1 UNITED STATES
DEPARTMENT OF TRANSPORTATION
FEDERAL AVIATION ADMINISTRATION WASHINGTON, D.C.

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Strumpher Enterprises Inc. dba AmeriSpec Home Inspe ction Service and Aerial Photography & Video
Solutions Inc.

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMEN TS OF
TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b ), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNI NG COMMERCIAL
OPERATION OF DJI PHANTOM 3 PROFESSIONAL UNMANNED AI RCRAFT SYSTEM
PURSUANT TO SECTION 333 OF THE FA A MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on December 18, 2015 Dana L. Strumpher - President Strumpher Enterprises Inc. dba AmeriSpec Home Inspe ction Service And Aerial Photography & Video Solutions Inc. 35 Twilight Lane Springfield, IL. 62712
217-529-53542 TABLE OF CONTENTS

Page

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

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

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

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

INTRODUCTION AND INTERESTS OF PETITIONER..

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

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

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

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

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

NAME AND ADDRESS OF PETITIONER.....

................................................... ...........................6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH STRUMPHER ENTERPRISES
INC. dba AMERISPEC HOME INSPECTION SERVICE and AERIAL PHOTOGRAPHY
& VIDEO SOLUTIONS INC.WHICH SKYSALT SEEKS EXEMPTION................................... ..........6

THE EXTENT OF RELIEF STRUMPHER ENTE RPRISES INC. dba AMERISPEC HOME
INSPECTION SERVICE and AERIAL PHOTO GRAPHY & VIDEO SOLUTIONS INC. SEEKS
AND THE REASON STRUMPHER ENTERPRISE S INC. dba AMERISPEC HOME
INSPECTION SERVICE and AERIAL PHOTO GRAPHY & VIDEO SOLUTIONS INC. SEEKS THE
RELIEF...................................

................................................... ...............................................8

THE REASONS WHY GRANTING STRUMPHER E NTERPRISES INC. dba AMERISPEC
HOME INSPECTION SERVICE and AERIAL P HOTOGRAPHY & VIDEO SOLUTIONS INC. REQUEST WOULD BE IN THE PUBLIC INTER EST ................................................... .................12

THE REASONS WHY GRANTING THE EXEMPTI ON WOULD NOT ADVERSELY AFFECT
SAFETY..............................

................................................... .................................................14

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER.................................. ......24

ANY ADDITIONAL INFORMATION, VIEWS, O R ARGUMENTS AVAILABLE TO SUPPORT
STRUMPHER ENTERPRISES INC. dba AMERI SPEC HOME INSPECTION SERVICE and
AERIAL PHOTOGRAPHY & VIDEO SOLUTIONS INC. REQUEST ..................................... .........25

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

................................................... ...........................................25

APPENDICES................................................................................................ ...........................................263 GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level
AOI Area of Interest
ATC Air Traffic Control ATO Air Traffic Organizati on AV Aerial Vehicle CFR Code of Federal Regul ations
COA Certificate of Authori zation
FAA Federal Aviation Admi nistration FAR Federal Aviation Regu lation
GCS Ground Control Statio n GPS Global Positioning Sy stem LOL Loss of Link NAS National Airspace Sys tem
NOTAM Notice to Airman
PIC Pilot In Command
Section 333 FAA Modernization and Refo rm Act of 2012 (FMRA) Section 333 SO Safety Observer SOP Standard Operating P rocedures
UA Unmanned Aircraft UAS Unmanned Aircraft Sys tem VFR Visual Flight Rules
VLOS Visual Line of Site VMC Visual Meteorological Conditions
VTOL Vertical Takeoff and L anding4 SUMMARY

Strumpher Enterprises Inc. dba AmeriS pec Home Inspection Service and Aerial Photography & Video Solutions Inc. seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 1 .7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1 ), 91.409(a)(1) & (a) (2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to S ection 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permi t Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions Inc. to operate an Unmanned Airc raft System (UAS) for the commercial purpose o f conducting aerial video and photography for
residential and commercial real estate in spections, real estate photography, special private events, and landscape over certain areas of the U nited States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Strumpher Enterprises Inc. dba AmeriS pec Home Inspection Service and Aerial Photography & Video Solutions Inc. provides its clients with expertise and knowledge in residential and commercial inspections and solutions to i ncrease efficiency, productivity and effectiveness. Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions Inc. also provides its cl ients with high quality digital content for use in their personal projects. Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service has over 5 years of professional experience in video and photography of real estate and is recognized a s an expert in their field. The objective of S trumpher Enterprises Inc. dba AmeriSpec Home Inspec tion Service and Aerial Photography & Video So lutions Inc. aerial video and photography operation s is to provide high quality imaging for a var iety of commercial/private events, and residential uses, specifically targeting:
* Residential & Commercial Real Est ate Inspections * Real Estate Video & Photography f or listings * 3D Mapping of Properties * Special Private Events (Wedding V ideos and Photography) * Increase public knowledge of UAS and promote safe UAS operations.

BACKGROUND Unmanned Aircraft Systems: DJI Phantom 3 UAS

Strumpher Enterprises Inc. dba AmeriS pec Home Inspection Service and Aerial Photography & Video Solutions Inc. seeks an exemption t o operate DJI systems for compensation for hire wit hin
the NAS. The DJI Phantom 3 is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) w ith a Ground Control Station (GCS) utilizing el ectronic tablet or smart phone systems. The DJI Pha ntom 3 has a maximum gross weight of approximate ly 2 pounds 13 ounces, while having a length of 18 inches, width of 13 inches, height of 8 i nches, and a maximum speed of approximately 30 knots. The DJI Phantom 3 is equipped with four main rotors; driven by Lithium Polymer batter y powered electric motors.5

