Sections 91.407, 91.417(a) and 91.417(b), because a ll maintenanc e of the DJI Phantom 3 UAS will be performed by train e d technicians. Maintenance will be documented and maintained utilizin g th e monthly maintenance log. Significantly, previou s exemptions granted by th e FAA concerning Sections 91.405(a) , 91.407(a)(l), 91.409(a)(1) 

### & (a)(2), and 91.417(a) 

### & (b) establish that safety i s not adve rse ly affected when the technical characteristics and operating limitation s of the UAS are considered. In consideration of IDS Design Concepts Media propos ed operatin g limi tations, the operating documents , and the technical aspects of the DJI Phantom 3 UAS , IDS Design Concepts Media s ubmits that safety will not be adv erse ly affected by granting

exe mption from 14 C.F.R. Sections 91.405(a), 91.407(a)(l) 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 respects , to those presented herein (e.g. Exemption Nos. 11062 , 11063 , 11064 , 11065 , ll066 , 11067 , 1 1080 , 11109,11110 , 11112 , 11136 , 11138 , 11150 , 11153 , 11156,11157 , 11158 , 11159,11160, 11161)

. In additional 350 Sky Vision fly only under a tight set of rules which can be fo und in Exhibit D, which ensure t h e safest operat i on under any foreseen circumstance.



### 7. The FAA May Prescribe Any Other Cond it ions For Safe Operation

. In accordance w ith Section 333 ofthe FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F

. R. 

### § 2 1.1 6 entitled Specia l Cond iti ons , IDS Design Concepts Media requests that the FAA prescribe special conditions for the intended operation of the DJI Phantom 3 UAS , which contain s uch safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F

.R. Part 2 1 , Subpart

H, and 14 C.F.R §§ 61.113(a) & (b), 9 1. 7 (a), 91.121 , 91.151 (b) , 91.405(a) , 91.407(a)(I ) , 91.409(a)(1) & (a)(2) , and 9 1.417(a) & (b)

. Such special condition s wi !J permit safe operation of the UAS fo r the limited purpose of conducting aerial video and photography

over certain areas of the United States for compensatio n or hire. FMRA Section 333 sets forth the requirements for cons iderin g wh ether a UAS will create a hazard to users of the NAS or the public, o r otherwise pose a threat to nati onal security; and f urth er , provides the authority fo r such UAS to operate without a irworthiness certific ation in accordance with any requirements that must be established for the safe operation of the UAS in the NAS

. Likewise , the Administrator may prescribe spec i al cond itions pursuant to 14



### 32C.F.R. 

### § 21. 16 , for operation of the DJI Phantom 3 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, e ntitle d Special Conditions, states the following: lf the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine , or propeller because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are i ss ued in accordance with Part 11 of this chapter and contain such safety standards for the aircraft, aircraft en gi ne o r propeller as the FAA finds necessary to establish a level of safety equivalent to that established in the regulations. See 14 C.F. R

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

### OJI Phantom 3 UAS, which contain such safety sta ndards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C. F.R. Part 21, Subpart H , and 14 C.F.R Sections 61.113(a) & (b) , 91.7(a), 91.121 , 91.151(b) , 91.405(a) , 91.407(a)(l) , 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 JDS Design Concepts Media Seeks Exemption: Horus Aer ial Services seeks exemption/rom the requirements of 14 C.F.R Sections 61.JJ3(a)&(b) , 91.7(a), 91.121 , 91.15/(b) , 91.405(a), 91.40 7(a)(l), 91.409(a)(1) & (a)(2) , and 91.417(a) & (b). A Brief Description Of The Nature Of The Exemption JDS Design Concepts Media Seeks: This exemption will permit IDS Design Concepts Media 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 JDS Design Concepts Media Request.

33This Petition is made pursuant to the FAA Modernization and Refom1 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, IDS Design Concepts Media 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 public , or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness c e rtification. As discussed in detail above, IDS Design Concepts Media wi ll operate the DJI Phantom

3 UASs safely in the NAS, without creating a hazard to user s of the NAS, or the public , or otherwise pose a threat to national security.