The DJI Phantom 3 UA will be operated by Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions Inc. and will be registered in Accordance with 49 U.S.C. 44103, Registrat ion of Aircraft, as well as 14 C.F.R Part 47, Aircr aft Registration, and marked in accordance wit h 14 C.F.R. Part 45, Identification and Registratio n Marking.
BASIS FOR PETITION Petitioner, Strumpher Enterprises Inc. d ba AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions Inc., pursuan t to the provisions of the Federal Aviation Regulat ions (14 C.F.R. § 11.61) and the FAA Modernizatio n and Reform Act of 2012 (FMRA), Section 333, Speci al Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate the DJI Phantom 3 UAS in the Nationa l Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407( a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). In consideration of the speed, weight, s ize, and limited operating area associated with the unmanned aircraft and its operation, Strump her Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video Solu tions Inc.’s operation of DJI Phantom 3 UAS meets t he
conditions of FMRA Section 333 and therefor e, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingly, Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions Inc. requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maint enance that only apply to aircraft with an airwort hiness certificate. Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions Inc. submits that the reque sted relief is proper since an equivalent level of safety will be ensured. Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions Inc. will use experienced personnel or technicians to perform maintenance, alterations, or preventive mai ntenance on the UAS using the methods, techniques, and practices prescribed in the operating d ocuments (i.e., Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual). Furthermore, Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions Inc. will document and maintain al l
maintenance records for the DJI Phantom 3 U AS. Relief from certain requirements of Sect ion 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in comman d, is requested by Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aeria l Photography & Video Solutions Inc. to the extent necessary to allow a Pilot in Comman d (PIC) holding a private pilot or higher level certificate, as well as an airman medical c ertificate, and who has demonstrated, by meeting minimum flight- hour and currency requireme nts, that the PIC is able to safely operate the
DJI Phantom 3 UAS in a manner consistent wi th this exemption, including evasive and emergency maneuvers and maintaining appropriate dista nces from people, vessels, vehicles and structures.

Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography &
Video Solutions Inc. seeks relief from Sect ion 91.7(a), entitled Civil aircraft airworthiness, because6

the DJI Phantom 3 UAS does not require an ai rworthiness certificate in accordance with 14 C.F.R

. Part 21, Subpart H. As such, Strumpher Enter prises Inc. dba AmeriSpec Home Inspection Service a nd Aerial Photography & Video Solutions Inc. su bmits that they will ensure that the DJI Phantom 3 UAS is in an airworthy condition, prior to every flight, by determining that the UAS is in complian ce with the operating documents (i.e., Monthly Maint enance Log, and DJI Phantom 3 Instruction Manual),
and that the aircraft is in a condition for safe flight. Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions Inc. also seek an exemption from the requirements of Section 91.121, entitled Altimeter Settings, as the DJI Phantom 3 UA will not have a typical barometric altimeter onboar d. However, altitude information of the DJI Pha ntom 3 UA will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which
downlinks from the UAS to the GCS for active monitoring of the flight path. This altitude information, combined with Strumpher Enterpr ises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions Inc.’s operation of the DJI Phantom 3 within visual line o f sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. Additionally, Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions Inc. seek an e xemption from the requirements of Section 91.151(b)

, entitled Fuel requirements for flight in VFR conditions. Strumpher Enterprises Inc. dba AmeriSp ec Home Inspection Service and Aerial Photograp hy & Video Solutions Inc. submits that safety will not be affected by operation of the DJI Phantom 3 UAS during daylight hours in visual meteorologica l conditions (VMC) under visual flight rules ( VFR), with enough battery power to fly for a total duration of approximately 18 minutes to the first point of intended landing and, assuming norma l cruising speed, to fly after that for at lea st 5 minutes. In accordance with 14 C.F.R. § 11.81, St rumpher Enterprises Inc. dba AmeriSpec Home Inspect ion Service and Aerial Photography & Video Solut ions Inc. provides the following information in sup port of its petition for exemption:

A. Name and Address of The Petitioner.
The name and address of the Petitioner and point of contact is: Dana L. Strumpher – President Strumpher Enterprises Inc. dba AmeriSpec Ho me Inspection Service 35 Twilight Lane Springfield, IL. 62712
Phone: 217-529-5354
Email: dstrumpher@amerispec.net

Dana L. Strumpher – President Aerial Photography & Video Solutions Inc. 35 Twilight Lane Springfield, IL. 62712
Phone: 217-691-8254
Email: iknowhomes@comcast.net7

B. The Specific Sections Of 14 C.F.R. from which St rumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photogra phy & Video Solutions Inc. Seeks Exemption.

1. Strumpher Enterprises Inc. dba AmeriSpec Home Inspe ction Service and Aerial Photography & Video Solutions Inc. Seek Exemption f rom the Requirements of Section 61.113(a) And (b).

Section 61.113, entitled Private pil ot privileges and limitations: Pilot in command, su bsections (a) and (b) prescribe the following, in relevant part: (a) No person who holds a priv ate pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying pass engers or property for compensation or hire; nor ma y that person, for compensation or hi re, act as PIC of an aircraft.

(b) A private pilot may, for compensat ion or hire, act as PIC of an aircraft in connectio n with any business or employment if— (1) The flight is only incidenta l to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire.

2. Strumpher Enterprises Inc. dba AmeriSpec Home Inspe ction Service and Aerial Photography & Video Solutions Inc. Seek Exemption f rom the Requirements of Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the followin g: (a) No person may operate a civil aircraft unless it is in an airworthy condition.

3. Strumpher Enterprises Inc. dba AmeriSpec Home Inspe ction Service and Aerial Photography & Video Solutions Inc. Seek Exemption f rom the Requirements of Section
91.121.

Section 91.121, entitled Altimeter se ttings, subsection (a), states the following, in pa rt: (a) Each person operating an aircraft shall main tain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an a ltimeter that is set, when operating—

(1) Below 18,000 feet MSL, to-- (i) The current reported altimet er setting of a station along the route and within 100 nautical miles of the aircraft;

(ii) If there is no station withi n the area prescribed in paragraph (a)(1)(i) of thi s section, the current reported altimeter setting of an appropriate available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of the dep arture airport or an appropriate altimeter setting available before departure.8 4. Strumpher Enterprises Inc. dba AmeriSpec Home Inspe ction Service and Aerial Photography & Video Solutions Inc. Seek Exemption f rom the Requirements of Section 91.151(b).

Section 91.151, entitled Fuel requir ements 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 fu el to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.

5. Strumpher Enterprises Inc. dba AmeriSpec Home Inspe ction Service and Aerial Photography & Video Solutions Inc. Seek Exemption f rom the Requirement of Section 91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following: Each owner or operator of an aircraf t— (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragra ph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter[. ]

6. Strumpher Enterprises Inc. dba AmeriSpec Home Inspe ction Service and Aerial Photography & Video Solutions Inc. Seek Exemption f rom the Requirements of Section 91.407(a)(1)

Section 91.407, entitled Operation af ter maintenance, preventive maintenance, rebuilding , or alteration, subsection (a)(1), states the following: (a) No person may operate any aircraf t that has undergone maintenance, preventive maintenance, rebuilding, or alt eration unless—

(1) It has been approved for return to service by a per son authorized under § 43.7 of this chapter[.]

7. Strumpher Enterprises Inc. dba AmeriSpec Home Inspe ction Service and Aerial Photography & Video Solutions Inc. Seek Exemption f rom the Requirements of Sections 91.409(a)(1) And 91.409 (a) (2).

Section 91.409, entitled Inspections, subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section , no person may operate an aircraft unless, within the preceding 12 calendar months, it has had –9 (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. Strumpher Enterprises Inc. dba AmeriSpec Home Inspe ction Service and Aerial Photography & Video Solutions Inc. Seek Exemption f rom the Requirements of Sections 91.417(a) And 91.417(b).

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the followi ng: (a) Except for work performed in accordance with §§ 91. 411 and 91.413, each registered owner or operator shall keep the following records for th e 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 o r approved inspections, as appropriate, for each aircraft (including the airfr ame) and each engine, propeller, rotor, and appliance of an aircraft. The records must incl ude— (i) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of completion of the work performed; and (iii) The signature, and certificate num ber of the person approving the aircraft for return
to service.

(2) Records containing the following inf ormation: (i) The total time in ser vice of the airframe, each engine, each propeller, and each rotor. (ii) The current status o f life-limited parts of each airframe, engine, prop eller, rotor, and appliance. (iii) The time since last overhaul of all items installed on the aircraft whi ch are required to
be overhauled on a specified time basis. (iv) The current inspectio n status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are main tained. (v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directi ve number and
revision date. If th e AD or safety directive involves recurring action, the time and date
when the next action is required. (vi) Copies of the forms pr escribed by § 43.9(d) of this chapter for each majo r alteration to
the airframe and cur rently installed engines, rotors, propellers, and a ppliances. (b) The owner or operator shall retain the following re cords for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this s ection shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed.10 (2) The records specified in paragraph (a)(2) of this s ection shall be retained and transferred
with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a registered owner o r operator under § 43.11 of this chapter shall be retained until the defects are repa ired and the aircraft is approved for return to
service.
C. The Extent of Relief Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions I nc. Seek and the Reason AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions Inc. Seek The Relief.

1. Extent of Relief Strumpher Enterprises Inc. dba Ame riSpec Home Inspection Service and Aerial Photography & Video Solutions Inc. Seek and the Reason AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions In c. Seek Relief from Section 61.113(a) And (b).

Relief from Section 61.113(a) an d (b) entitled Private pilot privileges and limitat ions: Pilot in command, is requested to the extent nece ssary to allow a PIC holding a private pilot or hig her level certificate, as well as a current and valid airman medical certificate, and who has m et certain flight-hour and currency requirements, t o conduct the proposed UAS flight operations for compensation or hire. This relief is requested since th e limitations set forth in Section 61.113(a) and (b ) state that a private pilot may, for compensation or h ire, act as PIC of an aircraft in connection with a ny business or employment if: (1) The fligh t is only incidental to that business or employment ; and (2) The aircraft does not carry passengers o r property for compensation or hire. As set forth more fully below, St rumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video S olutions Inc. submits that an equivalent level of s afety
will be maintained because no PIC will b e allowed to operate the DJI Phantom 3 UAS unless that PIC has met certain flight-hour and curr ency requirements, demonstrating that the PIC is ab le to safely operate either the DJI Phantom 3 UAS in a manner consistent with the operations specifications as described in this exem ption, including evasive and emergency maneuvers, a s well as maintaining appropriate distances fro m people, vessels, vehicles and structures. Further, Strumpher Enterprises Inc . dba AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions Inc. Submi ts that all flights of the DJI Phantom 3 UAS, condu cted by the PIC pursuant to the grant of this Petition: (1) will be incidental to Strumpher Ente rprises Inc. dba AmeriSpec Home Inspection Servi ce and Aerial Photography & Video Solutions Inc.’s business; and (2) will not carry passeng ers or property for compensation or hire.

2. Extent of Relief Strumpher Enterprises Inc. dba Ame riSpec Home Inspection Service and Aerial Photography & Video Solutions Inc. Seeks and the Reason Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Ph otography & Video Solutions Inc. Seek Relief From Section 91.7(a).11

Relief from Section 91.7(a) entitl ed Civil aircraft airworthiness, is requested to th e extent required to allow Strumpher Enterprises Inc . dba AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions Inc. to deter mine that the DJI Phantom 3 UAS is in airworthy condition prior to every flight by Ensuring that the UAS is in compliance with the operating documents (i.e., the Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aer ial Photography & Video Solutions Inc. Aerial O perations Manual, Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual). Strumpher Enterprises Inc. dba Amer iSpec Home Inspection Service and Aerial Photograph y & Video Solutions Inc. seek the requested reli ef because the DJI Phantom 3 UAS does not require a n airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Strumpher Enterprises Inc. dba AmeriSpec Home Inspecti on Service and Aerial Photography & Video Solutions
Inc. will ensure that the DJI Phantom 3 UAS is in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maint enance Log, and DJI Phantom 3 Instruction Manual) prior to every flight, and further, determin e that the aircraft is in condition for safe flight , as stated
in the conditions and limitations below.

3. Extent of Relief Strumpher Enterprises Inc. dba Ame riSpec Home Inspection Service and Aerial Photography & Video Solutions Inc. Seeks an d the Reason Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Ph otography & Video Solutions Inc.
Seeks Relief From Section 91.121.

Relief from Section 91.121, entitl ed Altimeter settings, may be required to allow fli ght Operations of the DJI Phantom 3 UAS, which u tilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data li nk to downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any altitude informat ion concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), Strumpher Enterprises Inc. dba AmeriS pec Home Inspection Service and Aerial Photography & Video Solutions Inc. seeks the requested rel ief because the DJI Phantom 3 UAS altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, be fore each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply wit h the applicable conditions and limitations stated below. As more fully set forth herein, an eq uivalent level of safety will be maintained since t he DJI Phantom 3 UAS is equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pr essure setting will be established prior to each fl ight, and provides the PIC with altitude informati on o UA on the heads-up display of the GCS.