34CONC LU S IO N As set forth here in , ID S D esign Concepts Media see ks an exemption pursuant to 14 C. FR.



### § 11. 6 1 and Section 333 ofthe FAA M oderni zat io n and Reform Act ot20 1 2 (FMRA), wh i c h wi ll permit safe operat io n ofthe DJI Phantom 3 UAS co mme rc ia ll y, w ith out an airworthiness cert ifi cate, for the limited purpose of conducting aeria l v id eo and ph otograph y over Lafayette, Lo ui s ia na a nd s urroundin g area. B y grantin g this Pet ition , the FAA A dmini s trator w ill be fulfil ling the Congress io nal mandate ofthe FAA Modernizat ion and Reform Act of2012 , w hil e a lso advanc in g the interests ofthe public, by a ll ow in g IDS D es ign Concepts M edia to safely , effic i ent ly, and
eco nomica ll y operate th e DJJ Ph anto m 3 UAS commerciall y within the NAS. WHEREFORE , in acco rd ance wi th th e Federa l Av iation R egu lati o n s and the FAA Modernization and R efo rm Act of20 1 2 , Sect ion 333, IDS D es ign Co ncept s M edia respectfu ll y requests that the Adm ini strato r gra nt this Petit io n for a n exemptio n from th e requirements of 14 C.F.R Sectio ns 61.l13(a) & ( b) , 91.7(a), 91. 1 21, 91.151 (b), 9l.405(a), 9 1. 407(a)( l ) , 91.409(a)(l) & (a)(2) , and 9 1. 4 17(a) & (b) , a nd permit Leading Edge to operate the DJT Ph antom 3 UAS commercia ll y for the purp ose of cond uct in g aeria l v ideo and ph otography ove r ce rta in areas of the U ni ted States. Dated: June 25 , 2015

R

espectfully submitted, .Ja:q:flSirnpm Of JD S D esign Concepts M edia

JD S De s ig n Concept s

Jo seph S imp son 114 Ocatahou l a Road Lafayette , Loui s i ana 7050 I E

m

a

i l : j ds269@gmail.co m



## 3§'Exhibits: A- DJI Phantom 3 Specifications Data Sheet B - DJI Phantom 3 Manufacturer's User Manual C

- Monthly Maintenance log D -Horu s Aerial Services On

- Site Safety Checkli st

E XHIBIT- A 

### DJI PHANTOM 3 TECHNICAL SPECIFICATIONS JDS Design Concepts Media on ly utilizes safe and r e li ab le UASs

. DJI is an indu stry leader in small UAS production. DJI UASs are loaded w ith ground breaking software e nablin g the u ser to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no hi g her than a p redetermined and set altitude as well as limit flight to a predetermined and set di stance . In addition , DJI software provides realtim e altitude and location information to the PIC v ia the linked monitor (smart phone/tab l et devices)



### Aircraft

Remote Control

Range Extender Supported Battery : DJI 5200mAh LiPo Battery Weight (Battery & Propellers included) : 1242g Hover Accuracy (Ready to Fly) : Vertical: 0.8m; Horizontal: 2.Sm Max Yaw Angular Ve l ocity; 200°/S Max Tiltable Angle : 35° Max Ascent 

### I Descent Speed : Ascent: 6m/s; Descent: 2m/s Max Flight Speed : lSm/s (Not Recommended) Diagonal motor-motor distance : 350mm Operating Frequency : 5.728 GHz-5.85 GHz Communication Distance (open area) : CE Compliance: 400m; FCC Compliance: BOOm Receiver Sensitivity (1%PER) : -93dBm Transmitter Power : CE Compliance: 25mW; FCC Compliance: lOOmW Working Voltage : 120 mA@3.7V Built - in LiPo Battery Working Current/Capacity : 3.7V, 2000mAh Operating Frequency : 2412-2462MHz Communication D i stance (open area) : 500-700m Transmitter Power : 20dBm Power Consumption : 2W



### 36