4. Extent of Relief Strumpher Enterprises Inc. dba Ame riSpec Home Inspection Service and Aerial Photography & Video Solutions Inc. Seeks an d the reason Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Ph otography & Video Solutions Inc. Seeks Relief from Section 91.151(b).12

Relief from Section 91.151(b) entitl ed Fuel requirements for flight in VFR conditions, is requested to the extent required to allow fl ights of the battery powered DJI Phantom 3 UA durin g daylight hours in visual meteorological cond itions (VMC), under visual flight rules (VFR), for a total duration of 18 minutes to the first point of intended landing and, assuming normal cruising spe ed, to fly after that for at least 5 minutes. St rumpher Enterprises Inc. dba AmeriSpec Home Inspect ion Service and Aerial Photography & Video Solut ions Inc. seeks the requested relief because withou t an exemption from Section 91.151(b), the flight time duration of the battery powered DJI Phantom 3 UAS will severely constrain the practicality of any aerial video or still photo flight operatio ns that Strumpher Enterprises Inc. dba AmeriSpec Hom e Inspection Service and Aerial Photography & Video Solutions Inc. propose to conduct pursuant t o this Petition. Significantly, as set forth below, t he technical specifications of the DJI Phantom 3 UA S, the DJI Phantom 3 operating documents, and Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video Solut ions Inc. proposed operating limitations, ensure th at Strumpher Enterprises Inc. dba AmeriSpec Hom e Inspection Service and Aerial Photography & Video Solutions Inc. will safely operate the batte ry powered DJI Phantom 3 UAS during daylight hours in visual meteorological conditions (VMC), unde r visual flight rules (VFR), with enough battery po wer to fly for a total duration of 18 minutes to the first point of Intended landing and, assuming normal cruising speed, to fly after that for at lea st 5 minutes.

5. Extent of Relief Strumpher Enterprises Inc. dba Ame riSpec Home Inspection Service and Aerial Photography & Video Solutions Inc. and the R eason Strumpher Enterprises Inc. AmeriSpec Home Inspection Service and Aerial Photog raphy & Video Solutions 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, Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions Inc. requests relief from these Sec tions because the DJI Phantom 3 UAS does not requi re airworthiness certificates. As set forth more fu lly below, the DJI Phantom 3 UAS meets the condi tions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, Stru mpher Enterprises Inc. dba AmeriSpec Home Inspectio n Service and Aerial Photography & Video Solut ions Inc. will use trained technicians to perform maintenance, alterations, or preventive main tenance on the UAS using the methods, techniques, and practices prescribed in the UAS operatin g documents (i.e., the Strumpher Enterprises Inc. d ba AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions Inc. Aerial Operatio ns Manual, Monthly Maintenance Log, and DJI Pha ntom 3 Instruction Manual). Furthermore, Strumpher Enterprises Inc. dba AmeriSpec Hom e Inspection Service and Aerial Photography & Video
Solutions Inc. will document and maintain al l maintenance records for the DJI Phantom 3 UAS.

D. The Reasons Why Granting Strumpher Enterprises I nc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video Solutio ns Inc. Request Would Be In The Public Interest; Th at Is, How It Would Benefit The Public As A Whole.13

Granting the present Petition will fur ther the public interest by allowing the Strumpher Enterprises Inc. dba AmeriSpec Home Inspectio n Service and Aerial Photography & Video Solutions Inc. to safely, efficiently, and economically perform aerial video and photography for real esta te, special private events, and landscape over ce rtain areas of the United States. Additionally, use of the DJI Phantom 3 and UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits t o the economy. Notably, the benefits of Strumpher Enterprises Inc. dba AmeriSpec Home Inspectio n Service and Aerial Photography & Video Solutions Inc. proposed operation of the DJI Phantom 3 UAS will be realized without implicating any privac y issues.

1. The Public Will Benefit From Decreas ed Congestion Of The NAS. The DJI Phantom 3 UAS is battery powered and serves as a safe, efficient, and economical
alternative to the manned aircraft traditiona lly utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform a erial acquisitions, an exemption allowing the use o f a
DJI Phantom 3 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 m anned aircraft operating in the NAS, congestion aro und airports caused by arriving and departing air craft will be reduced. The DJI Phantom 3 UAS does n ot require an airport to takeoff or land. Likewi se, a reduction of manned aircraft conducting aeria l video and photography missions would result in fewe r aircraft that must be handled by air traffic cont rol during the ground, takeoff, departure, arriva l, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficie ncy Of The DJI Phantom 3 UAS. Conducting aerial acquisitions with the DJI Phantom 3 UAS, instead of manned aircraft, wil l Greatly benefit the public by drastically red ucing the levels of air and noise pollution generat ed during traditional aerial video and still pho tography flight operations. By using battery power and Electric motors, the DJI Phantom 3 UAS produc es no air pollution, and is the most viable Environmentally conscious alternative to the cabin class, internal combustion engine aircraft th at are typically utilized for aerial video and photo graphy, while burning approximately 20-30 gallons p er hour of leaded aviation fuel. The DJI Phantom 3 UAS, while reducing the carbon footprint of aeri al acquisitions, also eliminates noise pollution , as the UAS is propelled by battery powered electr ic motors, rather than an internal combustion en gine. By using the DJI Phantom 3 UAS to perfor m aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircr aft flight operations, will be substantially redu ced or completely eliminated. Aside from the lack o f flight crew members located onboard the aircraft, th e DJI Phantom 3 UAS (weighing approximately 2 pounds 13 ounces at its maximum gross weight with lengths of 15 inches by 15 inches, and with no fuel on board), has less physical potential f or collateral damage to life and property on the gr ound, and in the air, compared to the manned aircra ft that typically conduct similar operations (weigh ing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).14

3. 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 UAS is also an economical altern ative to using manned aircraft to conduct similar aeria l operations. As such, operation of the DJI Phantom 3 UAS will allow United States based companies, like Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Vi deo Solutions Inc. to remain competitive and contribute to growth of the U.S. economy. Spec ifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regula tory actions phasing out leaded aviation fuels, U.S

. owned and operated companies must adopt new an d alternative technology in order to remain competitive. Operating the battery powered DJI Phantom 3 UAS is one such technology that not only allows companies greater operational flexibili ty compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft. By operating the DJI Phantom 3 UAS, comp anies such as Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial P hotography & Video Solutions Inc. can remain competitive and profitable, and therefore, pro vide greater job stability to employees and contrac tors, which will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through commercial use of the DJI Phantom 3 UAS, provides a stable workforce that increases consumer spending; improves local, s tate, and federal tax revenues; and allows companie s to invest in research and development in order to remain competitive both in the United States an d
abroad.

4. There Are No Privacy Issues. Similar to the manned aerial acquisiti on flight operations that have been conducted for d ecades, Strumpher Enterprises Inc. dba AmeriSpec Hom e Inspection Service and Aerial Photography & Video Solutions Inc.’s proposed operation of the D JI Phantom 3 UAS will not implicate any privacy iss ues. Specifically, the DJI Phantom 3 UAS will be operated only in compliance with operating document s (i.e., the Strumpher Enterprises Inc. dba Am eriSpec Home Inspection Service and Aerial Photogra phy & Video Solutions Inc. Aerial Operations Man ual, Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual) which requires property owner involvement as well as local law enforcement notification, and in accordance with the Fed eral Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Level of Safe ty At Least Equal To That Provided By The Rule From which Strumpher Enterprises Inc. dba Am eriSpec Home Inspection Service and Aerial Photography & Video Solutions Inc. Seek s Exemption.

1. Reasons Why The DJI Phantom 3 UA Meets The Conditio ns Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333.

In consideration of the size, wei ght, speed, and limited operating area associated w ith the unmanned aircraft and its operation, Strumph er Enterprises Inc. dba AmeriSpec Home Inspection15

Service and Aerial Photography & Video Solut ions Inc. operation of the DJI Phantom 3 UAS meets the conditions of FMRA Section 333, and will not require an airworthiness certificate in accord ance with 14 C.F.R. Part 21, Subpart H.

Section 333 provides authority fo r a UAS to operate without airworthiness certificat ion and sets forth requirements for considering whet her a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to na tional security. Specifically, FMRA Section 333 sta tes the following, in part:

(a) In General.--Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of enactment of this Act, t he Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the plan and r ulemaking required by section 332 of this Act or the guidance required by section 334 of this Act.

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under subsection (a), the secret ary shall determine, at a minimum

(1) which types of unmanned aircraft systems, if any, a s a result of their size, weight, speed, operational capability, proximity to airport s 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 n ational security; and

(2) whether a certificate of waiver, certificate of aut horization, or airworthiness certification under section 44704 of title 49, Unit ed States Code, is required for the operation of unmanned aircraft systems identified u nder paragraph (1).

(c) Requirements for Safe Operation.--If the Secretary determines under this section that certain unmanned aircraft systems may operate safel y in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system.

In seeking this exemption, Strump her Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions In c. submits that the DJI Phantom 3 UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI Phantom 3 UAS; (b) the pilot certificat ion requirement; and (c) the specific operating lim itations.

a. The Specifications Of The DJI Phantom 3 UAS Demo nstrates Its Safe Characteristics.

The DJI Phantom 3 UAS does not crea te a hazard to users of the NAS or the public, or o therwise pose a threat to national security consider ing its size, weight, speed, and operational capabi lity.16 i. Technical Specifications Of The DJI Phantom 3 UAS

The technical specifications of the DJI Phantom 3 UAS are set forth by the DJI Phantom 3 Specifications and Safety Data Sheet, attac hed hereto as Exhibit A.

ii. The DJI Phantom 3 UAS Autonomous Flight And Navigat ion Modes Enable the UASs To Remain Within A Defined Operational Area.

The DJI Phantom 3 UAS may be operate d in both manual and fully autonomous flight modes. A complete description of the flight and navi gational modes of the DJI Phantom 3 UAS is provided at pages 11-17 of the DJI Phantom 3 User Manua l, attached hereto as Exhibit B.

iii. The DJI Phantom 3 UAS is Designed For Automatic Ret urn To Home Point Or Hover In The Event of Loss of The Control Link Or Navigation.

When the Control Link is lost, the DJ I Phantom 3 UAS will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the D JI Phantom 3 UAS does not reacquire control link da ta 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 3 UAS is set forth at pages 12 through 15 of the DJI Phantom 3 User Manual , attached hereto as Exhibit B.

iv. The DJI Phantom 3 GCS And Its Operation.

A complete description of the operatio n and specifications of the DJI Phantom 3 GCS and f light control software is provided at pages 23 th rough 38 of the DJI Phantom 3 User Manual. The DJI
Phantom 3 User Manual is attached hereto as Exhibits B.

b. Flight Operations Of DJI Phantom 3 UAS is Limite d To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer.

Strumpher Enterprises Inc. dba AmeriSpe c Home Inspection Service and Aerial Photography & Video Solutions Inc. will only utilize cert ificated pilots who possess a current and valid air man medical certificate to act as a pilot in co mmand (PIC) of the DJI Phantom 3 UAS. Additionally, a safety observer will assist all pilots duri ng flight time.

c. Flights Of DJI Phantom 3 UAS Will Be Conducted P ursuant To Specific Operating Limitations.

In seeking this exemption, Strumpher En terprises Inc. dba AmeriSpec Home Inspection Servic e and Aerial Photography Video & Solutions In c. proposes to commercially operate DJI Phantom 3 UAS for the special purpose of conducting a erial video and photography over certain areas of United States, pursuant to the following sp ecific operating limitations:

1. Operations authorized by this grant of exemption wi ll be limited to the following aircraft17 described in the operating documents, rotorcr aft UAS weighing less than 55 pounds maximum gross weight: DJI Phantom 3 Unmanned Aircraft Systems. Proposed operations of any other aircraft will require a new petition or a petition to amend this
grant.
2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photography. 3. The UAS may not be flown a t an indicated airspeed exceeding 20 knots. 4. The UAS must be operated a t an altitude of no more than 500 feet above ground level (AGL), as indicate d by the procedures specified in the operating docu ments 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 o f sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision u naided by any device other than corrective lenses, as specified on the PIC’s FAA- issued airman medical certificate. 6. The use of first person v iew (FPV) by the PIC or safety observer (SO) is not permitted. 7. All operations must utili ze a safety observer (SO). The SO may be used to sa tisfy the VLOS requirement as long as t he PIC always maintains VLOS capability. The SO and PIC must be
able to communicate verb ally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the f light and
cannot transfer his or h er designation for the duration of the flight. The PIC must ensure that the SO can perform the functions prescribed in the operating documents

. 9. The SO must not perform any other duties beyond a ssisting 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.
10. The operating documents and the grant of exemptio n must be accessible during UAS operations and made available to the Administrato r upon request. If a discrepancy exists
between the conditions and limitations containe d in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption take precedence and m ust be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. I t 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 would affect the basis upon which the FAA granted the exe mption, then the operator must pe tition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS-8 0) may be contacted if questions arise regarding up dates or revisions to the operatin g documents.
11. 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 tha t affects the safe operation of the UAS, the aircraft is prohibited from operating until the n ecessary maintenance has been performed18 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 mainte nance and alterations must be properly
documented in the aircraft records.
12. Any UAS that has undergone maintenance or alteratio ns that affect the UAS operation or flight characteristics, e.g. replacement of a fligh t critical component, must undergo a functional test flight. The PIC who conducts the fu nctional test flight must make an entry in
the aircraft records.
13. The pre-flight inspection must account for all pote ntial discrepancies, e.g. inoperable components, items, or equipment, not already covere d in the relevant sections of the operating documents.
14. The operator must follow the UAS manufacturer’s air craft/component, maintenance, overhaul, replacement, inspection, and life limit r equirements.
15. The operator must carry out its maintenance, inspec tions, and record keeping requirements, in accordance with the operating docu ments. Maintenance, inspection, alterations, and status of replacement/overhaul com ponent parts must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature of the authorized person returning the UA S to service.
16. Each UAS operated under this exemption must comply with all manufacturer Safety
Bulletins.
17. The authorized person must make an entry in the air craft record of the corrective action taken against discrepancies discovered between insp ections.
18. The PIC must possess at least a private pilot certi ficate and at least a current third- class
medical certificate.
19. The operator may not permit any PIC to operate unle ss 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 dis tances from persons, vessels, vehicles and structures. PIC qualification flight h ours must be logged in a manner consistent with 14 C.F.R. §61.51(b). Flights for th e purposes of training the operator’s PICs are permitted under the terms of the exemption. How ever, training operations may only be conducted during dedicated training session s. During training, proficiency, and experience-building flights, all persons not essent ial for flight operations are considered nonparticipants, and the PIC must operate the UA w ith appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.1 19.
20. UAS operations may not be conducted during night, a s defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorolo gical conditions (VMC). If flight at night is required, a special request will be made a t the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized.
21. The UAS may not operate within 5 nautical miles of an airport reference point as denoted on a current FAA-published aeronautical chart unles s a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a19 NOTAM as required by the operator’s COA. The letter of agreement with the airport management must be made available to the Administra tor upon request.
22. 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 stat ute miles from the PIC.
23. If the UAS loses communications or loses its GPS si gnal, it must return to a predetermined location within the planned operating ar ea and land or be recovered in accordance with the operating documents.
24. The PIC must abort the flight in the event of unpre dicted obstacles or emergencies in accordance with the operating documents.
25. The PIC is prohibited from beginning a flight unles s (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 25% battery power remain ing.
26. The operator must obtain an Air Traffic Organizatio n (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operati ons under the grant of exemption. This COA will also require the operator to request a Not ice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours pri or to the operation. All operations shall be conducted in accordance with airspace requiremen ts in the ATO issued COA including class of airspace, altitude level and potential tra nsponder requirements.
27. All aircraft operated in accordance with the exempt ion must be identified by serial number, registered in accordance with 14 C.F.R. part 47, an d have identification (N- Number) markings in accordance with 14 C.F.R. part 45, Subp art C. Markings must be as large as practicable.
28. Before conducting operations, the radio frequency s pectrum used for operation and control of the UAS must comply with the Federal Com munications Commission (FCC) or other appropriate government oversight agency requi rements.
29. The documents required fewer than 14 C.F.R. 91.9 an d 91.203 must be available to the PIC at the Ground Control Station of the UAS any time t he UAS is operating. These documents must be made available to the Administrator or any law enforcement official upon request.
30. The UAS must remain clear and yield the right of wa y to all manned aviation operations
and activities at all times. 31. The UAS may not be operated by the PIC from any moving device or vehicle. 32. Flight operations must be cond ucted at least 500 feet from all nonparticipating p ersons (persons other than the PIC , SO, operator trainees or essential persons), vess els, vehicles,
and structures unless:

a. Barriers or structures are present that sufficientl y protect nonparticipating persons from the UA and/or debris in the event of an accide nt. The operator must ensure that nonparticipating persons remain under such protecti on. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or;
b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehi cles or structures has granted permission and the P IC has made a safety assessment of the risk of operating closer to those objects and d etermined that it20

does not present an u ndue 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).

33. All operations shall be conducted over private or c ontrolled-access property with permission from the land owner/controller or author ized representative. Permission from land owner/controller or au thorized representative will be obtained for each f light to be
conducted.
34. Any incident, accident, or flight operation that tr ansgresses the lateral or vertical boundaries of the operational area as defined by th e applicable COA must be reported to the FAA's UAS Integration O ffice (AFS-80) within 24 hours. Accidents must be r eported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB
Web site: www.ntsb.gov

.

2. Reasons Why An Exemption From The Requirements O f Section 61.113(a) And (b) Would Not Adversely Affect S afety.

Strumpher Enterprises Inc. dba AmeriS pec Home Inspection Service and Aerial Photography & Video Solutions Inc. submits that the equiv alent level of safety established by Section 61.113 (a) and
will be maintained because no PIC will be a llowed to operate the DJI Phantom 3 UAS unless that PIC has demonstrated, by meeting minimum flight -hour and currency requirements, that the PIC is ab le to safely operate the DJI Phantom 3 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintai ning appropriate distances from people, vessels,
vehicles and structures. Considering Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions Inc. proposed area of operations, and the operating limitations set forth-above; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemptio n No. 11062); and the airmanship skills necessary t o safely operate the DJI Phantom 3 UAS, Strum pher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video Solu tions Inc. submits that the additional manned airmanship experience of a commercially cer tificated pilot would not correlate to the airmansh ip skills necessary for Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aeri al Photography Video Solutions Inc.’s specific proposed flight operations.

The FAA has previously granted relief f rom Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material resp ects, to those presented herein (e.g. Exemption Nos

. 11062, 11063, 11064, 11065, 11066, 11067, 1 1080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). Strumpher Enterprises Inc. dba AmeriSpe c Home Inspection Service and Aerial Photography & Video Solutions Inc. will not allow any PIC to operate the DJI Phantom 3 UAS unless that PIC h as demonstrated, by meeting minimum flight-hou r requirements or the DJI Phantom 3 UAS training and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 UAS in a21

manner consistent with this exemption, incl uding evasive and emergency maneuvers and maintaining appropriate distances from peop le, vessels, vehicles and structures. Specifically, the PIC must have accumu lated and logged, in a manner consistent with 14 C. F.R. § 61.51(b), 25 hours of total time as a UAS r otorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In addition to the hour require ments, the PIC must accomplish 3 takeoffs and landi ngs in the preceding 90 days (for currency purp oses). As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regu lations will ensure an equivalent level of safety d uring Strumpher Enterprises Inc. dba AmeriSpec Ho me Inspection Service and Aerial Photography & Vide o Solutions Inc. proposed operations. The Adm inistrator 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 require d that prior to conducting operations for the purpo se of motion picture filming (or similar operatio ns), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot inclu ding at least 10 hours logged as a UAS pilot with a multi-rotor UAS. Prior to operations under Exempti on No. 11062, the PIC must also have accumulat ed and logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption. For clarification, the FAA considers these mini mum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi-rotor time and the 10 hours may be included in the tot al 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (f or currency purposes). The FAA finds that at a minimum, the flight-hour requirements in Exemption No. 11062 are appropriate to practice and b uild proficiency in the skills necessary to safely conduct the petitioner’s proposed operation s. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and exp erience-building flights can also be conducted unde r the grant of exemption to accomplish the re quired flight time. During training, proficiency, a nd experience-building flights the PIC is requ ired to operate the UA with appropriate distances i n accordance with 14 C.F.R 91.119.

Exemption No. 11138.

Accordingly, Strumpher Enterprises Inc. d ba AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions Inc. will ens ure safe operations by not allowing any PIC to oper ate the DJI Phantom 3 UAS unless that PIC has d emonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 UAS in a mann er consistent with the exemption, including ev asive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.22 3. Reasons Why An Exemption From The Requirements Of S ection 91.7(a) Would Not Adversely Affect Safety.

The equivalent level of safety establish ed by Section 91.7(a) will be maintained because pr ior to every flight, Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions Inc. will ensu re that the DJI Phantom 3 UAS is in an airworthy condition based upon the UAS’s compliance wi th its operating documents and as stated in the
conditions and limitations herein.

Additionally, the FAA has previously gra nted relief from Section 91.7(a) specific to UAS, i n circumstances similar, in all material resp ects, to those presented herein (e.g. Exemption Nos

. 11062, 11063, 11064, 11065, 11066, 11067, 1 1080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 1 1161).

4. Reasons Why An Exemption From The Requirements Of S ection 91.121 Would Not Adversely Affect Safety.

The equivalent level of safety establish ed by Section 91.121 will be maintained because the
altitude information of the DJI Phantom 3 U AS will be provided to the PIC via GPS equipment an d a radio communications telemetry data link, w hich downlinks from the UA to the GCS for active monitoring of the flight path and altitude. This altitude information, combined with Strumpher Enterprises Inc. dba AmeriSpec Home Inspect ion Service and Aerial Photography & Video Solution s Inc.’s operation of the DJI Phantom 3 UAS w ithin visual line of sight, at or below 500 feet AG L, will Ensure a level of safety equivalent to Sect ion 91.121. The altitude information will be genera ted by GPS equipment installed onboard the aircraf t. Prior to each flight, a zero altitude initiation point is automatically established by the UAS at gro und level. The FAA has previously granted relief fr om Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063

, 11064, 11065, 11066, 11067, 11080, 11109, 1 1112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

5. Reasons Why An Exemption From The Requirements Of S ection 91.151(b) Would Not Adversely Affect Safety.

A grant of this exemption would ensure a n equivalent level of safety established by 14 C.F. R. Section 91.151(b) as a result of (1) the te chnical specifications of the DJI Phantom 3 UAS; (2 ) the limitations on the proposed flight operatio ns; and (3) the location of the proposed flight ope rations. Accordingly, Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions Inc. will ens ure that it will safely operate the battery powered DJI Phantom 3 UAS during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 18 minutes to the first point o f intended landing and, assuming normal Cruising sp eed, to fly after that for at least 5 minutes.23

Here, as in Exemption No. 11109, the tec hnical specifications of the DJI Phantom 3 UAS; the limitations on the proposed flight operatio ns; and the location of the proposed operations, wi ll ensure an equivalent level of safety establ ished by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Phantom 3 UAS p rovides audible and visual warnings to the PIC at t he GCS when the UAS experiences low battery vo ltage, the first warning occurring at approximately 33% remaining battery power, and again at a pproximately 10% remaining battery power. At the critically low battery level, the DJI Phant om 3 UAS will descend and land automatically. Significantly, previous exemptions grant ed by the FAA concerning Section 91.151 establish t hat safety is not adversely affected when the t echnical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, incl uding Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted re lief from Section 91.151 specific to UAS, in circumstances similar, in all material resp ects, to those presented herein (e.g. Exemption Nos . 8811, 10808, 10673, 11042, 11062, 11063, 11064, 1 1065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 1 1159, 11160, 11161).

6. Reasons Why An Exemption From The Requirements Of S ections 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, Strumpher Ent erprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions Inc. s ubmits that the equivalent level of safety with reg ard to the regulatory maintenance and alteration r equirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91 .417(a) & (b) will be met because, Strumpher Enterp rises Inc. AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions Inc. will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practice s prescribed in the operating documents (i.e., the Strumpher Enterprises Inc. dba AmeriSpec Ho me Inspection Service and Aerial Photography & Vide o Solutions Inc. Aerial Operations Manual, Mo nthly Maintenance Log, and DJI Phantom 3 Instructio n Manual). Furthermore, Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions Inc. w ill document and maintain all maintenance records f or the DJI Phantom 3 UAS. Since the DJI Phantom 3 UAS will be insp ected as prescribed by the operating documents, Strumpher Enterprises Inc. dba AmeriSpec Ho me Inspection Service and Aerial Photography & Vide o Solutions Inc. will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of t he DJI Phantom 3 User Manual is attached hereto as Exhibit B; a copy of the DJI Phantom 3 UAS Maintenance LOG is attached hereto as Exhibit C. Likewise, the exemption sought will not adversely affect safety because Strumpher Enterpris es Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions Inc. will use trained technicians to perform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and practice s prescribed by the operating documents. Furthermore, the exemption sought would maintain an equivalent level of safety established by24

Sections 91.407, 91.417(a) and 91.417(b), b ecause all maintenance of the DJI Phantom 3 UAS wil l be performed by trained technicians. Maintenan ce will be documented and maintained utilizing the monthly maintenance log. Significantly, previous exemptions grant ed by the FAA concerning Sections 91.405(a), 91.407 (a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected whe n the technical characteristics and operating lim itations of the UAS are considered. In consideration of Strumpher Enterprise s Inc. dba AmeriSpec Home Inspection Service and Ae rial Photography & Video Solutions Inc. proposed operating limitations, the operating documents, an d the technical aspects of the DJI Phantom 3 UAS, Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions Inc. submits that safety will not be adversely affected by granting exemption fr om 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 FA A has previously granted relief specific to UAS in circumstances similar, in all material resp ects, to those presented herein (e.g. Exemption Nos

. 11062, 11063, 11064, 11065, 11066, 11067, 1 1080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 1 1161).

7. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 333 of the F AA Modernization and Reform Act of 2012 (FMRA) and 14C.F.R. § 21.16 entitled Special Condition s, Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions Inc. requests that the FAA prescri be special conditions for the intended operati on of the DJI Phantom 3 UAS, which contain such saf ety standards that the Administrator finds nece ssary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H , and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121

, 91.151(b), 91.405(a), 91.407(a)(1), 91.409( a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of th e UAS for the limited purpose of conducting aerial video and photography over certain areas of the U nited States for compensation or hire. FMRA Section 333 sets forth the requirements for conside ring whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a thre at to national security; and further, provides the authority for such UAS to operate without a irworthiness certification in accordance with any requirements that must be established for t he safe operation of the UAS in the NAS. Likewise, the Administrator may prescrib e special conditions pursuant to 14 C.F.R. § 21.16, for operation of the DJI Phantom 3 UAS, since t he airworthiness regulations of 14 C.F.R. Part 21 d o not contain adequate or appropriate safety stan dards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled Speci al Conditions, states the following:

If the FAA finds that the airworthiness regulations of this subchapter do not contain adeq uate or appropriate safety standards for an air craft, aircraft engine, or propeller because of a n ovel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes specia l
conditions and amendments thereto for t he product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety standards for the aircraft , aircraft engine or propeller as the FAA finds ne cessary to establish a level of safety equivalent t o that25

established in the regulations.

See 14 C.F.R. § 21.16. Therefore, in accordance with FMRA Secti on 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for Strumpher Enterprise s Inc. dba AmeriSpec Home Inspection Service and Ae rial Photography & Video Solutions Inc. intended operation of the DJI Phantom 3 UAS, which contain such safety standards that the Administrato r finds necessary to establish a level of safety eq uivalent to that established by 14 C.F.R. Part 21, S ubpart 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).

F. A Summary That Can Be Published In The Federal Register, stating: The Rules From Which Strumpher Enterprises Inc. dba AmeriSp ec Home Inspection Service and Aerial Photography & Video Solutions Seeks Exemption:

Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions Inc. seek 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), 9 1.407(a)(1), 91.409(a)(1)& (a)(2), and 91.417(a) & (b).

A Brief Description Of The Nature Of The Exemption Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photo graphy & Video Solutions Inc. Seeks:

This exemption will permit Strumpher Ent erprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions Inc. to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducti ng aerial video and photography over certain areas of
the United States.

G. Any Additional Information, Views, Or Arguments Available To Support Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Ser vice and Aerial Photography & Video Solutions Inc.’ s Request.

This Petition is made pursuant to the FA A Modernization and Reform Act of 2012 (FMRA) Secti on 333, which directs the Secretary of Transpo rtation to determine if certain UAS may operate saf ely in the NAS. As such, Strumpher Enterprises Inc . dba AmeriSpec Home Inspection Service and Aerial Photography & Video Solution’s Inc. 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 requirem ents for considering whether a UAS will create a ha zard to users of the NAS or the public, or other wise pose a threat to national security; and furthe r, provides the authority for such UAS to oper ate without airworthiness certification. As discussed in detail above, Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Serv ice and Aerial Photography & Video Solutions In c. will operate the DJI Phantom 3 UAS safely in the NAS, without creating a hazard to users of the N AS or the public, or otherwise pose a threat to nat ional security.26 CONCLUSION

As set forth herein, Strumpher Enterpris es Inc. dba AmeriSpec Home Inspection Service and A erial Photography & Video Solutions Inc. seeks an exemption pursuant to 14 C.F.R. § 11.61 and Sectio n 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation o f the DJI Phantom 3 UAS commercially, without an airworthiness certificate, for the limited purp ose of conducting aerial video and photography over certain areas of the United States. By grantin g this Petition, the FAA Administrator will be ful filling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by all owing Strumpher Enterprises Inc. dba AmeriSpec Ho me Inspection Service and Aerial Photography & Vide o Solutions to safely, efficiently, and econo mically operate the DJI Phantom 3 UAS commercially
within the NAS. WHEREFORE, in accordance with the Federa l Aviation Regulations and the FAA Modernization an d Reform Act of 2012, Section 333, Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video Solu tions Inc. respectfully requests that the Administr ator grant this Petition for an exemption from t he requirements of 14 C.F.R Sections 61.113(a) & (b ), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.4 07(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b ), and permit Strumpher Enterprises Inc. dba Ameri Spec Home Inspection Service and Aerial Photography & Video Solutions Inc. to operate the DJI P hantom 3 UAS commercially for the purpose of conducting aerial video and photography ove r certain areas of the United States.

Dated: December 18, 2015

Dana L. Strumpher – President Strumpher Enterprises Inc. dba AmeriSpec Ho me Inspection Service 35 Twilight Lane Springfield, IL. 62712
Phone: 217-529-5354
Email: dstrumpher@amerispec.net

Dana L. Strumpher – President Aerial Photography & Video Solutions Inc. 35 Twilight Lane Springfield, IL. 62712
Phone: 217-691-8254
Email: iknowhomes@comcast.net27

EXHIBITS INCLUDED:

A – DJI Phantom 3 Safety Guideline Sheet

B – DJI Phantom 3 Manufacturer’s User Manua l

C – Monthly Maintenance Log